Singapore and Indonesia Sign MOU to Enhance Cross-border Insolvency Communication and Cooperation
On 30 March 2026, the Supreme Court of Singapore and the Supreme Court of Indonesia signed a Memorandum of Understanding (“MOU“) to Enhance Cross-Border Communication and Cooperation in Cross-Border Insolvency Proceedings.
The MOU marks another important step in further strengthening the relationship between the Supreme Courts of Singapore and Indonesia, following their first bilateral MOU for judicial cooperation. It reflects both judiciaries’ shared commitment to closer collaboration. The MOU builds on the Model Framework for Communication and Cooperation Between ASEAN Courts in Cross-Border Insolvency Proceedings endorsed at the 12th Council of ASEAN Chief Justices Meeting in November 2025. Through the MOU, communication and cooperation in insolvency and restructuring are expected to be further strengthened, particularly through the appointment of liaison points.
Indonesia is the latest Association of Southeast Asian Nations (ASEAN) jurisdiction to join Singapore in affirming its commitment to cooperation and communication in cross-border insolvency proceedings through bilateral arrangements. This follows the 2021 protocol between the Federal Court of Malaysia and the Supreme Court of Singapore on court-to-court communication in cross-border corporate insolvency matters, and the 2025 memorandum of understanding between the Supreme Court of the Philippines and the Supreme Court of Singapore to enhance cross-border communication and cooperation in such proceedings.
For more information, please refer to the Singapore Courts Media Release here.
PDP Law Updates: DPA, US Trade-Related Data Transfers, and Recent Court Rulings
Indonesia’s Personal Data Protection (“PDP“) Law (Law No. 27 of 2022) continues to evolve through regulatory, international, and judicial developments. In late February 2026, the Government published a long‑awaited draft Presidential Regulation to establish Indonesia’s Data Protection Authority (“DPA“), as mandated by Article 58(5) of the PDP Law. The draft regulation, prepared by the Ministry of Communication and Digital Affairs (“MOCD“), is pending presidential approval and would establish the DPA as a non‑ministerial government agency reporting to the President through the MOCD, without operational supervision by the ministry. The DPA will be led by a presidentially appointed Head and three deputies overseeing policy and guidance, dispute resolution, and compliance and enforcement, with authority over PDP Law oversight, administrative enforcement, and out‑of‑court dispute resolution.
Separately, Indonesia’s cross‑border data transfer commitments to the United States of America (“US)” under the US-Indonesia Agreement on Reciprocal Trade signed on 19 February 2026 have data‑protection implications. Under the trade agreement, Indonesia commits to facilitating the transfer of personal data to the US by recognising the US as providing adequate data protection under Indonesian law. This is significant because the PDP Law generally requires adequacy, appropriate safeguards, or explicit consent for cross‑border transfers, and Indonesia has not yet issued a formal adequacy list. The trade agreement itself remains subject to ratification, and its interaction with the PDP Law’s statutory transfer requirements continues to raise compliance questions for data controllers.
Recent court rulings also continue to shape compliance expectations under the PDP Law, particularly in relation to cross‑border data transfers and criminal liability for unlawful personal data disclosure. Together, these regulatory, trade‑related, and judicial developments signal a tightening enforcement environment and underscore the need for organisations operating in or dealing with Indonesia to closely monitor the establishment of the DPA, the implementation of trade commitments, and evolving judicial interpretation of the PDP Law.
For more information, click here to read our Legal Update.
Understanding the New US-Indonesia Trade Agreement and What It Means for Businesses
On 19 February 2026, the United States of America (“US“) and Indonesia signed a new Agreement on Reciprocal Trade (“Agreement“) aimed at reducing trade barriers, improving market access, and strengthening strategic supply‑chain cooperation. A key outcome is the reduction of US tariffs on selected Indonesian exports from 32% to 19%, including textiles, footwear, electronic components, and rubber‑based products, which is expected to enhance the competitiveness of Indonesian goods in the US market. The Agreement also links improved market access to compliance with labour, environmental, and transparency standards.
