Indonesia PSE Registration for Foreign Companies: Who Must Register and How OSS Works

If you are reading this with a letter from Komdigi open in another tab, its deadline is probably a week away or less. That is the pattern Komdigi has followed through 2026: a list of named operators, a short deadline, then a warning, with blocking as the stated next step.

The obligation behind the letter is registration as a PSE Lingkup Privat, a private-scope electronic system operator. It applies to foreign companies whose website, app or platform is used in Indonesia. It does not require an Indonesian company. And since October 2025 it is filed somewhere other than where most English guides still send you.

The legal basis

Komdigi (Kementerian Komunikasi dan Digital, the Ministry of Communication and Digital Affairs) is the ministry formerly called Kominfo. That is why the 2020 rules are a Permenkominfo and the 2025 ones a Permenkomdigi.

• PP 71/2019, Art. 6. The government regulation on electronic systems and transactions, which requires electronic system operators to register.
• Permenkominfo 5/2020. It sets out who must register, what they declare and what happens if they do not. Its only amendment, Permenkominfo 10/2021, changed the transition deadline. The text is on Komdigi's legal database.
• Permenkomdigi 15/2025 (Annex II B.1, 22 October 2025) and BKPM Regulation 5/2025 (2 October 2025). Together these set the current procedure. BKPM is the investment authority that runs OSS (Online Single Submission), Indonesia's business licensing system, and the foreign registration now runs through it.

Who has to register

Article 4(1) of Permenkominfo 5/2020 covers a foreign operator that provides services in Indonesia, does business in Indonesia, or runs a system that is used or offered in Indonesia. Any one of those is enough. The system must also fall into one of the categories listed in Art. 2(2)(b).

That second condition looks like a filter. It rarely filters anything. Category 5 covers systems that provide information as text, images or video, and category 6 covers systems that process personal data. Between them they reach almost any website: a company site with a contact form publishes information and collects personal data.

Three points to settle early:

• There is no threshold. The form asks for your number of Indonesian users and the value of your Indonesian transactions, but those figures are declared, not tested against a minimum. A small Indonesian audience is not an exemption.
• Registration is due before use. Art. 2(3) requires it before Indonesian users use the system. If they already do, you are late.
• It describes a system, not a company. The form takes one system name and its URL. The 25 operators Komdigi wrote to in June 2026 had 57 systems between them.

Having no office in Indonesia does not take you out of scope, because the test is use, not establishment. If you believe a system is out of scope, get that view in writing from Indonesian counsel. This article is not legal advice, and we are not a law firm.

What enforcement looks like

The sanction for a system that should be registered and is not sits in Art. 7(2): access blocking (pemutusan akses). The warning ladder in Art. 7(3) is for registered operators who fail to report changes to their data. We have found no fine for non-registration in the regulations. The exposure is that Indonesian users cannot reach your service.

This has already happened to well-known foreign brands. On 28 June 2025 Komdigi blocked eBay, KLM and Bath & Body Works. Access comes back once the system is registered (Art. 7(4)), on request by email to aduanpseprivat@mail.komdigi.go.id.

In 2026 enforcement turned into named batches:

Also on 28 September, a Komdigi Director General described the sequence to the press as two warnings, then a temporary suspension, then blocking (Investortrust, a press report).

Look at the deadlines: seven days in June, four in July, three at the end of September. And look at who was named. Airlines, hotel groups and a fitness app are not what most people would call Indonesian businesses, which is the point: the trigger is use in Indonesia.

The filing: OSS, not the PSE portal

Most guides online tell you to register at pse.komdigi.go.id. That was the route before October 2025. A foreign operator now files in OSS. The registration then appears on pse.komdigi.go.id, the public register where any registration can be checked.

The steps, under BKPM Regulation 5/2025 Art. 273 and Permenkomdigi 15/2025:

1. Open an OSS account as a foreign entity. The account type is Badan Usaha Luar Negeri (foreign business entity), PSE Asing (foreign PSE). OSS verifies the email address, and the person in charge is identified by passport.
2. Enter the business data and the system data. The full list is below.
3. Upload the documents. The certificate of incorporation or certificate of domicile with a sworn Indonesian translation, and a self-declaration. Art. 273 does not list an apostille.
4. OSS issues an NIB (Nomor Induk Berusaha, the business identification number) "as the identity of the foreign PSE".
5. The same registration issues the TDPSE (Tanda Daftar Penyelenggara Sistem Elektronik, the PSE registration certificate) automatically, under Permenkomdigi 15/2025. Komdigi may review it afterwards.

