One of the most important legal obligations for companies operating online is Penyelenggara Sistem Elektronik (PSE) registration under Kominfo.
In recent months, PSE Kominfo has become a widely discussed topic, especially after the Ministry of Communication and Informatics (Kominfo) intensified enforcement against foreign platforms and digital services that failed to comply with the licensing framework. For businesses, both Indonesian and foreign,understanding what a PSE license is and how to register properly is now essential to avoid disruption, penalties, or potential blocking of digital services.
This guide outlines the fundamentals of PSE registration, compliance requirements, and why obtaining a PSE license is critical for every online business operating in Indonesia.
What is PSE?
A Penyelenggara Sistem Elektronik (PSE) is any person, company, or organization that operates, manages, or provides an electronic system to users in Indonesia. An electronic system refers to any organized set of information, communication, and technology tools used to collect, process, store, display, or distribute electronic information.
In regulatory terms, PSE Kominfo is the official registration administered by the Ministry of Communication and Informatics. Any platform must obtain a PSE license before legally operating online in Indonesia.
Legal Basis for PSE Registration
PSE regulations are governed by several key laws:
- Government Regulation No. 71/2019 – Electronic Systems and Transactions
- Minister of Kominfo Regulation No. 5/2020 – Private Electronic System Operators
- Government Regulation No. 5/2021 – Risk-Based Licensing System
- Minister of Kominfo Regulation No. 3/2021 – Business Activity Standards
- Minister of Kominfo Regulation No. 10/2021 – Amendments to PSE Private Scope Rules
These frameworks together create Indonesia’s digital licensing ecosystem, ensuring consistency across sectors such as e-commerce, fintech, SaaS, cloud computing, online media, and digital content platforms.
Who is obligated to register for PSE?
Under Indonesian regulations, certain types of electronic systems must be registered with the Ministry of Communication and Informatics (Kominfo). Below are the categories of Electronic System Operators (Penyelenggara Sistem Elektronik) that are required to obtain a PSE registration:
Categories of Electronic Systems Required to Register as PSE
- Platforms that provide, manage, and/or operate the offering or trading of goods and/or services
- Examples: Tokopedia, Shopee
- Platforms that provide, manage, and/or operate financial transaction services
- Examples: GoPay, OVO
- Platforms that deliver paid digital content through data networks, whether via downloads from websites or portals, email distribution, or applications on user devices
- Examples: Spotify, Netflix
- Platforms providing communication services, including but not limited to text messaging, voice calls, video calls, email, online chats, digital platforms, social networks, and social media
- Examples: Facebook, Instagram, Twitter
- Search engine services and platforms delivering electronic information in the form of text, audio, images, animation, music, video, film, games, or combinations of such content
- Examples: Google, Yahoo
- Platforms conducting personal data processing for operational activities related to Electronic Transactions
- Examples: SaaS platforms
These obligations are based on Government Regulation No. 71 of 2019 on the Operation of Electronic Systems and Transactions (PP 71/2019). Under this regulation, any platform that falls into one of the categories above must register as a PSE.
Examples of businesses classified as PSE include:
- E-commerce platforms
- Online marketplaces and classifieds
- SaaS platforms and cloud services
- Mobile apps and digital products
- Payment gateways and fintech solutions
- Social media and user-generated content platforms
- Online gaming platforms that possess in-app transactional
- Company websites collecting user data
Whether the operator is an Indonesian company or a foreign entity providing services to Indonesian users, PSE registration is mandatory.
Also read: Starting a Business in Indonesia: 10 Challenges Foreign Companies Must Navigate
What is the Purpose of the PSE Regulation?
Indonesia’s PSE framework was designed to enhance legal certainty, user protection, and digital governance in a rapidly evolving online environment. The primary objectives include:
1. Ensuring Digital Accountability
By requiring registration, Kominfo can verify the legitimacy of digital service providers and ensure they comply with Indonesian law.
2. Consumer and Personal Data Protection
PSE regulations mandate businesses to secure customer data, prevent misuse, and report cyber incidents.
3. Maintaining Digital Stability
Registered PSE operators are required to ensure system reliability and adhere to operational standards.
4. Supporting Fair and Transparent Business Practices
Mandatory registration promotes equal compliance obligations among local and foreign digital players.
5. Strengthening National Cybersecurity
PSE operators must support cybersecurity initiatives and cooperate with national authorities during investigations or emergencies.
Who Is Required to Register for PSE?
PSE registration applies to all operators who run an electronic system used by the public in Indonesia. This includes:
- Domestic companies (PT / PT PMDN / PT PMA)
- Foreign companies (PSE Asing) providing access to Indonesian users
- Government bodies
- NGOs or organizations providing public-facing systems
- Individuals operating large-scale commercial digital services
- If your business falls under any of these categories and handles user interactions, transactions, or personal data online, you must register for a PSE license.
Categories of PSE Applicants
PSE applicants are divided into two main categories:
1. PSE Lingkup Privat (Private Scope PSE)
This includes businesses or organizations providing electronic services to the public for commercial purposes. Examples:
- E-commerce and marketplace platforms
- Travel platforms
- EdTech and HealthTech apps
- Payment services and fintech applications
- Online recruitment portals
- Cloud computing and SaaS platforms
2. PSE Lingkup Publik (Public Scope PSE)
Government institutions, ministries, or public bodies offering online services. Examples:
- Government portals
- Public registries
- Licensing systems (e.g., OSS RBA)
For most companies, especially PT PMDN and PT PMA, the relevant category is PSE Lingkup Privat.
