The implementation of PP Number 17 of 2025, known as PP Tunas, aims to regulate digital protection for children in Indonesia. This regulation serves as the primary legal framework overseeing children’s activities in the online environment. However, experts and industry players express serious concerns regarding the technical clarity and practical application of this policy.
A major issue lies in the lack of transparent and well-defined risk assessment parameters. Indriyatno Banyumurti, Executive Director of ICT Watch, highlights that the effectiveness of PP Tunas depends heavily on the objective classification of risks posed by digital platforms. Without clear standards, the regulation may lead to different interpretations by stakeholders, preventing consistent enforcement.
Digital platform providers, officially termed as Electronic System Providers (PSE), are mandated to submit self-assessment reports within three months. This requirement is stipulated under Article 62 of the Ministry’s Regulation on Digital Information and Electronic Transactions (Permen Komdigi) Number 9 of 2026. Despite this, the government has yet to finalize the detailed technical indicators needed to evaluate the risk levels of these platforms, further adding to the ambiguity faced by the industry.
Challenges in Risk Indicator Transparency
The absence of finalized technical criteria significantly hampers the industry’s ability to comply effectively. Many PSEs remain unsure about the benchmarks for measuring their platforms’ impact on children’s digital safety. Indriyatno stresses that clear and transparent parameters are critical for ensuring the self-assessment process is meaningful and standardized.
Additionally, beyond legal frameworks, the readiness of the entire digital ecosystem is crucial. Experts advocate for intensified digital literacy programs targeting parents, educators, and caregivers. These educational efforts should be complemented by digital platforms embedding educational content directly within their services to foster a safer online environment for children.
Need for Inclusive Public Dialogue
Trubus Rahardiansah, a public policy expert from Trisakti University, critiques the government’s predominantly top-down approach in formulating PP Tunas. According to him, the development of this regulation insufficiently involves essential stakeholders such as children, parents, and teachers. Their inclusion is vital as they represent those directly affected by the law.
Opening wider spaces for public dialogue can prevent the law from becoming detached from the actual needs in the field. Constructive conversations with diverse groups can lead to more comprehensive and empathetic protections for children in the digital space. This participative approach is encouraged to ensure the policy remains relevant and balanced.
Potential Risks to Digital Freedom of Expression
Amnesty International Indonesia issues warnings about the long-term implications of overly strict digital child protection regulations. Usman Hamid, the organization’s Executive Director, underscores the importance of social media as a vital platform for young people’s expression and information exchange.
Restrictive regulations risk infringing on the rights of tens of millions of Indonesian youths to communicate and access diverse viewpoints. Stricter controls may inadvertently push children to use digital platforms clandestinely, where they are more vulnerable and less protected.
Key Points on the Ongoing Implementation of PP Tunas
- Deadline for Self-Assessment: PSEs must submit risk evaluation results within three months, but lack of clear indicators creates compliance challenges.
- Unfinalized Technical Indicators: The government has not yet issued the detailed risk parameters needed to guide industry assessments.
- Demand for Digital Literacy: Experts urge massive efforts to enhance digital awareness among caregivers and users.
- Call for Inclusive Policy Development: Effective regulations require engagement with children, parents, educators, and other stakeholders.
- Balancing Safety and Freedom: Safeguards should avoid over-restricting online expression to preserve youths’ rights.
In summary, the implementation of PP Tunas highlights a complex crossroads where digital child protection must balance technical clarity, inclusivity, and respect for freedom of expression. Without transparent risk indicators and meaningful stakeholder participation, the regulation risks creating legal uncertainty and social backlash. This uncertainty may compromise the ultimate goal of protecting children online while safeguarding their fundamental rights in the digital world.