Beyond tariffs, Indonesia has made substantive customs and trade commitments that may materially affect import and export practices. These include the elimination of quota‑based import restrictions linked to licensing and commodity‑balance rules, which have historically delayed and complicated imports of US goods. In addition, US products are generally exempt from Indonesia’s local content (TKDN) requirements, allowing them to enter the Indonesian market without modification, although sector‑specific implementation remains relevant in industries with strong domestic‑industry protections.
The Agreement also expands bilateral cooperation on critical minerals, particularly nickel and battery‑related materials, reflecting both countries’ priorities in supply‑chain resilience and the electric‑vehicle ecosystem. While the Agreement creates new commercial opportunities, it also introduces heightened regulatory and compliance considerations for exporters, importers, and digital‑economy players operating across both jurisdictions, making close monitoring of implementing regulations essential.
For more information, click here to read our Legal Update.
KPPU Regulation 2/2026: Streamlining Enforcement to Support Indonesia's 2026 Competition Outlook
In early January 2026, the Indonesia Competition Commission (Komisi Pengawas Persaingan Usaha or “KPPU“) issued KPPU Regulation No. 2 of 2026 (“KPPU Regulation 2/2026“), which sets out the procedural framework for exercising KPPU’s authority under Law No. 5 of 1999 on Competition Law. Issued alongside KPPU’s Competition 2026 Outlook, KPPU Regulation 2/2026 supports enforcement priorities aimed at strengthening Indonesia’s competition ecosystem and improving the Business Competition Index (IPU), in line with the Government’s broader economic growth objectives.
KPPU Regulation 2/2026 introduces a formal delegation and sub‑delegation framework to streamline internal operations. KPPU may delegate certain duties to the Secretary General, who may further sub‑delegate implementation to bureau heads and units, subject to technical guidelines. The power to impose administrative sanctions remains exclusively with the KPPU Panel and cannot be delegated, preserving institutional independence and accountability. The regulation also clarifies the KPPU Secretariat’s role in inter‑agency coordination and oversight of micro, small, and medium enterprise (MSME) partnership arrangements, and confirms the application of public administrative law principles to KPPU officials.
Overall, the regulation is intended to deliver greater procedural clarity, efficiency, and predictability in competition law enforcement. By streamlining internal processes while retaining adjudicative authority at panel level, KPPU Regulation 2/2026 supports a more consistent enforcement environment ahead of intensified competition supervision in 2026, underscoring the importance of robust compliance frameworks for businesses operating in Indonesia.
For more information, click here to read our Legal Update.
Bank Indonesia Rewrites the Rules for Indonesia's Payment System under BI Regulation No. 10/2025
In December 2025, Bank Indonesia (“BI“) issued Bank Indonesia Regulation No. 10 of 2025 on the Payment System Industry (“PBI 10/2025“), introducing a single, consolidated regulatory framework for Indonesia’s entire payment ecosystem, covering payment service providers, infrastructure operators, and supporting partners. This reform responds to longstanding regulatory fragmentation under multiple BI regulations and is intended to modernise Indonesia’s payment system in line with the Payment System Blueprint 2030, as digital transactions continue to expand. PBI 10/2025 consolidates and replaces provisions previously dispersed across PBI 23/6/PBI/2021 on Payment Service Providers, PBI 23/7/PBI/2021 on Payment System Infrastructure Providers, and PBI 23/11/PBI/2021 on National Payment System Standards, reducing overlapping compliance obligations. The regulation took effect on 31 March 2026.
A core feature of PBI 10/2025 is the introduction of the Transaction, Interconnection, Competence, Risk Management, and IT Infrastructure (Transaksi, Interkoneksi, Kompetensi, Manajemen Risiko, dan Infrastruktur Teknologi Informasi) or TIKMI assessment framework, which evaluates payment system service providers based on Transaction volume and value, Interconnection, Competence, Risk Management, and information technology (IT) Infrastructure. TIKMI is used by BI across licensing, classification, supervision, and approval processes. The regulation also simplifies provider classification by grouping participants into two main categories: Payment Service Providers (“PJPs“) and Payment Infrastructure Providers (PIPs), replacing the previous, more fragmented categorisation model. In addition, PBI 10/2025 introduces new activity‑bundling rules for PJPs, aiming to standardise how payment activities are structured and licensed.
