Are healthcare AI system providers required to register as Electronic System Operators (PSE)?

Generally yes. Permenkominfo 5/2020 (as amended by Permenkominfo 10/2021) and PP 71/2019 do not create a separate registration track labeled specifically for AI. Instead, registration attaches to an operator's status as a Private-Scope Electronic System Operator (PSE). Healthcare AI systems that form part of an electronic medical record system. Alternatively, That run as online applications processing patient personal data, fall within the mandatory registration categories before end-user deployment.

Why healthcare AI providers qualify as Private-Scope PSEs

Article 1 points 5 and 6 of Permenkominfo 5/2020 define a Private-Scope PSE as any electronic system operated by individuals, business entities, or the community. This definition makes no distinction between AI software and conventional software. Registration is mandatory when an operator falls into either group under Article 2 paragraph (2) of Permenkominfo 5/2020 (and PP 71/2019 Article 2 paragraph (5)):

• PSEs regulated or supervised by a ministry or government agency (sub-paragraph (a)), such as electronic medical record systems regulated by the Ministry of Health. or
• PSEs operating a portal, website. Alternatively, Online application that processes personal data in operational activities serving the public in connection with electronic transactions (sub-paragraph (b) point 6).

Ministry of Communication and Informatics Circular Letter Number 9 of 2023 on AI Ethics provides ethical guidance only and is not a registration statute.

Registration process, foreign providers, and sanctions

• Submission via OSS (Articles 3 and 6): Registration is submitted through the Online Single Submission (OSS) system. The registration form covers system name, sector, business model, functions, categories of personal data processed, and data processing and storage locations (Article 3 paragraph (4)).
• Foreign providers (Article 4 paragraph (1)): Providers incorporated under foreign law must still register if they provide services or their systems are used within Indonesia.
• Access blocking sanction (Article 7): Unregistered providers face administrative access blocking until registration is completed.

Two additional registrations in the healthcare sector

For electronic medical record (RME) systems, Permenkes 24/2022 adds two sector-specific requirements:

1. The partnering PSE must be registered as a healthcare-sector PSE at the ministry responsible for communications and informatics (Article 9 paragraph (3)). and
2. The healthcare facility or PSE must register the electronic system with the Ministry of Health (Article 12 paragraph (1)).

For telemedicine services, Law 17/2023 Article 172 paragraph (2) and PP 28/2024 Article 558 paragraph (4) likewise require healthcare facilities to partner with registered PSEs. When evaluating a healthcare AI vendor, clinics and hospitals should request proof of PSE registration, proof of Ministry of Health RME registration where applicable. In addition, Written disclosure of data storage locations.

Legal basis

• Permenkominfo Number 5 of 2020 on Private-Scope PSEs (as amended by Permenkominfo 10/2021): Article 1 points 5 and 6. Articles 2–7.
• Government Regulation Number 71 of 2019 (PP 71/2019): Article 2 paragraphs (2), (3), and (5). Article 6 paragraphs (1)–(3).
• Ministry of Health Regulation Number 24 of 2022 on Medical Records (Permenkes 24/2022): Article 9 paragraph (3) and Article 12 paragraph (1).
• Law Number 17 of 2023 on Health: Article 172 paragraph (2).
• Government Regulation Number 28 of 2024 (PP 28/2024): Article 558 paragraph (4).