Understanding what is PSE in Indonesia has become an urgent priority for every company, domestic or foreign, that operates a website, application or digital platform accessible to Indonesian users. PSE, or Penyelenggara Sistem Elektronik (Electronic System Operator), is the government’s mandatory registration framework administered through the Ministry of Communication and Digital (Komdigi, formerly Kominfo). With enforcement actions intensifying, including the high-profile blocking of platforms that failed to register, compliance is no longer optional. This guide explains who must register, walks through the OSS and Komdigi PSE portal registration process step by step, clarifies the TDPSE certificate, and provides actionable checklists to help businesses avoid service disruption.

Quick Answer: What is PSE in Indonesia?

PSE stands for Penyelenggara Sistem Elektronik, which translates to Electronic System Operator. In regulatory terms, a PSE is any individual, entity or government body that provides, manages or operates an electronic system, whether a website, mobile application, digital marketplace, cloud service or any internet-based platform, for and accessible to users in Indonesia. The framework is governed by Government Regulation No. 71 of 2019 on the Implementation of Electronic Systems and Transactions (PP 71/2019) and further operationalised through ministerial regulations issued by Kominfo (now Komdigi).

Registration is compulsory. Every electronic system operator that provides services to Indonesian users must register through the Komdigi PSE portal. Failure to do so exposes the operator to administrative sanctions, the most consequential of which is the blocking of access to the platform throughout Indonesia.

The types of electronic systems caught by the definition are broad. They include:

E-commerce marketplaces, platforms facilitating online buying and selling.
Social media and messaging platforms, any app enabling user-generated content or communication.
Cloud and SaaS providers, infrastructure, platform and software services hosted remotely.
Fintech applications, payment gateways, peer-to-peer lending, digital wallets and crypto exchanges.
Search engines, content platforms and digital advertising networks.

The risk snapshot is straightforward: if your electronic system can be accessed by Indonesian users and you have not registered, your service can be blocked at any time.

Why Kominfo / Komdigi Requires PSE Registration

The PSE registration framework serves several policy objectives that the Indonesian government considers essential to digital governance. At its core, PSE registration Indonesia requirements aim to create a transparent and accountable digital ecosystem.

User protection is the primary driver. By requiring operators to register and disclose contact information, complaint channels and data handling practices, the government ensures Indonesian users have recourse if a platform mishandles their data or facilitates harmful content. Data governance is equally important: registered PSEs commit to cooperating with lawful data access requests and complying with Indonesian data-protection obligations.

Transparency and law-enforcement access are the regulatory backstops. Registration gives Komdigi a registry of every electronic system operating in the country, enabling the ministry to issue takedown orders for illegal content, request user data under court order, and coordinate with other agencies on cyber-security incidents. Finally, the registration regime supports tax and regulatory compliance, it closes the gap that previously allowed offshore platforms to serve millions of Indonesian users without any formal legal footprint.

The framework distinguishes between two scopes: Lingkup Publik (public-sector electronic systems, such as government portals) and Lingkup Privat (private-sector electronic systems). The obligations and registration pathways differ for each, with the vast majority of commercial operators falling under PSE Lingkup Privat.

Who Must Register as PSE in Indonesia: Scope, Categories and Exemptions

The single most common question businesses ask is whether their platform falls within the mandatory registration scope. The short answer is that virtually every privately operated electronic system accessible to Indonesian users must register as PSE Lingkup Privat. This applies regardless of whether the operator is an Indonesian company or a foreign entity with no physical presence in the country.

Lingkup Publik vs Lingkup Privat

PSE Lingkup Publik covers electronic systems managed by government institutions or entities acting on behalf of the state, for example, public-health information systems, social-security portals and government e-procurement platforms. Registration for Lingkup Publik is handled through a separate administrative channel and is not discussed in detail in this guide.

PSE Lingkup Privat covers all non-government electronic systems. This is the category relevant to businesses, startups, multinational platforms and foreign SaaS providers. The registration obligation attaches to the electronic system, not the legal entity, meaning a single company operating three distinct platforms must register each one separately.

Comparison Table: Who Must Register?

Entity Type	Must Register?	Key Evidence / Typical Documents
Domestic company operating electronic services for public	Yes	NIB (business identification number), business licence, company registration documents
Foreign platform accessible to Indonesian users (no local entity)	Yes, typically required	Public-access logs, Indonesian user-base evidence; may need a local representative or PT PMA
Government / public services (health, social security)	Yes (Lingkup Publik)	Government authorisation documents; registration handled via a separate pathway
Closed internal corporate system (no public access)	Generally no	Must genuinely be closed, no external user access whatsoever

Foreign Platforms: Can They Avoid Registering?

