Child Protected or Chained? Observer Criticizes the Lack of Regulation

JAKARTA - Child protection in the digital space is a state responsibility that cannot be negotiated. However, the implementation of policies in this field must be carried out transparently and have clear parameters. Without clarity, regulations have the potential to create uncertainty, both for the child protection support ecosystem and for the digital ecosystem as a whole.

ICT Watch Executive Director Indriyatno Banyumurti assessed that the implementation of Government Regulation Number 17 of 2025 concerning the Governance of the Implementation of Electronic Systems in Child Protection (PP TUNAS) will be effective if supported by an adequate ecosystem. One aspect that is in the spotlight is related to the determination of the risk parameters of digital platforms. According to Indriyatno, transparency and objectivity in the risk assessment process of platforms are crucial factors so that the implementation of this regulation can run effectively and not give rise to different interpretations for all stakeholders.

He explained, Regulation of the Minister of Communication and Digital Number 9 of 2026 concerning the Governance of the Implementation of Electronic Systems in the Protection of Children which has been published still requires further elaboration through a Ministerial Decree. This explanation is important, especially to clarify the risk indicators which until now are still awaited by stakeholders.

"The challenge for PSE is that they are required to submit the results of the self assessment three months later in accordance with Article 62 of the Komdigi Decree, while the indicators are not yet fully ready," he said in a statement in Jakarta, Thursday, March 12.

He also believes that the Minister of Law and Human Rights will need to include objective parameters and provide room for all parties, including digital platform organizers, to be able to provide input. Thus, risk classification can be carried out transparently. Without clear parameters, there is potential for distortion and inconsistency in risk classification for all digital platforms that can result in suboptimal protection.

Beyond the technical aspects of regulation, Indriyatno emphasized that the success of child protection in the digital space also depends heavily on the readiness of its supporting ecosystem. One important step that needs to be taken is to strengthen digital literacy massively in various lines.

This education needs to reach parents and caregivers in the family environment, as well as teachers in schools. With a better understanding, they can play an active role in accompanying children when interacting in the digital space.

"PSE is also obliged to carry out this education with content that is embedded in its platform," said Indriyatno.

In addition to education, he also considers it important to have a safe digital space for children to express themselves through platforms that have adequate supervision and protection standards.

"Don't let them even enter a platform that is difficult to monitor and has open rules with risks that are actually greater for children," he said.

Similarly, public policy expert from Trisakti University, Trubus Rahardiansah, also assessed that the formulation of child protection policies in the digital space needs to involve more parties, including children and parents as the groups directly affected. Trubus said that the current policy approach is still top-down and has not fully opened up a dialogue with key stakeholders.

"Children as the target of policies should also be heard. There needs to be a dialogue with them, parents, and educators," he said.

Trubus also reminded that social media does not have a completely negative impact on children. Many digital content are actually educational and can help develop their knowledge and creativity. Therefore, according to him, child protection policies in the digital space should not only focus on restrictions, but also on education and guidance.

"The role of parents and teachers remains the key. Regulations alone are not enough if supervision in the family and school does not work," he said.

Meanwhile, Amnesty International Indonesia Executive Director Usman Hamid reminded that the implementation of the PP TUNAS did not restrict the rights of young people in Indonesia to access digital spaces, including online discussion spaces.

He said social media had become an important space for young people to voice their opinions and express their views on various issues affecting their lives.

"This complete ban on social media will deprive tens of millions of young people in Indonesia of important channels to communicate with others, access information, develop creativity, and express themselves," Usman said in an official statement, Tuesday, March 10.

According to him, policies that are too restrictive can actually encourage children and adolescents to access social media secretly without adequate protection. This can actually bring greater risks for them.

Usman emphasized that digital access today has become an important part of children's education, well-being, and participation in the public sphere. Therefore, the prohibition approach is considered to have the potential to close opportunities to build solutions that empower children.

"This ban is tantamount to ignoring children to be heard in every decision that affects their lives," said Usman.