AI Developer (Pengembang KA) in Indonesia's August 2025 Draft AI Ethics Guide

In the August 2025 public consultation draft of the AI Ethics Guidelines issued by the Ministry of Communication. Furthermore, Digital Affairs (Komdigi), an AI Developer (Pengembang Kecerdasan Artifisial) is the party that designs, develops. In addition, Conducts initial training of an AI model, including determining the architecture, algorithms. In addition, Training methodology used to produce the AI system (Definition 6). Because this text is a consultation draft, its wording may change before final adoption.

Position in the Draft

The draft groups regulated parties into Users, Sector Actors (Pelaku Sektor), and Policymakers. Under Definition 3, Sector Actors comprise Data Providers (Definition 5), AI Developers (Definition 6), AI System Providers (Definition 7). In addition, AI System Operators (Definition 8). Lifecycle duties such as risk management across every stage of the AI lifecycle apply to Sector Actors collectively.

Why the Distinction Matters

The draft requires documenting which party is responsible for developing and deploying an AI system (Chapter IV. Chapter VII.2 Table 1). Under Definition 8, a hospital or clinic operating a vendor's AI application aligns with the role of an AI System Operator rather than an AI Developer. Safeguards tied to model development include representative data, periodic algorithmic impact testing, technical documentation, and developer competence. Non-commercial testing, development, and research are exempted from the draft's monitoring. Furthermore, Evaluation provisions so long as they comply with applicable laws (Chapter VIII item 2).

Comparison: SE Menkominfo Number 9 of 2023 (item 5(b)) does not define AI Developer separately. Furthermore, Instead uses a single umbrella term, AI Implementation (Penyelenggaraan KA), covering research, product development, marketing, and use.

Legal basis: Komdigi Draft Concept of AI Ethics Guidelines (August 2025. Not yet in force) Definitions 3, 5–8, Introduction, Chapter IV, Chapter VII.2 Table 1, and Chapter VIII(2). SE Menkominfo Number 9 of 2023 item 5(b).