Introduction

The rules and policies on consumer protection in Indonesia are fragmented, with regulations issued at different levels and by various authorities, depending on the type of product involved. Nonetheless, the preliminary framework for consumer protection law in Indonesia is set out in Law No 8 of 1999 on Consumer Protection (the “Consumer Protection Law”). This law establishes the rights and obligations of both consumers and businesses, outlines several prohibited conducts, and sets out applicable sanctions for violations.

Under the Consumer Protection Law, businesses have several key obligations to ensure fair treatment and transparency for consumers, including:

• providing accurate, clear and honest information about products, including their condition, warranty, and instructions for use, repair, and maintenance;
• treating all consumers fairly, respectfully and without discrimination;
• allowing consumers to test or try certain products when appropriate, and providing clear guarantees and warranties;
• offering compensation or refunds for harm caused by the use, consumption, or application of goods or services or if such goods or services do not match what was promised; and
• recalling products if they are found to be unsafe or non-compliant with applicable laws and regulations.

In addition to the Consumer Protection Law, sector-specific regulations provide more detailed or distinctive rules for consumer protection in various industries. For instance, consumer protection in the financial sector is governed by Law No 4 of 2023 on the Development and Strengthening of the Financial Sector. In the automotive industry, consumer protection is regulated under Minister of Trade Regulation No 21 of 2023 on the Determination of Business Activity and Product Standards in the Implementation of Risk-Based Business Licensing in the Trade Sector. This regulation sets out requirements relating to aftersales services and spare parts, product labelling, and the provision of user manuals in Indonesian for specific products.

Given the dynamic nature of consumer protection laws in Indonesia, businesses should stay informed about laws and regulations that are relevant to their businesses, including new laws and draft bills currently under discussion. Regularly reviewing and updating business practices and policies is essential to ensure ongoing compliance.

In the following sections, the authors set out recent and notable updates that businesses should be aware of in order to understand potential changes in the legal landscape, assess their impact, and, if necessary, prepare and implement appropriate compliance strategies.

No Proof of Fault Needed: Proposed Strict Liability for Defective Products in the Draft Bill on Consumer Protection

The Indonesian government, along with the parliament, is currently amending the Consumer Protection Law. One of the key proposed amendments is the implementation of a strict liability regime for defective products.

Under the current framework, manufacturers or importers generally bear responsibility for the products they sell or import in Indonesia. However, if distributors, intermediaries, or sellers modify or change a product in any way, they then become liable for any resulting defects or damages. It is worth noting that the liability of businesses remains fault-based, meaning that businesses may be exempt from liability if they can prove that the harm, loss or injury was not caused by their fault.

In relation to the above principle of businesses’ liability, the government is proposing to introduce a strict liability approach under the new Draft Consumer Protection Law. If enacted, this would allow consumers to claim compensation for damages caused by defective products or services, regardless of whether the manufacturer, importer, or seller was at fault.

This proposed change stems from growing pressure to strengthen consumer protection and reinforce the role of the Indonesian National Standards (Standar Nasional Indonesia, SNI). However, it remains to be seen how stakeholders will respond to this proposed amendment, as discussions are still ongoing.

Empowering Consumers, Elevating Standards: Indonesia’s National Consumer Protection Roadmap

The government of Indonesia has recently issued Presidential Regulation No 49 of 2024 on the National Consumer Protection Strategy (STRANAS-PK). This regulation marks a renewed commitment to strengthening the country’s consumer protection ecosystem. This regulation updates and expands the scope of the 2017–2019 strategy, responding to new challenges and emerging digital market realities.

Key goals include creating a more inclusive, fair, and integrated consumer protection system by co-ordinating efforts across ministries, local governments, businesses, and civil society. STRANAS-PK serves as a national roadmap to guide priority sectors, align policies, and promote the welfare and empowerment of Indonesian consumers. Further, general strategies to enhance business compliance include promoting fair business competition, improving effective communication with consumers, and improving supervision and enforcement by respective ministries.

