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PSE - Electronic System Operator: What It Is and Who Needs PSE Registration in Indonesia

What is PSE

PSE stands for Penyelenggara Sistem Elektronik, which translates to electronic system operator. Companies and projects offering digital services to users in Indonesia are required to have this legal status.

In the business environment, the term 'PSE certificate' is often used. In practice, it refers not to a security certificate but to mandatory government registration as an electronic system operator. This registration is managed by the Ministry of Communication and Information Technology of Indonesia (Kominfo).

Registration is conducted through the OSS RBA platform (Online Single Submission – Risk-Based Approach). It is mandatory for private electronic system operators (PSE Private Scope), which include commercial and public online services.

Types of PSE

Indonesian legislation divides electronic system operators into two types:

  1. PSE Public Scope (Lingkup Publik) includes state and public electronic systems. These are government portals, registries, and official digital platforms.

  2. PSE Private Scope (Lingkup Privat) encompasses commercial and private services. The vast majority of business platforms operating online belong to this category.

Who is required to register

PSE registration is mandatory for any electronic platforms available to users in Indonesia that process data or provide digital services, regardless of whether they have a local office or legal entity in the country.

Websites and mobile applications with user accounts, e-commerce platforms, streaming and media services, fintech projects, payment systems, cloud services, and SaaS platforms are subject to these requirements. Registration is also mandatory for social networks and messaging apps.

It is sufficient if the service can be used by people from Indonesia.

Why it matters now

  • Indonesia's digital market is rapidly growing, with the government intensifying control over data protection and risk management.

  • The Personal Data Protection Law (PDP Law) has heightened requirements for electronic system operators.

  • Not having PSE registration creates a risk of sudden service disruptions.

  • A company might lose access to the Indonesian market.

  • For businesses, PSE has become a fundamental requirement for legal operations.

  • For investors, PSE status serves as a marker of regulatory reliability.

Legal Framework

The PSE system is built upon several regulations that operate concurrently.

  1. Government Regulation No. 71/2019 (PP 71/2019) governs electronic systems and transactions, setting out operator duties, including user data storage and processing rules.

  2. Permenkominfo No. 10/2021 (formerly Permenkominfo No. 5/2020) details the PSE registration process, document requirements, and penalties for non-compliance.

  3. Law No. 27/2022 (PDP Law) focuses on personal data protection, directly linked to the PSE system. It fully came into effect on October 17, 2024, increasing the responsibilities of companies regarding data handling.

What Kominfo checks

The PSE registration process is not a technical audit, but the regulator reviews several key areas.

  1. Description of the electronic system. Kominfo requests details on how the service operates, its functions, modules used, and data processing locations.

  2. Legal status of the operator. The company must confirm the legality of its business, typically using a Business Identification Number (NIB) or similar document for foreign entities.

  3. Approach to personal data processing. While PSE registration does not assess cybersecurity levels, the regulator expects compliance with the PDP Law, including lawful data processing and user rights.

  4. Data storage and processing locations. It is crucial for the regulator to know whether servers are located in Indonesia or abroad, influencing control and governmental access.

Sanctions and Risks of Non-compliance

PSE is not a formality but a legal requirement. Failure to register carries direct legal and operational risks.

  • Kominfo has the authority to temporarily or permanently block user access to the service in Indonesia, sometimes without prior notice. The regulator also employs administrative measures, including warnings, restricted access, and other legal actions.

  • Working with partners can become more complicated. Payment providers and financial institutions often require PSE status confirmation. Lack of it can halt market operations.

  • For foreign platforms, the consequences are particularly severe. Blocking a service leads not only to a loss of users but also to significant reputational risks.

Real Examples of Blockings

Instances of blocking due to the absence of PSE have already been officially confirmed. In June 2025, the Ministry of Communication and Information Technology of Indonesia (Kominfo) announced the suspension of three international platforms for failing to register as PSE Private Scope.

Affected were PT Dunia Luxindo, representing the Bath & Body Works brand, eBay Inc., and airline KLM Royal Dutch Airlines.

Warnings and Risk of Blockings

In addition to actual blockings, Kominfo regularly sends warnings to platforms that have not registered or updated their information.

The regulator has officially notified at least 36 operators of the risk of blocking due to non-compliance. In other cases, warnings were issued to 25 foreign and local platforms, including Cloudflare, Dropbox, Duolingo, Marriott, and OpenAI with the ChatGPT service.

All notifications explicitly state that ignoring the requirements may lead to administrative sanctions, including complete access blocking in Indonesia.

Conclusion

PSE in Indonesia is a mandatory government registration for electronic system operators. It is required for all platforms offering digital services to Indonesian users or processing their data.

PSE is not a security certificate; it is a legal status confirmed by registration with Kominfo through the OSS RBA system. It reduces blocking risks, simplifies partnership operations, and enhances user trust.

Ignoring the requirements can lead to access blockings, administrative sanctions, and reputational damage.

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