There is no government fee. The PSE portal's FAQ says the process up to the TDPSE carries no charge of any kind.

What the form asks for

Art. 3(3) and (4) and Art. 4(2) of Permenkominfo 5/2020 set out the data. Collect it before you open OSS, because it rarely sits with one person.

• company identity
• the leader or person in charge
• the name of the system
• its sector
• its URL
• DNS and IP addresses
• the business model
• the personal data the system processes
• where that data is located
• an access-guarantee statement
• number of users in Indonesia
• value of transactions in Indonesia

The answers on personal data and data location should agree with your privacy notice. If you keep a GDPR record of processing activities, most of them are already written down (our GDPR guide explains that record).

The one input you cannot produce in-house is the sworn translation, done by a penerjemah tersumpah (sworn translator). On a short deadline, order it first.

Three things older guides get wrong

"File on pse.komdigi.go.id." That describes the procedure before October 2025. The filing is in OSS; the PSE portal shows the result.

"You need a PT PMA and an NIB first." Half right. A PT PMA, the foreign-owned Indonesian limited company, is not needed. An NIB is involved, but OSS issues it to your foreign company as part of this registration. The "NIB first" step you may see on the portal is labelled for domestic operators.

"No Indonesian presence needed." Also half right. No Indonesian entity is needed, but Art. 25 of Permenkominfo 5/2020 requires a liaison officer domiciled in Indonesia. That is a person, not a company or an office.

Who can file, and in whose name

Someone else can do the filing for you, but not in place of you. BKPM Regulation 5/2025 Art. 322(9) expects OSS account holders to authorise others to act in their account. The account still belongs to your company, and so do the self-declarations made in it. The registrant has to be the owner of the system, and the account holder stays liable for what was declared.

Be wary of any offer to register your system in the provider's own name. The NIB and the TDPSE should carry your company's name.

After registration

A TDPSE has no renewal. What continues is this:

The change reports deserve more attention than they usually get. The Art. 7(3) warning ladder exists for exactly that failure: a registered operator whose declared data has gone stale. A new domain, a move to another hosting region or a new person in charge each changes something you declared.

Still pending, and not covered by a TDPSE

A representative office for foreign PSEs. Press reports describe a requirement for foreign operators to open a representative office as still under study. It is not law today.

PP Tunas. Government Regulation 17/2025 on child protection, implemented by Permenkomdigi 9/2026, requires every TDPSE holder to complete a self-assessment. Reported deadlines were 6 June 2026, later moved to 30 June 2026. Registering puts you among the operators it addresses, and the self-assessment is separate work that a TDPSE does not complete for you.

E-commerce trade licensing. A platform that trades with Indonesian buyers may also need trade licensing, which is a separate regime: a PB PMSE business licence for trading through electronic systems and, above a threshold, a KP3A PMSE representative office. A TDPSE covers neither.

If you have a letter with a deadline

A sequence that fits inside a week, assuming the systems are in scope:

1. Search pse.komdigi.go.id for each system. A group company may already hold a registration for one of them.
2. Match the letter to your systems. List every name and URL it mentions.
3. Order the sworn translation of the certificate of incorporation the same day.
4. Choose the person in charge, whose passport identifies them in OSS, and decide who will be the liaison officer in Indonesia.
5. Collect the data from the list above.
6. File in OSS. When the TDPSE is issued, tell Komdigi through the contact given in the letter.
7. If access is already blocked, email aduanpseprivat@mail.komdigi.go.id with the registration and ask for access to be restored under Art. 7(4).

No one can promise a date, or that a system will not be blocked while the file is being prepared. OSS issues the TDPSE automatically once the file is complete, so the work is in getting it complete, and Komdigi may still review the registration afterwards.

Getting it done

We file the registration in your company's OSS account for a fixed fee per electronic system, sworn Indonesian translation of the certificate of incorporation included, and see it through until OSS issues the foreign-PSE NIB and the TDPSE. Optional yearly upkeep files the LKPM by 15 January and any change filings. The liaison officer is not included: you name your own, or we refer you to one. The details are on the PSE registration service page, or book a call if your letter's deadline is close.