Foreign platforms cannot avoid PSE registration Indonesia obligations simply by lacking a local entity. The regulation applies to any electronic system accessible in Indonesia, and Komdigi has demonstrated its willingness to enforce this through blocking. Foreign operators generally have three options:

Register directly, the Komdigi PSE portal accepts registrations from foreign entities, though it requires appointing a contact person and, in practice, a local point of contact in Indonesia.
Appoint a local representative, some foreign operators appoint a local law firm or corporate-services provider to act as their designated contact for regulatory matters.
Establish a PT PMA, for platforms with significant Indonesian operations, establishing a foreign-owned limited-liability company (PT PMA) provides a formal legal structure and simplifies ongoing compliance, including PSE registration.

Industry sectors with specific additional regulatory layers, such as fintech (regulated by OJK), telecommunications (regulated by Komdigi under separate telecoms licences) and digital health, must also satisfy those sector-specific requirements alongside PSE registration.

OSS PSE Registration: Step-by-Step Process for PSE Lingkup Privat

The registration process for PSE Lingkup Privat involves two interconnected government systems: the OSS (Online Single Submission) platform, which handles general business licensing, and the Komdigi PSE portal, which is the dedicated registration interface for electronic systems. Below is a detailed, step-by-step walkthrough of the OSS PSE registration pathway.

Pre-Requisites: NIB and Business Licence

Before a company can register PSE Kominfo (now Komdigi), it must first hold a valid Nomor Induk Berusaha (NIB), the master business identification number issued through the OSS system. The NIB serves as the company’s baseline licence and is a prerequisite for virtually all sector-specific permits in Indonesia, including PSE registration.

To obtain an NIB, the company must be registered in the OSS system with a valid business classification code (KBLI) that corresponds to its activities. For electronic-system operators, the relevant KBLI codes typically fall under information and communication services. The company’s deed of establishment, tax identification number (NPWP) and shareholder structure must all be recorded in OSS before the NIB is generated.

If the company does not yet have an NIB, the first step is to access the OSS portal, complete the entity registration and obtain the NIB. Only then can the company proceed to PSE registration. This is sometimes a source of delay for foreign operators unfamiliar with the Indonesian business-licensing framework, which is why early engagement with local counsel is advisable.

OSS / OSS‑RBA Integration Specifics

Indonesia’s current business-licensing regime operates under the OSS‑RBA (Risk-Based Approach) system, which classifies business activities by risk level and assigns corresponding licensing requirements. PSE registration for private-sector operators is integrated into this system, meaning that an operator’s KBLI code and risk classification determine the exact set of approvals needed.

For most electronic-system operators, the risk classification will require obtaining a Sertifikat Standar (Standard Certificate) or a Perizinan (Licence) through OSS, in addition to the NIB. The critical point is that the OSS system and the Komdigi PSE portal are linked: once the business licensing side is addressed in OSS, the operator must separately complete the PSE-specific registration through the Komdigi portal. The two systems do not automatically synchronise, so operators must actively manage both.

Common pitfalls at this stage include misclassified KBLI codes (which can delay or block the issuance of the correct licence type), incomplete shareholder data in OSS, and failure to update business-activity descriptions to reflect electronic-system operations. Ensuring that the OSS profile accurately describes the electronic services being offered will prevent complications during Komdigi review.

Komdigi PSE Portal Registration Flow

Once the NIB and any required OSS licences are in hand, the operator proceeds to register on the Komdigi PSE portal. The following numbered steps outline the typical registration flow:

Create an account on the Komdigi PSE portal. The person registering should be the designated Person in Charge (PIC), typically a director or compliance officer.
Select “PSE Lingkup Privat” as the registration category.
Enter company details, legal name, NIB number, NPWP, registered address, and business-activity description matching the KBLI code in OSS.
Provide electronic-system details, name of the system or platform, URL or application store link, a description of the services provided, the type of data processed, and whether the system processes personal data.
Designate a Person in Charge (PIC), the name, position, email address and phone number of the individual responsible for regulatory communication with Komdigi.
Upload supporting documents, these typically include the company’s deed of establishment, NIB certificate, business licence, and a letter of appointment for the PIC.
Submit the application and await verification by Komdigi.

