The implementation of PP Tunas, a government regulation aimed at protecting children in digital spaces, faces significant uncertainties that threaten the stability of digital platforms. The regulation mandates that Electronic System Providers (PSE) submit self-assessment results within three months, yet the absence of clear technical parameters creates confusion for industry players. This uncertainty risks undermining both compliance and the intended protection measures.
PP Tunas is established under Government Regulation No. 17 of 2025, which governs the management of electronic systems with a focus on child protection. The regulation seeks to create a robust framework to monitor and safeguard children’s online activities. However, experts warn that incomplete technical guidelines may hinder practical implementation and lead to inconsistent risk evaluations across platforms.
Challenges for Industry Actors
According to Indriyatno Banyumurti, Executive Director of ICT Watch, the success of PP Tunas heavily depends on transparent risk assessment indicators. Without detailed ministerial decisions outlining these technical benchmarks, PSEs face difficulties in accurately assessing and managing the risks associated with their platforms. The deadline to submit risk self-assessments, as stipulated in Article 62 of Ministerial Regulation No. 9 of 2026, intensifies the pressure on companies that must comply swiftly despite lacking clear instruction.
This regulatory ambiguity could lead to distorted interpretations and uneven enforcement. Inconsistent classification of platform risks may result in unjustified restrictions or overlooked vulnerabilities, weakening the regulation’s protective intent. For PSEs, navigating such uncertainty not only complicates compliance but also affects their operational planning and innovation capacity.
The Need for Digital Literacy and Inclusive Dialogue
The effectiveness of PP Tunas extends beyond legal mandates to the readiness of the wider ecosystem supporting children online. Digital literacy for parents, educators, and guardians is essential to empower them to guide children safely and responsibly in digital environments. Trubus Rahardiansah, a public policy expert from Universitas Trisakti, criticizes the government’s top-down approach, emphasizing the importance of multi-stakeholder engagement.
He suggests that incorporating dialogue with affected groups—children and parents—will yield more practical and accepted regulations. Child participation in policymaking allows regulations to better reflect users’ realities and avoids unilateral restrictions that may provoke resistance or circumvention.
Impact on Freedom of Expression
Amnesty International Indonesia highlights critical concerns about balancing child protection and digital freedoms. Usman Hamid, the organization’s Executive Director, asserts that PP Tunas should not serve as a pretext to curtail youth expression. Social media and similar platforms serve as crucial spaces for young people to engage in discourse and access diverse information.
Overly restrictive measures may push children toward unsafe, hidden digital channels, negating the regulation’s safety goals. A balanced, rights-respecting approach is necessary to protect children while preserving fundamental freedoms. The government must ensure that child protection policies align with democratic principles to avoid fostering an environment of legal uncertainty that stifles creativity and digital innovation.
Key Points Regarding PP Tunas Implementation
- Electronic System Providers must submit risk self-assessments within a three-month deadline.
- There is a lack of detailed technical indicators to guide these self-assessments.
- The regulation emphasizes child protection in digital spaces amid concerns about social media’s impact on children under 16.
- Industry players face compliance pressures due to unclear guidelines and short timeframes.
- Stakeholders stress the importance of digital literacy and involving affected groups in policymaking.
- Human rights organizations urge a balanced approach that protects children without suppressing freedom of expression.
The government’s ability to refine PP Tunas with clear, transparent criteria and foster multi-stakeholder dialogue will largely determine whether the regulation succeeds in safeguarding children without stalling digital ecosystem growth. Without these enhancements, digital platforms risk operating under legal ambiguity, impacting their services and the broader digital economy.
Ongoing monitoring, inclusive policy development, and comprehensive literacy initiatives are essential for the regulation to fulfill its child protection goals meaningfully and sustainably. Digital space governance must carefully balance safeguarding vulnerable users and maintaining open, dynamic platforms that contribute to social and economic development.
