On 4 June 2026, the Minister of Trade (“MoT”) issued MoT Regulation No. 19 of 2026 on the Implementation of Trade Business Through Electronic Systems (“MoT Reg. 19/2026”), which came into force on 8 June 2026. MoT Reg. 19/2026 replaces and revokes MoT Regulation No. 31 of 2023 on Business Licensing, Advertising, Guidance, and Supervision of Business Actors in Trading Through Electronic Systems.
While on the regulation on trade through electronic systems (Perdagangan Melalui Sistem Elektronik or “PMSE”) are mostly unchanged compared to the previous regulation, MoT Reg. 19/2026 introduces several important updates, including an expanded scope of PMSE business models, stricter merchant licensing and product compliance requirements, enhanced platform transparency, domestic product prioritization, cross-border PMSE requirements, and specific obligations relating to the use of artificial intelligence (“AI”).
We set out below the key provisions introduced under MoT Reg. 19/2026:
- Expanded PPMSE Business Models
MoT Reg. 19/2026 expands the scope of PMSE business models by expressly introducing ride hailing and online travel agent as new PPMSE business models, in addition to the existing models such as online retail, marketplace, online classified advertising, price comparison platform, daily deals, and social commerce (Article 3 of MoT Reg. 19/2026).
Ride Hailing refers to a business model in the land transportation sector, which may include features for trading goods and/or services through an electronic system within the same ecosystem (Article 1(19) of MoT Reg. 19/2026). Online Travel Agent refers to a business model for selling and/or ordering travel services, including transportation tickets, accommodation, attractions, and/or travel packages, either directly or by facilitating transactions between consumers and relevant business actors (Article 1(20) of MoT Reg. 19/2026).
- Seller Licensing and Product Compliance
MoT Reg. 19/2026 strengthens the compliance requirements applicable to sellers conducting PMSE. Business actors conducting PMSE are required to hold business licensing in the trade sector and, where applicable, business licensing in the relevant sector (Article 4(1) and (2) of MoT Reg. 19/2026).
For domestic sellers, PPMSE providing PMSE facilities must reject registration requests from sellers that do not hold the required business licensing, which must include a Business Identification Number (Nomor Induk Berusaha) in the trade sector, and proof of compliance with the mandatory standards and/or technical requirements for the relevant goods and/or services, where applicable (Article 4(4) and (5) of MoT Reg. 19/2026). However, PPMSE must provide a temporary registration feature with the label “Dalam Proses Legalisasi” (in the legalizing process) for sellers that have yet to fulfil the applicable business licensing requirements, provided that such sellers obtain the required licensing within 6 months after registration (Article 17(3) and (4) of MoT Reg. 19/2026).
For foreign sellers conducting PMSE through domestic PPMSE that provide facilities for foreign sellers, MoT Reg. 19/2026 requires the submission of, among others, seller identity information, business licence documents from the country of origin, proof of the product standard compliance, bank account information for the transactions, Indonesian-language product descriptions, and information on the country of origin of shipment. Certain foreign seller information must also be supported by a certificate or inspection report issued by an independent survey institution in the country of origin (Article 6(1), (2), and (3) of MoT Reg. 19/2026).
- Complaint Services and Dispute Resolution
MoT Reg. 19/2026 requires PPMSE which operates a marketplace, online classified advertising, daily deals, social commerce, ride hailing, and online travel-agent platforms, as well as non-exempt intermediary service providers, to provide complaint services and dispute resolution mechanisms for their sellers (Article 10(1) of MoT Reg. 19/2026).
Such complaint services must be clearly displayed and easily accessible, provide more than one active electronic complaint channel, specify a response time or service level agreement, and be documented together with the resolution of the relevant complaint (Article 10(2) and (3) of MoT Reg. 19/2026). Any dispute between the sellers and PPMSE and/or non-exempt intermediary service providers must first be prioritized for amicable settlement before the parties pursue other available dispute resolution mechanisms (Article 11 of MoT Reg. 19/2026).
Separately, PPMSE and non-exempt intermediary service providers are required to provide consumer complaint services and display the relevant consumer complaint contact details, including the contact information of the Directorate General of Consumer Protection and Trade Compliance of MoT (Articles 12 and 13 of MoT Reg. 19/2026).