Additionally, this regulation outlines key strategies and priority sectors for improving consumer protection and strengthening monitoring and law enforcement efforts across relevant sectors and authorities.

The nine priority sectors, along with two supporting sectors, identified under STRANAS-PK are as follows.

Food and medicine

The strategy focuses on strengthening consumer protection through enhanced product safety, efficacy and quality standards, while also increasing consumer awareness and satisfaction. Key policy interventions target products such as medicines (including those derived from natural ingredients), cosmetics, health supplements, and processed foods including snacks sold in schools. Key concerns include counterfeit drugs, expired or unregistered products, misleading health claims, and the presence of harmful substances in food.

E-commerce

The strategy encourages greater accountability from marketplace and platforms, promotes consumer digital literacy, and calls for adaptive regulations. Key concerns include counterfeit goods, deceptive advertisements, return/refund difficulties, cybersecurity risks and the misuse of consumer data.

Household electricity and gas

One of the main focuses is ensuring a reliable, affordable and transparent energy supply to households. The strategy includes strengthening the socialisation of consumer education and improving mechanisms for handling consumer complaints.

Telecommunication service

STRANAS-PK aims to improve the reliability of telecommunication services by addressing issues such as unfair data and roaming charges, unsolicited services, and the misuse of personal data. The strategy also includes strengthening digital infrastructure and enhancing transparency and accountability among service providers.

Finance

This sector covers consumer protection in the banking, insurance, investments and financial technology industries. Key concerns include product transparency, informed consent, digital lending practices, fraud prevention, and proper handling of consumer complaints. The strategy further highlights the need for strong regulatory enforcement.

Housing, water and sanitation

In this sector, STRANAS-PK highlights several key concerns regarding construction delays, hidden costs, water quality, and lacking functional sanitation systems. However, the strategy remains broad, focusing primarily on regulatory harmonisation and improved enforcement.

Transportation service

To improve the overall public and private transportation, this sector includes buses, trains, aviation, shipping, and ride-hailing. Key concerns include fee transparency, safety and equitable access. The strategy in this sector includes setting service quality standards and improving complaint resolution mechanisms.

Health service

Key focus areas include access to care, misuse of informed consent, medical malpractice, pricing transparency and patient data privacy. To address these concerns, STRANAS-PK promotes the implementation of quality assurance systems and the strengthening of sectoral standards in service delivery.

Electronics, telematics and motor vehicles

The strategy calls on producers and importers to implement effective complaint-handling systems and to comply with mandatory type supervision. Effective oversight in this sector requires co-ordination among multiple agencies, particularly the Ministry of Industry, Ministry of Trade, and the National Standardisation Agency (BSN).

In general, STRANAS-PK seeks to elevate businesses accountability and enforce efficient supervision across key sectors by addressing challenges and implementing institutional collaboration. However, its further development and implementation remain to be seen.

The Trend of Recent Consumer Protection Enforcement

One of the government bodies in Indonesia that oversee consumer issues is the National Consumer Protection Agency (, BPKN), whose duties include: (i) receiving complaints from the consumers, non-governmental consumer protection agency (LPKSM), or businesses; and (ii) providing recommendations to the government on consumer protection policies.

BPKN regularly publishes reports on consumer complaints across key sectors. Based on the data report published on their official website, there has been a notable rise in consumer complaints, with a total of 1,708 consumer complaints recorded as of 26 November 2024. This reflects a staggering increase of 84% from the 929 complaints reported in 2023. In 2024, the highest number of complaints was reported from sectors such as financial services, tourism and the creative economy, e-commerce, and housing. This significant increase in consumer complaints is due to various factors, including rising consumer awareness, greater access to online platforms for filing complaints, and the growing complexity of services and products in these sectors, which often lead to more frequent disputes. In response to this increasing trend, BPKN has focused on the enhancement of consumer protection outreach through multichannel strategies. This includes increasing consumer literacy, particularly in e-commerce and emerging commodities.

