Hard Deadline for the Registration of Private Electronic System Operator

Back in May 2021, Minister of Communication and Informatics (MOCI) issued Regulation No. 10 of 2021 which partially amended MOCI 5/2020 that came into force on May 21, 2021. Particularly on the electronic system registration requirement, the amended MOCI 5/2020 stipulates a transitional provision which requires a Private Electronic System Operator (Private ESO) to comply with the registration requirements at the latest 6 (six) months after the operation of Risk-based Approach Online Single Submission (OSS RBA) licensing system (the “OSS System”) became effective.

The requirements for a Private ESO to register its electronic system in the database maintained by MOCI is governed under the Government Regulation No. 71 of 2019 on the Operation of Electronic Systems and Transactions (“GR 71/2019”) and MOCI 5/2020. Both local Private ESO and foreign Private ESO (off-shore) that provide its electronic system to the users within Indonesian jurisdiction are subject to the registration requirement.

As a follow up to the registration requirements, MOCI had just set a hard deadline for Private ESO (local or off-shore) to comply with such registration requirement by issuing Circular Letter No. 3 of 2022 dated June 14, 2022 on the Effective Date of the Registration of Private Electronic System Operator (“Circular Letter 3/2022”). Below we highlight some notable provisions under Circular Letter 3/2022.

  • Hard Deadline for the Registration of Private ESO

Circular Letter 3/2022 sets out a specific deadline for Private ESO to comply with the registration requirement under GR 71/2019 and MOCI 5/2020. Point 5 letter a of Circular Letter 3/2022 requires Private ESO to register its electronic system at the latest 6 (six) months since January 21, 2022 — thus, making the deadline to be on July 20, 2022, at the latest. The registration shall be carried out through the new OSS System at https://oss.go.id. If the Private ESO does not register within the specified timeframe, MOCI  may impose  administrative sanction against the Private ESO by blocking the access to their relevant electronic system in Indonesia.

  • Re-Registration Requirement for Registered Private ESO

Circular Letter 3/2022 also requires Private ESOs that registered its electronic system and obtained ESO Certificate prior to the enactment of MOCI 5/2020 (November 24, 2020) to re-register their electronic system through the new OSS System.

For explanation on the scope of ESO, registration process, documents submission, or otherwise our summary to GR 71/2019 and MOCI 5/2020, please read our article here.


July 11, 2022


Please contact Abadi Abi Tisnadisastra (atisnadisastra@aksetlaw.com) and Noor Prayoga Mokoginta (nmokoginta@aksetlaw.com) for further information.



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