- Transparency Obligations
MoT Reg. 19/2026 strengthens the transparency obligations applicable to PPMSE, particularly regarding fees, product information, and seller labels.
Fees Transparency
PPMSE operating marketplace, online classified advertising, daily deals, social commerce, ride hailing, and online travel agent platforms are required to disclose all fees imposed on sellers in a transparent manner using clear and visible language. Such fees must be set out in a written agreement and/or electronic contract that is downloadable by both parties. Any amendment must be notified to, and approved by, the relevant seller. Sellers may submit written objections against unilateral amendments, fees, penalties, and/or other matters which were not previously agreed, and PPMSE must respond within 14 business days. If PPMSE fails to respond within this period, the objection is deemed administratively accepted and may be used as a basis for initiating dispute resolution (Article 14 of MoT Reg. 19/2026).
Goods and/or Services Information
Sellers are required to provide information on the origin of goods and evidence of compliance with applicable standards for the goods and/or services offered through PMSE, including, where applicable, product registration numbers, Indonesian National Standard (Standar Nasional Indonesia) certificates, halal certificate numbers, product registration or permit numbers for goods related to safety, security, health, environment, pharmaceutical products, or food products, as well as information on the origin of the goods, the country of origin of the seller, and/or the country of origin of shipment. PPMSE must facilitate the submission and display of such information through their electronic systems (Article 15 of MoT Reg. 19/2026).
Seller Label
PPMSE operating marketplaces, daily deals, ride-hailing, and/or online travel agent platforms may use seller labels indicating, among others, the seller’s official status, credibility level, or certain characteristics, such as “official store,” “authorised store,” “flagship store,” or similar labels. Where a label indicates an official relationship with a trademark owner, manufacturer, distributor, and/or an official agent, the label must be supported by relevant information and/or documents. PPMSE must ensure that such labels are based on clear criteria and displayed clearly, accurately, and in a manner that is understandable and not misleading to consumers, while the sellers remain responsible for the accuracy and validity of the information and documents submitted as the basis for the relevant label (Article 16 of MoT Reg. 19/2026).
- Domestic Prioritization
MoT Reg. 19/2026 requires business actors that operates an PMSE to support government programs by prioritizing the trade of domestic goods and/or services, improving the competitiveness of domestic goods and/or services, and providing promotional space for domestic products (Article 36 of MoT Reg. 19/2026). In particular, PPMSE operating marketplace, online classified advertising, daily deals, social commerce, ride hailing, and online travel agent platforms must ensure that their search, recommendation, and product ranking systems prioritize the display of domestic products, including by placing the domestic products, particulary the ones produced and/or traded by micro and small enterprises, at the top order of the main page, at least, on the first row of the first page (Article 40(3)(a) of MoT Reg. 19/2026).
If the domestic products do not appear on the first row of the first page of search or recommendation results, PPMSE must display all available domestic products in the relevant category and provide a main page and/or dedicated landing page containing promotional areas for domestic products (Article 40(3)(b) and (c) of MoT Reg. 19/2026). MoT Reg. 19/2026 also requires PPMSE to provide equal business opportunities to the sellers, and keep the goods and/or services free of direct or indirect price manipulation. The marketplace and social commerce PPMSEs are prohibited from acting as producers, while the social commerce PPMSEs are prohibited from facilitating payment transactions within their electronic systems (Article 18(1); and Article 25(2) and (3) of MoT Reg. 19/2026).
- Representative Office of a Foreign Trading Company in the PMSE Field (Kantor Perwakilan Perusahaan Perdagangan Asing di Bidang Perdagangan Melalui Sistem Elektronik or “KP3A PMSE”
MoT Reg. 19/2026 maintains the thresholds requiring a foreign PPMSE to appoint a representative in Indonesia. A foreign PPMSE must appoint a representative if it:
- has conducted transactions with, at least, 1,000 consumers in Indonesia within a one-year period;
- has delivered, at least, 1,000 packages to consumers in Indonesia within a one-year period; and/or
- accounts for, at least, 1% of domestic internet traffic within a one-year period.
