Jakarta, INTI - Asosiasi E-commerce Indonesia (idEA) has submitted a number of recommendations to the government to ensure that the implementation of Government Regulation No. 17 of 2025 on Electronic System Governance for Child Protection (PP Tunas) can proceed efficiently while remaining aligned with the growth of Indonesia’s digital economic ecosystem.
The recommendations were delivered amid concerns that the development of implementing regulations for PP Tunas has not fully accommodated the needs of digital economy ecosystem players.
idEA Chairman Hilmi Adrianto stated, "First, regarding tiered and proportional risk classification. We suggest adopting a tiered or score-based system so that the classification better reflects actual risk profiles, in line with an evidence-based approach, the principle of safety by design, and global practices," said idEA Chairman Hilmi Adrianto during a virtual press conference organized by KADIN on Friday.
Proposing Principle-Based Risks Assessment
The first recommendation responds to provisions in the draft implementing regulation of PP Tunas concerning risk assessments for Electronic System Providers (PSE), which are considered too rigid as the indicators are limited to features and binary data.
If the provisions remain unchanged, many PSEs could potentially be categorized as high-risk for children despite already having child protection mitigation measures in place within their services.
Hilmi stated that the government should apply a principle-based approach in the implementing regulation of PP Tunas for assessing PSE risks.
Hilmi Adrianto stated, "The characteristics and business models of each platform need to be further reviewed proportionally so that assessments focus on the effectiveness of mitigation against specific risks and reasonable measures that have been undertaken, rather than merely on a rigid list of technical features," he said.
Highlighting Age Verification and Transition Period
The next recommendation concerns the age verification mechanism for PSEs, which idEA believes should not only apply to PSEs but also to operating system owners or app store providers on mobile devices.
Hilmi Adrianto stated, "The goal is to complement each other, enhance effectiveness, and avoid repeated technical burdens," said Hilmi.
idEA views that in the draft PP Tunas regulation, age verification provisions still lack clear technical standards and may create privacy and data security gaps, potentially increasing compliance costs and causing system fragmentation across platforms.
idEA hopes the government will involve partners more broadly in drafting the implementing regulations of PP Tunas so that the policy continues to uphold child protection principles while supporting digital economic growth.
Hilmi Adrianto stated, "We suggest providing a minimum transition period of 12 months so that implementation can be carried out through cross-ministerial coordination and industry involvement in an open and data-based manner," Hilmi concluded.
PP Tunas was enacted in March 2025 and is scheduled to take full effect in March 2026. The government is currently preparing a ministerial regulation as its implementing rule and has conducted public consultations as part of the drafting process.
Conclusion
idEA’s recommendations highlight the need for balanced regulation that protects children while sustaining innovation within Indonesia’s digital economy. By proposing a principle-based risk assessment, clearer technical standards for age verification, and a reasonable transition period, the association aims to ensure that PP Tunas is implemented effectively without creating unnecessary compliance burdens. The dialogue reflects the broader challenge of aligning regulatory safeguards with the continued growth of the digital ecosystem.
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