Indonesia. Comprehensive data protection. Law

PDP LawLaw No. 27 of 2022 on Personal Data Protection (UU PDP)

In force

§1Summary

Synopsis

Indonesia's GDPR-style data protection law with lawful bases, rights, DPO, DPIA and 72-hour breach notice. Applies extraterritorially where processing has legal effect in Indonesia or on Indonesian citizens abroad.

Key themes
  • lawful bases
  • data subject rights
  • DPO
  • DPIA
  • breach notification
  • cross-border
  • criminal penalties
Unique features

Combines administrative fines of up to 2% of annual revenue with criminal sanctions; corporate criminal fines up to 10x.

SaaS relevance

Foreign SaaS processing Indonesians' data is in scope; PSE registration with KOMDIGI also applies to services offered in Indonesia.

§2Obligations

Extraterritorial
Yes
Breach notification
Individuals and agency within 72h (3x24h)
DPO
Conditional
Cross-border transfers
Equal or higher protection, binding safeguards, or consent
Maximum penalty
Administrative 2% of annual revenue; criminal up to 6 years/IDR 6bn (individual), corporate fines up to 10x

§3Dates

Key dates
  • Adopted
  • In force
  • Two-year transition ended 2024-10-17; implementing Government Regulation still in harmonisation; PDP Agency targeted 2026

§4Text and authority

Text
Authority
PDP Agency (not yet established); interim: Ministry of Communication and Digital Affairs (KOMDIGI)

§5Where it applies

Domestic law of
Indonesia

§6Sources and verification

Sources consulted
Verification

High confidence.

Agency status as of Feb 2026 per DLA Piper. Criminal maximum figures partly from general knowledge. [Link: official Indonesian (BPK JDIH); no verified government English translation]