07 Aug 2026
What’s Changing for E-Commerce in Indonesia? Key Takeaways from Minister of Trade Regulation No. 19 of 2026

The Ministry of Trade (“MOT”) has issued Regulation No. 19 of 2026 on the Implementation of E-Commerce Activities ("MOT Reg. 19/2026"), replacing MOT Regulation No. 31 of 2023 on Business Licensing, Advertising, Guidance and Supervision of Business Undertakings in Trading through Electronic Systems (“MOT Reg. 31/2023”). The new regulation responds to the rapid evolution of Indonesia's digital economy by expanding regulatory coverage, strengthening consumer protection, reinforcing fair competition safeguards, and for the first time introducing provisions on the use of artificial intelligence ("AI") in electronic commerce.

MOT Reg. 19/2026 applies to all business undertakings engaged in trade through electronic systems (Perdagangan Melalui Sistem Elektronik or "PMSE"), including domestic and foreign merchants, E-commerce Undertakings (Penyelenggara Perdagangan Melalui Sistem Elektronik or "PPMSE"), and intermediary service providers (Penyelenggara Sarana Perantara or "PSP"). The key features of MOT Reg. 19/2026 are summarized below.
 

1. Broader Scope of Regulated Business Models: Express Inclusion of Ride Hailing and Online Travel Agent within the E-Commerce Regime

One of the most notable changes introduced by MOT Reg. 19/2026 is the expansion of the categories of e-commerce business models recognized under the regulation.

While the previous regulation primarily addressed online retail, marketplaces, online classified advertisements, price comparison platforms, daily deals, and social commerce, MOT Reg. 19/2026 now expressly recognizes the following as regulated PPMSE business models:

• Ride Hailing – electronic systems (websites or applications) for commercial land transportation services, which may include goods and/or services commerce features as ancillary services within the same ecosystem;

• Online Travel Agent ("OTA") – platforms facilitating the sale or booking of travel-related services, including transportation tickets, accommodations, attractions, and travel packages. 

This update emphasizes that platforms whose main business is not traditionally perceived as “e-commerce” may still fall within the scope of MOT Reg. 19/2026 if they facilitate PMSE activities. For example, a ride-hailing application that also allows food delivery, courier delivery, or other service transactions may need to review whether its platform features trigger PPMSE obligations. Similarly, OTAs may need to assess their obligations not only as travel-sector platforms but also as PMSE operators under the MOT framework, including the applicable licensing requirements.

The express inclusion of these sectors reflects the increasingly diverse nature of Indonesia's digital economy. By bringing ride-hailing and travel-booking platforms more clearly within the scope of the e-commerce regulatory framework, the Government appears to be seeking greater consistency in the regulation of digital intermediaries that facilitate commercial transactions between businesses and consumers.

While these business models are already captured under the definition of e-commerce business under MOT Reg. 31/2023, the express inclusion of ride-hailing services and travel booking services signifies the potential heightened enforcement towards these business models. 

2. Use of AI in E-Commerce
    

   MOT Reg. 19/2026 is also notable for expressly regulating the use of AI in PMSE, although the provisions remain general and refer to compliance with applicable laws and regulations.
   
   Business undertakings are permitted to utilize AI in conducting PMSE activities while maintaining their responsibility for any information, recommendations, content, or other outputs generated through such systems. At a minimum, they must inform and/or label goods, services, promotional offers or recommendations that are generated, displayed, recommended or promoted using AI. They must also ensure that information generated, displayed, recommended or promoted by AI is correct, clear, accurate and accountable.

   
   For PPMSE operators, MOT Reg. 19/2026 requires internal governance for AI use that is proportionate to the relevant risk, as well as a mechanism for complaints or correction of information, recommendations, promotions or services generated through AI. Business undertakings using AI must also ensure the protection of consumers, business undertakings, personal data and intellectual property rights, and must comply with competition law and avoid unfair or harmful practices..

    

   These provisions may be relevant to platforms that use AI or automated systems for product recommendations, search ranking, personalized promotions, pricing suggestions, merchant scoring, customer service chatbots, fraud detection, review moderation, or travel and mobility recommendations. Although the Regulation does not yet provide detailed technical standards for AI governance, it indicates that AI use is now part of PMSE compliance and should be addressed through internal policies, risk assessment, transparency measures, complaint handling and accountability mechanisms.
    

3. Business Licensing and Merchant Onboarding

MOT Reg. 19/2026 introduces stricter licensing and onboarding requirements for both PPMSE and merchants operating on their platforms:

• Unlicensed merchants may no longer onboard: PPMSEs must reject registration requests from unlicensed domestic Merchants. Domestic Merchants are required to substantiate that they at least have a Business Identification Number (Nomor Induk Berusaha or NIB) and evidence of compliance with the required standard and/or technical requirements for goods and/or services in accordance with the provisions of laws and regulations.

