Regional Round-up
Issue 3 of 2025

Your Snapshot of Key Legal Developments in Asia

Issue 3 of 2025 (Jul / Aug / Sep)

Cover Story

Indonesia

Indonesia’s PDP Law Update: Broader DPO Mandate Confirmed, Further Clarity Expected on Data Disclosure and Cross-Border Transfers

Indonesia’s Constitutional Court has clarified that organisations must appoint a Data Protection Officer (DPO) if any one of the three conditions under Article 53(1) of the Personal Data Protection Law is met. This ruling resolves previous uncertainty over whether all three conditions had to be fulfilled simultaneously. The clarification stems from a judicial review decided on 30 July 2025, confirming that the word “and” in the article should be interpreted as “and/or”.

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.