28 May 2026
Start a New Game: Entering the Indonesian Video Game Market

1. Introduction
   In recent years, the Indonesian video game market has been booming. The market is currently valued at approximately IDR 30 trillion (around USD 1.7 billion), making it the largest in Southeast Asia and the 15^th largest in the world.[1] This growth is underpinned by a substantial consumer base. 

   From a policy standpoint, the Indonesian Government has demonstrated a clear commitment to advancing the domestic gaming sector through Presidential Regulation No. 19 of 2024 on the Acceleration of the National Game Industry. This regulation recognises gaming as a strategic pillar of Indonesia’s creative economy and seeks to enhance the role of local developers, stimulate investment, and support workforce and skills development. Measures include dedicated business classifications for game developers, funding and incentive schemes, and structured talent development programmes. That said, foreign developers should pay attention: the regulation also signals stricter scrutiny, particularly around local presence requirements, local partnership obligations, and alignment with national industry goals.

   With its rapidly expanding value, Indonesia offers compelling opportunities for game publishers. However, the market is currently in a dynamic growth phase rather than being fully mature. As a result, stakeholders must navigate an evolving regulatory landscape. This article walks through the key regulatory requirements for game publishers entering or already operating in Indonesia.

2. Market Entry
   Indonesian law does not require game publishers to establish a local presence. Offshore entities can market video games in Indonesia without a physical or legal presence, provided they comply with registration requirements. However, if a publisher's activities trigger e-commerce thresholds (discussed below), local presence may be required.

   Any game publisher distributing games through online platforms in Indonesia, which includes online portals, websites, and applications, is classified as Electronic System Operator (“ESO”) in Private sector (“Private ESO”) under Law No. 11 of 2008 on Electronic Information and Transactions, as amended (“EIT Law”). This matters because the EIT Law applies extraterritorially: it covers any person, inside or outside Indonesia, whose actions have legal consequences or adversely affect Indonesian interests. As a result, game publishers are subject to EIT Law obligations when offering and operating of their games in Indonesia.

   A key obligation under the EIT Law regime is the mandatory registration of ESOs as stipulated under the Minister of Communication and Informatics (currently known as Ministry of Communications and Digital Affairs or “MOCD”) Regulation No. 5 of 2020 on Electronic System Provider in the Private Sector, as amended by Minister of Communication and Informatics Regulation No. 10 of 2021 (“MOCI Reg. 5/2020”). All Private ESOs, including game publishers, must register their electronic systems (e.g., websites, gaming platforms, etc.) through the Online Single Submission (“OSS”) platform before launching it in Indonesia. Registration requires submitting details about the electronic system, including an overview of how it works, information on security measures, personal data protection practices, and feasibility testing results. Failure to register may result in the platform being blocked in Indonesia.

   Furthermore, should the game include elements of e-commerce (e.g. in-game purchases of objects or coins to be used within the game), game publishers would also be subject to Government Regulation No. 80 of 2019 on E-Commerce and Ministry of Trade Regulation No. 31 of 2023 on Provisions on Business Licensing, Advertisement, Development and Supervision of Business Actors in E-Commerce, which specifically requires establishment of a representative office upon reaching the following thresholds:

   1. transactions with more than 1,000 Indonesian consumers within 1 year;
   2. shipments of more than 1,000 packages to Indonesian consumers within 1 year; and/or
   3. traffic or access of at least 1% of domestic internet users in the country within 1 year.
       

3. Game Classification and Rating
   Once registered as a Private ESO, game publishers must classify their games under the Indonesia Game Rating System (“IGRS”). The IGRS operates under Minister of Communication and Informatics Regulation No. 2 of 2024 on Game Classification, which repealed the previous 2016 framework and introduced a more comprehensive and modernised rating regime. Under this system, publishers must complete a self‑assessment via the official IGRS platform, undergo a conformity review by government-authorised examiners, and obtain an official IGRS rating for each of its game. MOCD will then issue an official classification result, and publishers may only market or distribute their games in Indonesia after such classification has been obtained. Games are assigned age classifications (3+, 7+, 13+, 15+, or 18+), which must be prominently displayed on packaging, promotional materials, and digital distribution channels. Non‑compliance may expose the publisher to administrative sanctions, including content takedowns and access blocking.