Further, to strengthen international co-operation, BPKN has also engaged with global and regional partners, including the ASEAN Committee on Consumer Protection, and participated in the 8th Intergovernmental Group of Experts on Consumer Law and Policy hosted by United Nations Trade and Development (UNCTAD) in Geneva, Switzerland, in July 2024. These efforts aim to align Indonesia with global consumer protection standards and enhance the country’s capacity to address increasingly complex regional challenges.

Besides BPKN, the Directorate General of Consumer Protection and Trade Stability, Ministry of Trade (DG-PKTN), is another governmental body overseeing consumer issues. As a regulator and supervisor, DG-PKTN formulates and enforces policies and regulations relating to consumer protection across most sectors. In addition, DG-PKTN handles consumer complaints and provides counselling to consumers and businesses. According to data from the Director of Consumer Empowerment of DG-PKTN, from January to March 2025, there were approximately 1,657 consumer complaints lodged with DG-PKTN, with most of the complaints coming from financial, automotive, telecommunication, transportation service, food, and pharmaceutical industries.

Indonesia Enforces Halal Certification

Indonesia, home to the world’s largest Muslim population, has commenced the enforcement of its halal certification requirements as mandated under Law No 33 of 2014 on Halal Product Assurance. This law requires that all products entering, circulating and traded within Indonesia be halal-certified if they fall under categories subject to halal obligation. The primary objectives are to protect Muslim consumers and strengthen Indonesia’s position as a global halal hub.

Under the current regulatory regime, products required to be halal must be accompanied by a halal certificate and clearly labelled as “halal.” Conversely, if a product is not halal, it must be explicitly labelled as “non-halal” on its packaging.

To provide businesses with an adaptation period, the halal certification obligation is being implemented in stages, depending on the product categories, as stipulated under Government Regulation No 42/2024 on the Implementation of Halal Products Assurance. Since 18 October 2024, this obligation has officially applied to:

• food and beverage products;
• raw materials, food additives, and auxiliary materials for food and beverage products; and
• slaughtered products and related services.

A relaxation is provided to micro and small enterprises (MSEs), exempting them from this obligation until 17 October 2026. A similar exemption applies to imported products, subject to the finalisation of mutual recognition agreements for halal certification following co-ordination with the relevant ministries/agencies, but in any case, not later than 17 October 2026.

The effective enforcement of this obligation requires close co-ordination between the Halal Product Assurance Agency (BPJPH) and other government agencies, particularly the Food and Drug Agency (BPOM). BPOM is mandated to regulate and supervise the safety, quality and efficacy of food, drugs, cosmetics and health products in Indonesia to protect public health in Indonesia. Recently, as a result of this inter-agency co-ordination for joint supervision and market monitoring, the two agencies identified several halal-certified products that were found to contain non-halal ingredients. Consequently, BPJPH and BPOM ordered their withdrawal from the market. This action highlights the government’s strong commitment to upholding halal certification standards in Indonesia.

On the international front, BPJPH has entered into 72 mutual recognition agreements (MRAs) with halal bodies from various countries. These agreements enable halal certificates issued abroad by recognised institutions to be accepted in Indonesia, facilitating trade while maintaining Indonesia’s halal standards. Such collaboration is key for ensuring the smooth entry of imported goods into the Indonesian market while upholding halal certification requirements.

In subsequent stages, other product categories, such as pharmaceuticals, cosmetics and chemicals, will have staggered deadlines, giving businesses more time to comply. Mandatory halal certification will apply to the following categories starting on 18 October 2026:

• health supplements and traditional medicine;
• cosmetics, genetically modified products, chemical products;
• clothing and headgear;
• household health supplies, office supplies, household appliances; and
• medical devices classified as Class A risk.

Businesses operating in these categories are encouraged to begin preparations for certification in advance to ensure timely compliance.