PBI 10/2025 further strengthens risk management, governance, and capital adequacy requirements, with the stated objective of improving the resilience, stability, and security of Indonesia’s national payment system. Collectively, these changes represent a structural shift in BI’s supervisory approach, with a stronger emphasis on system‑wide integration and risk‑based oversight to support Indonesia’s digital economy objectives under the Payment System Blueprint 2030. Payment system operators and related businesses will need to reassess their licensing status, internal controls, and operational readiness ahead of the regulation’s implementation.
For more information, click here to read our Legal Update.
New Framework for Addressing IP Infringement on Digital Platforms under Minister of Law Regulation No. 47 of 2025
In December 2025, the Minister of Law issued Minister of Law Regulation No. 47 of 2025 on the Handling of Intellectual Property Infringement Reports in Electronic Systems (“Regulation 47/2025“), establishing a formal framework for enforcing intellectual property (“IP“) rights on digital platforms. Regulation 47/2025 introduces a structured mechanism for reporting, verifying, and taking action against IP infringements occurring through electronic information and electronic documents, with the aim of strengthening IP enforcement in Indonesia’s digital environment. In practice, the framework provides IP rights holders with a clearer pathway to seek content takedown or access‑blocking measures through coordination with government authorities.
Regulation 47/2025 applies to unauthorised acts of producing, selling, imitating, or distributing materials, products, services, or signs protected by IP rights when conducted through electronic systems. Its scope captures a broad range of online activities, including the sale of counterfeit goods on e‑commerce platforms, the distribution of pirated copyrighted content via websites or applications, and the unauthorised use of trademarks or trade names that may mislead users as to origin or affiliation. Regulation 47/2025 applies across digital platforms and covers IP infringements committed through electronic information and electronic documents.
Regulation 47/2025 introduces a formal reporting mechanism, allowing reports to be submitted electronically via the Directorate General of Intellectual Property (“DGIP“) website or manually at the DGIP office. Reports may be filed by registered IP rights holders or recorded licensees, and must include the reporter’s identity, details of the infringing content (such as uniform resource locators (URLs) or platform names), a description of the alleged infringement, and supporting information. This framework is intended to deliver greater procedural clarity and more coordinated enforcement against online IP infringement, with implications for digital platforms and rights holders operating in Indonesia.
For more information, click here to read our Legal Update.
Indonesia Sets New Carbon Framework under Presidential Regulation 110/2025
In October 2025, the Indonesian government issued Presidential Regulation No. 110 of 2025 on the implementation of Carbon Economic Value instruments and national greenhouse gas emission control (“Presidential Regulation 110/2025“), replacing the earlier framework under Presidential Regulation No. 98 of 2021. The new regulation introduces a clearer and more integrated carbon governance framework, strengthening oversight of carbon pricing instruments and aligning Indonesia’s carbon market more closely with its commitments under the Paris Agreement. For businesses, the urgency stems from several structural changes, including clearer carbon allocation rules, recognition of voluntary and international standards, earlier access to international carbon trading, and the rollout of a new national carbon registry.
A key legal development under the new regulation is the introduction of an express framework for Carbon Allocation (Alokasi Karbon), establishing defined emission limits previously absent under sectoral greenhouse gas baselines. Carbon Allocation must now align with Indonesia’s low‑carbon development and green economy policies, and be anchored to the National Long‑Term and Medium‑Term Development Plans. The regulation also introduces Carbon Reserves (Karbon Cadangan) to support longer‑term emissions management and market stability. To ensure consistency, carbon allocation decisions are subject to a formal cross‑ministerial governance structure, including a Steering Committee and joint ministerial decision mechanisms for setting and adjusting allocations.
Presidential Regulation 110/2025 also strengthens the institutional and market infrastructure underpinning Indonesia’s carbon market, including improved oversight mechanisms and the establishment of a dedicated national carbon registry to support transparency and traceability. Collectively, these reforms are intended to enhance market confidence, increase participation, and position Indonesia for greater integration with international carbon markets. Businesses will need to enhance internal monitoring, reporting, and regulatory engagement to adapt to the new framework.
For more information, click here to read our Legal Update.
Please note that whilst the information in this Update is correct to the best of our knowledge and belief at the time of writing, it is only intended to provide a general guide to the subject matter and should not be treated as a substitute for specific professional advice