   Furthermore, taking into account the applicable game classification and rating, game publishers as Private ESOs are required to ensure adequate protection for children accessing their video games, in accordance with the Government Regulation No. 17 of 2025 on Governance of the Organization of Electronic Systems in Child Protection (“GR 17/2025”). These obligations include: (i) displaying clear minimum age information; (ii) implementing age verification for child users ; and (iii) establishing a mechanism for reporting  misuse that may violate children’s rights. Publishers must also obtain parental consent before granting children access to their platforms, as required under GR 17/2025. Failure to comply with these obligations may expose the game publisher to administrative sanctions in the form of written warning, administrative fines, temporary suspension, and/or access blocking. 

4. Content Restrictions
   Indonesia enforces strict content restrictions that game publishers must take seriously. Under the EIT Law, Government Regulation No. 71 of 2019 on the Organization of Electronic Systems and Transactions (“GR 71/2019”), and MOCI Reg. 5/2020, Private ESOs are prohibited from hosting, transmitting, or facilitating the dissemination of contents that (i) violate prevailing laws and regulations; (ii) cause public unrest or disturb public order; and (iii) provide instructions or access to obtain prohibited contents. Prohibited content according to the aforementioned regulations includes, among others: pornographic content, LGBTQ+-related content, gambling, hate speech, terrorism or radicalism, and content that contravenes prevailing social, cultural, or moral values. Non-compliance with content restrictions obligation would expose the game publisher to the risk of administrative sanctions under GR 71/2019 and MOCI Reg. 5/2020 in the form of written warning, administrative fines, temporary suspension, access blocking and/or revocation of its ESO registration certificate.

   Specific to gambling content, Indonesian law draws a firm legal boundary between lawful games and gambling activities. Gambling is criminally prohibited under Law No. 7 of 1974 and the Indonesian Criminal Code, with the EIT Law extending this prohibition to the digital environment. As a result, game features involving prize mechanics, loot boxes, or chance-based rewards must be carefully structured to avoid any elements that could be interpreted as wagering or gambling. Regulatory enforcement in this area is primarily conducted through criminal sanctions and digital content blocking, making early legal review of monetisation features essential.

5. Key Takeaway
   Indonesia’s gaming market is growing fast, and regulation is keeping pace. Publishers can expect both government support and increasing scrutiny. Game publishers operating in or entering Indonesia should address game classification, ESO registration, and content compliance early, ideally during development and prior to launch. Compliance will be critical to maintaining uninterrupted access to one of the region’s largest and fastest-growing gaming markets.

This article was written by partner Ayik Candrawulan Gunadi (agunadi@abnrlaw.com), associates Sonia Dhan Kaur (dkaur@abnrlaw.com), Agassi Usman (rusman@abnrlaw.com), and Jyestha Herawanto (jherawanto@abnrlaw.com)

This ABNR News and its contents are intended solely to provide a general overview, for informational purposes, of selected recent developments in Indonesian law. They do not constitute legal advice and should not be relied upon as such. Accordingly, ABNR accepts no liability of any kind in respect of any statement, opinion, view, error, or omission that may be contained in this legal update. In all circumstances, you are strongly advised to consult a licensed Indonesian legal practitioner before taking any action that could adversely affect your rights and obligations under Indonesian law.
 

[1] Ministry of Communication and Digital Affairs, “Industri Gim Nasional Dibidik Jadi Andalan Pertumbuhan Ekonomi,” Ministry of Communication and Digital Affairs, 15 May 2025, https://www.komdigi.go.id/berita/siaran-pers/detail/industri-gim-nasional-dibidik-jadi-andalan-pertumbuhan-ekonomi.