Regulation on PP TUNAS Deemed Unready, These Aspects Are Under Scrutiny

Child protection in digital spaces is a non-negotiable responsibility of the state. However, policy implementation in this field must be conducted transparently and with clear parameters.

Without such clarity, regulation risks creating uncertainty for both the child protection support ecosystem and the broader digital ecosystem as a whole.

Indriyatno Banyumurti, Executive Director of ICT Watch, believes that the implementation of Government Regulation No. 17 of 2025 on the Governance of Electronic System Management in Child Protection (PP TUNAS) will run effectively if supported by an adequate ecosystem.

One aspect that has come under scrutiny is the determination of digital platform risk parameters.

“Transparency and objectivity in the platform risk assessment process are crucial factors so that the implementation of this regulation can run effectively and does not create different interpretations among all stakeholders,” said Indriyatno in a statement on Thursday, 12 March 2026.

He explained that the Ministry of Communication and Digital Affairs Regulation No. 9 of 2026 on the Governance of Electronic System Management in Child Protection has been issued but still requires further elaboration through a Ministerial Decree.

This elaboration is important, especially to clarify risk indicators that stakeholders are still awaiting.

“It is a challenge for electronic system operators (PSE) because they are being asked to submit their self-assessment results in three months in accordance with Article 62 of the Communications Ministry Regulation, whilst the indicators are not yet fully ready,” he said.

He also believes that the regulation will need to contain objective parameters and provide space for all parties, including digital platform operators, to submit their input.

“In this way, risk classification can be carried out transparently. Without clear parameters, there is potential for distortion and misalignment of risk classification across all digital platforms, which could result in suboptimal child protection,” he said.