(Article 22(1) and (2) of MoT Reg. 19/2026)
The representative must be established as a KP3A PMSE and may represent only one foreign PPMSE. It must also obtain a Business License for Representative Office of a Foreign Trading Company in the PMSE Sector (Surat Izin Usaha Perwakilan Perusahaan Perdagangan Asing di Bidang Perdagangan Melalui Sistem Elektronik or SIUP3A PMSE) through the Online Single Submission (“OSS”) system (Article 42(1) and (2); and Article 43(1) and (2) of MoT Reg. 19/2026).
A KP3A PMSE acts for and on behalf of the represented foreign PPMSE only in matters relating to consumer protection, development to improve the competitiveness of domestic products, and dispute resolution, and is prohibited from taking actions outside such role (Article 45(1) and (2) of MoT Reg. 19/2026). In addition, PPMSE conducting cross-border PMSE must apply a minimum price of FOB USD 100 per unit for finished goods of foreign origin sold directly by sellers into Indonesia, subject to any exemptions determined by the MoT based on ministerial-level coordination (Article 23 of MoT Reg. 19/2026).
- Utilization of AI in PMSE
MoT Reg. 19/2026 introduces specific provisions on the use of AI in PMSE. Business actors may use AI in or operating a PMSE, provided that such use of AI complies with applicable laws and regulations, and they remain responsible for such use (Article 47(1) and (2) of MoT Reg. 19/2026).
Such responsibility includes informing and/or labelling the goods and/or services generated, displayed, recommended, or promoted using AI, ensuring that the AI-generated information is accurate, clear, correct, and accountable, and protecting consumers, business actors, personal data, and intellectual property rights. For PPMSE, this also includes providing internal governance proportionate to the relevant AI risks, as well as a complaint or correction mechanism for information, recommendations, promotions, or services generated through AI. Business actors using AI must also comply with fair competition and anti-monopoly requirements and ensure that their AI use does not harm consumers or other business actors (Article 47(3) and (5) of MoT Reg. 19/2026).
- Transitional Provisions
Existing business licences which have been previously obtained by domestic PPMSE, domestic sellers, domestic intermediary service providers, and KP3A PMSE before the enactment of MoT Reg. 19/2026 shall remain valid, provided that they have not expired or been revoked and are registered in the OSS system (Article 73 of MoT Reg. 19/2026).
Sellers that conducted PMSE through PPMSE before the enactment of MoT Reg. 19/2026 are given a transition period of up to 18 months to comply with the business licensing requirements under Article 4 of MoT Reg. 19/2026. Failure to comply with MoT Reg. 19/2026 may result in administrative sanctions, including written warnings, inclusion in a priority supervision list, blacklisting, temporary blocking of PPMSE services, and/or revocation of business licences, depending on the relevant violation (Article 74 and Articles 57 to 70 of MoT Reg. 19/2026).
Concluding Remarks
MoT Reg. 19/2026 marks a measured but meaningful recalibration of Indonesia’s PMSE regime. Rather than overhauling the existing framework, the regulation extends it to a broader range of digital business models and places greater emphasis on platform accountability, seller verification, product transparency, domestic product visibility, and the responsible use of AI. The practical effect is clear: compliance is no longer confined to licensing formalities, but now reaches deeper into platform design, onboarding architecture, consumer-facing disclosures, recommendation systems, and internal governance.
For PPMSE, foreign platforms, sellers, and other digital commerce participants, the immediate task is to reassess existing PMSE operations against the new requirements, particularly in relation to seller licensing, cross-border trade, fee transparency, complaint handling, domestic product prioritization, and AI governance. As Indonesia’s digital market continues to expand, MoT Reg. 19/2026 signals a policy direction that is at once pro-commerce and more interventionist: platforms may continue to scale, but they are expected to do so with clearer rules, stronger accountability, and a more visible commitment to domestic market development.
Disclaimer: The information herein is of general nature and should not be treated as legal advice, nor shall it be relied upon by any party for any circumstance. Specific legal advice should be sought by interested parties to address their circumstances.