• Additional requirements for service merchants: Merchants offering services must hold a competency certificate or be supported by certified technical personnel, in accordance with the applicable regulations.

• Platforms to support licensing: PPMSEs are required to facilitate domestic Merchants’ process of obtaining a business license by providing facilities that inform and/or connect merchants to the Online Single Submission (“OSS”) Agency’s website.

• Temporary registration mechanism: Merchants whose licensing is still in process may register temporarily under a "Legalization in Progress" label. However, such merchants must obtain their licenses within six months. This six-month period applies only to merchants onboarded under the temporary registration mechanism and is separate from the transitional period granted to merchants already conducting PMSE activities on PPMSE platforms prior to the effective date of MOT Reg. 19/2026, as discussed under the Transitional Period section below. Failure to do so will result in the PPMSE being obligated to restrict the merchant's access, including by suspending their trading activities.

4. A Stronger Push for Consumer Protection and Platform Transparency

    

   MOT Reg. 19/2026 strengthens the framework for how platforms engage with merchants and consumers, introducing a more transparent and accountable e-commerce ecosystem. Key highlights include:

• Complaint handling and dispute resolution: PPMSEs operating marketplace, online classified ads, daily deals, social commerce, ride hailing, and OTA models, as well as non-exempt PSP, must provide accessible complaint channels (including at least two active electronic channels such as email, live chat, or ticket systems). They are also required to establish and publish service level agreements governing their complaint response times. Disputes between merchants and PPMSE/PSP should first be resolved through deliberation, with recourse to formal dispute resolution mechanisms if necessary.

• Fee transparency and merchants’ right to object: PPMSEs must inform merchants of all applicable fees in a clear and easily accessible manner, with such fees documented in written agreements and/or electronic contracts. Any changes will require merchant consent, and merchants are entitled to object in writing, with PPMSEs required to respond within 14 business days.

• Product labelling and seller verification: PPMSEs may assign labels such as "official store," "authorized store," or "star seller" to merchants, but only where supported by transparent criteria, risk-based verification, and proper record-keeping. These labels must be displayed accurately and must not mislead consumers.

• Non-compliant ads: Similar to the previous regulation, Article 33 of MOT Reg. 19/2026 prohibits PPMSEs from displaying non-compliant electronic ads, requires termination of access to such content and, for non-Online Retail PPMSEs, mandates termination of the offending business undertakings’ account after 3 repeated violations. The newly introduced paragraph (4) under MOT Reg. 19/2026 reinforces this framework by prohibiting PPMSEs from facilitating account name changes or new account registrations by terminated business undertakings under the same business license, thereby preventing circumvention through re-registration.

Transitional Period

Existing business licenses obtained by domestic PPMSEs, merchants, PSP, and E-Commerce Representative Office prior to MOT Reg. 19/2026 remain valid provided they have not expired or been revoked and are registered with the OSS system. Merchants already conducting PMSE activities on PPMSE platforms prior to the effective date of MOT Reg. 19/2026 are granted an 18-month transition period to comply with the new licensing requirements.

ABNR Commentary

MOT Reg. 19/2026 represents a significant overhaul of Indonesia's e-commerce regulatory landscape. By explicitly bringing ride hailing and OTA platforms within the PPMSE framework, the Government has addressed a long-standing gap in the regulatory perimeter, recognizing that these platforms play a functionally equivalent role to traditional marketplaces in facilitating digital commerce. For businesses operating integrated digital ecosystems, such as "super apps" offering transportation, travel booking, and retail services within a single platform, this expansion means that each service vertical must be assessed against the full suite of PMSE compliance obligations.

While many of the new provisions build upon existing regulatory principles, businesses operating digital platforms in Indonesia may wish to conduct a thorough review of their operations, licensing status, contractual arrangements, and compliance frameworks to ensure alignment with the new requirements ahead of any applicable transition deadlines.

By partners Agus Ahadi Deradjat (aderadjat@abnrlaw.com), Mahiswara Timur (mtimur@abnrlaw.com), associate Bernessa Clarissa (brotua@abnrlaw.com), and trainee associate Amanda Wijanarko (awijanarko@abnrlaw.com).

This ABNR client alert is intended solely to provide a general overview, for informational purposes, of selected recent developments in Indonesian law. It does not constitute legal advice and should not be relied upon as such. ABNR accepts no liability of any kind in respect of any statement, opinion, view, error or omission that may be contained in this update. You are strongly advised to consult a licensed Indonesian legal practitioner before taking any action that could affect your rights and obligations under Indonesian law.