The document checklist for OSS PSE registration typically includes:

NIB certificate, downloaded from the OSS portal.
Business licence or Sertifikat Standar, as applicable under OSS‑RBA.
Company deed of establishment, notarised and, for PT PMAs, approved by the Ministry of Law and Human Rights.
NPWP (tax identification number).
PIC appointment letter, signed by a director or authorised representative.
Platform description and data-processing declaration.

Processing times vary, but Komdigi has indicated that verification and issuance can occur within days for straightforward applications. Complex cases, particularly those involving foreign entities or platforms processing sensitive personal data, may take longer. Operators should not wait until enforcement action is threatened before beginning the process.

TDPSE: Tanda Daftar PSE and Post-Registration Obligations

Upon successful registration, the operator receives a TDPSE, Tanda Daftar Penyelenggara Sistem Elektronik, or PSE Registration Certificate. The TDPSE is the formal proof that the electronic system has been registered with Komdigi and is operating in compliance with the regulatory framework.

The TDPSE contains key information including the name of the registered electronic system, the registration number, the date of issuance, and the name of the operating entity. Operators are expected to make their TDPSE status verifiable, while there is no universal requirement to display the certificate on the platform itself, best practice is to reference the registration number in the platform’s legal notices or terms of service.

Post-registration obligations are ongoing and should not be treated as a one-time administrative exercise. Registered PSEs must:

Maintain accurate records, any change to the company structure, PIC, platform URL or scope of services must be updated on the Komdigi portal promptly.
Cooperate with lawful data-access requests, Komdigi and law-enforcement agencies may request access to user data or platform information under applicable legal processes.
Maintain a complaint-handling mechanism, registered PSEs must provide a channel through which Indonesian users can submit complaints about the electronic system.
Comply with content-moderation requirements, Komdigi may direct registered PSEs to take down specific content that violates Indonesian law.
Report security incidents, breaches or significant security incidents affecting Indonesian users should be reported as required under applicable data-protection regulations.

Failure to maintain compliance after receiving the TDPSE can result in the same sanctions as failure to register, including the revocation of the TDPSE and the blocking of the electronic system.

How to Check PSE Registration on the Komdigi Portal

Verifying whether a particular platform or electronic system is registered as a PSE is straightforward using the Komdigi PSE portal. This is useful for businesses conducting due diligence, users wanting to confirm a platform’s legitimacy, and compliance officers verifying their own registration status.

To check PSE registration, follow these steps:

Navigate to the Komdigi PSE portal, the public search function is accessible without an account.
Enter the platform name, URL or company name in the search field.
Review the results, the portal will display the registration status, the registered system name, the operating entity and the TDPSE number (if registered).
Confirm the scope, verify whether the registration is under Lingkup Publik or Lingkup Privat, and whether the listed details match the platform you are investigating.

If a platform does not appear in the Komdigi registry, it is likely unregistered, and potentially at risk of blocking. Third-party verification is also possible through public notices and press releases issued by Komdigi, which periodically publish lists of platforms that have been blocked or given registration deadlines.

Enforcement: Blocking, Sanctions and How to Avoid Them

The risk of blocking for unregistered PSE operators is real and actively enforced. Komdigi (then Kominfo) demonstrated the severity of its enforcement stance when it gave Wikimedia Foundation a seven-day deadline to register as a PSE or face blocking in Indonesia. Similar deadlines and enforcement actions have been applied to other major international platforms.

What Enforcement Looks Like

Komdigi’s enforcement toolkit includes several escalating measures:

Warning notices, the ministry may issue formal written warnings to unregistered operators, setting a deadline for compliance.
Access blocking, the most visible sanction. Komdigi can instruct Indonesian internet service providers (ISPs) to block access to unregistered electronic systems. This effectively cuts the platform off from all Indonesian users.
Takedown orders, for registered platforms that violate content or data-access obligations, Komdigi can order the removal of specific content or features.
TDPSE revocation, in serious cases, the registration certificate can be revoked, leading to subsequent blocking.

The blocking mechanism is technical and comprehensive. Once Komdigi issues a blocking order, ISPs are required to implement it, and the affected platform becomes inaccessible through standard internet connections in Indonesia. While some users may circumvent blocks using VPNs, the commercial and reputational damage to an operator is significant, particularly for platforms that depend on the Indonesian market for revenue.