PSE Registration Application Requirements
To register with Kominfo, businesses must prepare the following documents and information:
Business & Legal Information
- Legal entity details (PT / PT PMA / PT PMDN)
- NIB (Nomor Induk Berusaha) from OSS RBA
- Deed of Establishment & Approval
- NPWP (Tax ID)
Technical Information
- Domain name(s) used by the platform
- Data center and disaster recovery center locations
- Cybersecurity and data protection policies
- System description and intended functions
- Contact person for communication with Kominfo
Compliance Statements
Operators must declare that they can:
- Protect user data
- Provide secure system operation
- Report incidents within required timeframes
Failure to provide accurate information may result in registration rejection or future enforcement actions.
Steps to Acquire Your PSE License
The PSE registration process is conducted through the Online Single Submission (OSS RBA) system and monitored by Kominfo.
Step-by-Step Overview
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Prepare legal documents and ensure your NIB is valid.
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Create or update OSS RBA account for your company.
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Submit PSE Lingkup Privat form with platform details.
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Provide system description and URLs/domain names.
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Declare data protection and operational compliance.
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Submit supporting documents according to PSE Kominfo guidelines.
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Await verification from Kominfo.
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Once approved, your business will appear on the official PSE Kominfo registry.
Processing time varies but is typically 5–7 working days, depending on completeness.
Get Professional Legal Advice for Indonesia
PSE regulation is part of Indonesia’s wider digital compliance framework, which also includes data protection, cybersecurity, and consumer protection laws. For companies, especially foreign digital providers—navigating these requirements independently can be complex.
LMI Consultancy provides trusted support for:
- PSE Kominfo registration (PSE Lingkup Privat & PSE Asing)
- Assistance for PT PMDN and PT PMA entities
- Legal review of platform compliance
- Data protection and GDPR/PDPA alignment
- Digital business licensing
Our consultants ensure your business remains compliant, secure, and fully operational.
Updates to PSE Regulations and Compliance Requirements
Kominfo periodically updates PSE regulations to address new cybersecurity threats, digital economy demands, and data protection standards.
Key updates include:
- Mandatory reporting of data breaches within strict timelines
- Certification requirements for certain digital industries
- Stricter enforcement for foreign platforms
- Integration with Indonesia’s new personal data protection ecosystem
Staying updated is essential to avoid penalties or forced shutdowns.
Consequences of Operating Without a PSE License
Operating as an unregistered digital platform can lead to serious risks:
1. Temporary or Permanent Blocking
Kominfo may block access to your platform for Indonesian users.
2. Administrative Sanctions
Fines, warnings, or removal of service availability.
3. Loss of Consumer Trust
Users expect transparency and protection of their data.
4. Compliance Investigations
Authorities may conduct audits or request corrective actions.
5. Negative Business Impact
Loss of revenue, reputational harm, and operational disruptions.
For online businesses, securing a PSE license is not optional—it is a fundamental legal requirement.
Setting Up Your E-commerce Business with a PSE License
A valid PSE license strengthens your business by:
- Establishing trust and credibility
- Enabling smoother partnerships with banks and payment gateways
- Ensuring legal protection for digital transactions
- Supporting long-term scalability and compliance
For PT PMA investors or local e-commerce founders, aligning PSE registration with other business setup requirements—such as NIB, SIUP, PKP, and OSS RBA notifications—ensures your digital operations run smoothly and legally.
Frequently Asked Questions
1. Do foreign companies need to register as PSE?
Yes. Any foreign platform (PSE Asing) providing services in Indonesia must register.
2. Does a simple website need a PSE license?
If the website collects user data (forms, logins, payments), registration is required.
3. What is the difference between a PSE License and an E-Commerce License?
| Aspect | PSE License | E-Commerce License / OSS E-Commerce |
|---|---|---|
| Purpose | Regulates online systems & data processing | Regulates the business activity of selling goods/services online |
| Authority | Kominfo | OSS RBA (BKPM / Ministry of Trade) |
| Focus | Data, cybersecurity, system reliability | Commercial permissions, business activity classification |
| Required For | Any digital platform or system | Any business conducting online sales |
In short:
- PSE regulates digital platforms and data systems
- E-commerce licensing regulates the commercial business activity
- 4. How long is PSE registration valid?
It remains valid as long as the operator complies with Kominfo rules.
4. Which e-commerce businesses require PSE registration?
You must register as PSE if your platform:
- Allows users to create an account
- Conducts online transactions
- Stores or processes user data
- Provides a marketplace or classified listing
- Provides digital content or digital goods
- Integrates payment gateways or wallets
Examples:
- Online stores with checkout systems
- Marketplaces (Tokopedia-style)
- Multi-vendor platforms
- Subscription services
- Dropshipping apps collecting user data
- A simple social media shop (manual inbox orders) may not require PSE—but platforms with automated systems do.
5. Can one company register multiple platforms under one PSE license?
Yes, as long as all domains and systems are listed.
6. What happens if I fail to update my system information?
Non-compliance may result in sanctions or removal from the PSE registry.
