INTRODUCTION

Indonesia's personal data protection ("PDP") regime has entered its operational phase. On 16 July 2026, the Government issued Government Regulation No. 33 of 2026 on the Implementation of the Personal Data Protection Law ("PP 33/2026"), setting out how the obligations under Law No. 27 of 2022 ("PDP Law") are to be applied in practice.

Businesses have been subject to the PDP Law's broad principles for some time, but with limited guidance on what compliance actually looks like. PP 33/2026 fills much of that gap. Once it takes effect on 16 January 2027, the question will no longer be whether a business has a privacy policy, but whether it can demonstrate to the regulator, customers and transaction counterparties that its day-to-day practices comply.

This article outlines the key changes introduced by PP 33/2026 and the priorities businesses should address before the deadline.

CONCLUSION

PP 33/2026 marks a clear shift in Indonesia's PDP framework, from having documents in place to being able to demonstrate compliance. Records of processing, DPIAs, transfer assessments, data processing agreements and a working breach response plan will increasingly be expected as evidence, with administrative fines of up to 2% of annual revenue or receipts for non-compliance.

Regards, 

Pasaka Rievan Smith
Counsellors at Law

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INTRODUCTION 

Artificial intelligence ("AI") has rapidly become a foundation of today's digital economy, driving unprecedented demand for computing power. Meeting this demand requires more than advanced software; it depends on robust physical infrastructure, including AI data centers supported by reliable power, suitable land, and advanced computing equipment.

As established data center hubs such as Northern Virginia in the United States and the FLAPD markets (Frankfurt, London, Amsterdam, Paris, and Dublin) face mounting constraints on land availability, power capacity, and grid connectivity, global investors are expanding their search for new locations capable of supporting large-scale AI infrastructure. The race is no longer about identifying opportunities; it is about securing critical resources before they become difficult to obtain. Amidst these conditions, Indonesia has emerged as a compelling destination, offering the competitive advantages needed to enable sustained digital infrastructure investment.

This article explores why Indonesia is emerging as a regional AI data center hub, the legal and regulatory considerations investors should address, and how strategic legal planning can support successful execution.

Regards, 
Pasaka Rievan Smith
Counsellors at Law 

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INTRODUCTION

Indonesia has fundamentally changed the way certain strategic commodities are exported.

Government Regulation No. 24 of 2026, effective from 1 June 2026, introduces a centralized export system for coal, palm oil, and ferroalloy, with additional commodities expected to follow. Rather than allowing exporters to sell directly to overseas buyers, exports will gradually be centralized through a government-designated state-owned enterprise, which is widely expected to be PT Danantara Sumberdaya Indonesia.

For businesses operating in these sectors, this represents a significant regulatory shift that may affect existing contracts, pricing strategies, and export operations.

Regards, 

Pasaka Rievan Smith
Counsellors at Law

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