How to Avoid Blocking: Compliance Checklist

The following checklist provides immediate, practical steps to avoid being blocked:

Register now, if your electronic system is accessible to Indonesian users and you have not registered, begin the process immediately. Do not wait for an enforcement notice.
Verify your KBLI code and NIB, ensure your OSS profile accurately reflects your electronic-system activities.
Appoint a responsive PIC, the person in charge must be reachable and authorised to respond to Komdigi communications within short timeframes.
Maintain up-to-date records, any change in company structure, platform URL or PIC must be updated on the Komdigi portal.
Establish a complaint channel, ensure Indonesian users can submit complaints and that the channel is monitored.
Prepare for data-access requests, have internal procedures ready to process lawful requests from Indonesian authorities in a timely manner.
Monitor Komdigi announcements, regularly check for new enforcement notices, policy updates and regulatory guidance from the ministry.
Engage local counsel, particularly for foreign operators, having an Indonesian legal advisor who can interface with Komdigi is a critical safeguard.

If your platform has already received a warning notice or is facing imminent blocking, immediate legal intervention is essential. Contact Komdigi directly to request a compliance extension while simultaneously completing the registration process as quickly as possible.

Practical Scenarios and Checklists by Sector

PSE registration Indonesia requirements apply uniformly, but the practical compliance considerations differ by sector. Below are three common scenarios with sector-specific recommendations.

Fintech platforms (payment gateways, lending, digital wallets). In addition to PSE registration, fintech operators must hold relevant licences from OJK (Indonesia’s Financial Services Authority) or Bank Indonesia. PSE registration does not replace sector-specific licensing, it supplements it. Fintech operators should pay particular attention to data-security declarations during PSE registration, as financial data attracts heightened regulatory scrutiny. Ensure your PIC is familiar with both Komdigi and OJK reporting obligations. Those seeking comparable regulatory guidance in other jurisdictions may find our walkthrough on obtaining an MSB licence in the US a useful reference point.
E-commerce marketplaces. Marketplace operators must register each distinct platform (for example, a website and a separate mobile application may require individual registrations). Content-moderation obligations are particularly relevant: Komdigi may issue takedown orders for prohibited products or content. Ensure your complaint-handling mechanism is visible, functional and staffed. Data-access procedures should be documented and tested before they are needed.
SaaS and cloud providers. Foreign SaaS and cloud providers serving Indonesian enterprise clients are caught by the PSE framework even if they have no local office. Key considerations include data-localisation requirements (which may apply under separate regulations), the appointment of a local representative, and clear contractual terms with Indonesian customers that address regulatory cooperation. Operators managing intellectual property across borders should also consider how PSE obligations interact with cross-border data-transfer restrictions.

When to Seek Legal Help: Escalation, Appeals and Takedown Responses

While PSE registration can be completed without external counsel in straightforward cases, several scenarios warrant immediate legal assistance:

Receipt of a blocking notice or compliance warning, the deadline windows are short, and engaging counsel immediately maximises your chances of avoiding disruption.
Complex corporate structures, multi-jurisdictional platforms, joint ventures, or operators with multiple KBLI codes may face classification challenges that require legal analysis.
Data-access requests from Komdigi or law enforcement, responding to these requests involves balancing Indonesian law, foreign data-protection obligations and contractual duties. Legal guidance is essential.
Takedown orders, if Komdigi orders content removal that the operator considers unjustified, there are administrative channels to challenge or clarify the order, but these must be navigated quickly and correctly.
Post-blocking remediation, if a platform has already been blocked, the process to restore access requires demonstrating full compliance and may involve direct engagement with Komdigi officials.

Prepare the following documentation before contacting counsel: your current OSS and Komdigi registration status, copies of any enforcement notices received, your NIB and business licence, details of the electronic system(s) in question, and the contact information for your current PIC. Having these materials ready will allow your legal advisor to act swiftly.

Conclusion: Act Now to Secure PSE Compliance

Understanding what is PSE in Indonesia is the first step; acting on that knowledge is what protects your business. Komdigi’s enforcement record makes clear that unregistered electronic systems face real and immediate consequences, from formal warnings to full access blocking across the Indonesian market. The registration process, while multi-layered, is navigable with proper preparation: secure your NIB through OSS, complete PSE Lingkup Privat registration on the Komdigi portal, obtain your TDPSE and maintain ongoing compliance with post-registration obligations. Companies that delay risk not only losing access to one of Southeast Asia’s largest digital markets but also facing reputational damage that extends well beyond Indonesia’s borders.

If you are uncertain about your obligations or are already facing enforcement pressure, seek qualified legal counsel immediately.

Need Legal Advice?

This article was produced by Global Law Experts. For specialist advice on this topic, contact Putu Raditya Nugraha at UMBRA – Strategic Legal Solutions, a member of the Global Law Experts network.