New Framework for Addressing IP Infringement on Digital Platforms Under Minister of Law Regulation No. 47 of 2025

The Minister of Law has issued Minister of Law Regulation No. 47 of 2025 on the Handling of Intellectual Property Infringement Reports in Electronic Systems (“Regulation 47/2025“), introducing a formal framework for addressing intellectual property (“IP“) infringements occurring on digital platforms.

Regulation 47/2025 is aimed at strengthening the enforcement of IP rights in Indonesia’s digital environment by establishing a structured mechanism for reporting, verifying, and taking action against infringing online content. In practice, the regulation provides IP rights holders with a clearer pathway to seek takedown or access-blocking measures by coordinating with the government.

The key features of Regulation 47/2025 are summarised below.

Scope of IP Infringements Covered 

Regulation 47/2025 applies to producing, selling, imitating, or distributing materials, creations, products, services, and/or signs protected by intellectual property rights without authorisation, where such acts are carried through electronic information and/or electronic documents.

In practice, this scope captures a wide range of online activities, including, for example:

1. The unauthorised sale or offering of counterfeit branded goods through e‑commerce platforms or online marketplaces;

2. The distribution of pirated copyrighted content (such as films, music, software, or written works) via websites, applications, or file‑sharing platforms; and

3. The use of trademarks, logos, or trade names on digital platforms in a manner that may mislead users as to origin, affiliation, or endorsement.

By expressly covering infringements committed through electronic information and electronic documents, the regulation is designed to address IP violations occurring across a broad range of digital platforms and online environments.

Reporting Mechanism 

Reports of IP infringements may be submitted to the Minister of Law through the following means:

1. Electronic submissions: A party can submit a report electronically by filling out the prescribed report form in the Directorate General of Intellectual Property (“DGIP“) website.

2. Manual submissions: A party can submit a report manually by completing a written report form available at the DGIP office.

Reports may be filed by the registered IP owners or holders, as well as authorised licensees whose rights have been recorded with the DGIP.

Required Content and Supporting Documents

At a minimum, the report must include the following information:

1. The identity details of the reporting party;

2. A description of the infringing content (such as URLs, website names, or application names);

3. A brief explanation of the alleged infringement; and

4. Any additional information relating to the infringing products or services.

In addition, the report must also be supported by evidence, including proof of ownership of the relevant IP rights or documentation evidencing the recordation of a licensing agreement.

Examination, Verification, and Enforcement Measures 

Upon submission, the report will first undergo an administrative examination. Once the administrative process is deemed complete, it will proceed to the verification stage.

The verification process is conducted by a team comprising representatives from the Ministry of Law, the Ministry of Communication and Digital Affairs, and relevant IP associations. The verification team will examine the report, prepare minutes of meetings, give takedown recommendations, and formulate further considerations. The team may also summon the relevant platform provider and/or the reported parties.

If the verification results indicate that the reported content meets the criteria for IP infringement, the verification team may recommend:

1. Partial takedown of the relevant website;

2. Complete takedown of the website; and/or

3. Blocking of access to the infringing content.

Access to blocked or taken-down content may be reinstated if a licence or cooperation agreement is subsequently obtained from the IP rights holder, or if the parties reach a resolution through mediation.

Commentary

Regulation 47/2025 represents a notable development in Indonesia’s approach to online IP enforcement. By formalising inter-agency coordination and establishing clear procedural steps, the regulation enhances legal certainty for IP rights holders while clarifying the obligations and potential exposure of digital platform operators in responding to infringement reports.

Contribution Note

This Legal Update is contributed by the listed Contact Partners and Senior Associate Nalendra Wibowo, with the assistance of Achmad Faisal Rachman (Associate, Assegaf Hamzah & Partners).