The Asia Internet Coalition (AIC) and its members express our sincere gratitude to the Ministry of Communications and Information Technology (KOMINFO) for the opportunity to submit comments on the Government Regulation No. 71/2019 (GR71) and subsequent Regulation on Governance of Private Scope Electronic System Administrator, on the 26th of March 2020.
While we commend KOMINFO’s efforts to develop a legal framework for electronic system administrators under GR71, in our previous submissions to the government we have expressed our concerns on the requirements imposed under the Regulation and suggested that they be aligned with global best practices.
In this regard, we would like to reiterate that this important regulation necessitates a credible, wide-ranging and transparent consultation, which by definition must involve sharing updated policy drafts with stakeholders so there is common understanding on feedback solicited and the resulting revisions. To that end, we once again respectfully request that the Government of Indonesia and KOMINFO make available a copy of the revised draft regulation to seek additional input and feedback from relevant stakeholders.