This edition of Indonesian Law Digest highlights that the Deferred Prosecution Agreement ("DPA") mechanism under Law No. 20 of 2025 on Criminal Procedural Law (Kitab Undang-Undang Hukum Acara Pidana/KUHAP) allows deferred prosecution of corporations admitting wrongdoing, subject to obligations such as compensation and compliance enhancements. Upon fulfillment, cases may be terminated without further proceedings. Comparative international practice, including the Rolls-Royce (2017) and Standard Chartered Bank (2019) cases, illustrates DPAs effectiveness in enhancing compliance, restoring losses, and minimizing business disruption.

Law No. 20 of 2025 on Criminal Procedural Law (Kitab Undang-Undang Hukum Acara Pidana KUHAP), which officially came into force in early 2026, establishes a comprehensive corporate criminal liability framework, which was largely missing under the previous framework of Law No. 8 of 1981 on KUHAP. The new KUHAP clearly defines corporate responsibility, including the liability of management, controllers and beneficial owners, while introducing various procedural innovations such as pretrial mechanisms and expanded coercive measures, including travel bans and asset blocking.

During the course of 2025, Indonesia's regulatory framework continued to develop. This development encompassed amendments to the Priority National Legislation Program (Program Legislasi Nasional/Prolegnas). At the time of writing, the House of Representatives (Dewan Perwakilan Rakyat/DPR) had finalized 64 Draft Bills for inclusion in the 2026 Priority Prolegnas after the completion of several revisions. This edition of Indonesian Law Digest (ILD) highlights the most anticipated Draft Bills and regulatory developments that are expected to affect multiple sectors during the course of the year ahead.

In 2025, Indonesia's legal and regulatory landscape underwent a significant shift amid political transitions and major policy reforms that are affecting both the public and private sectors. Hukumonline recorded approximately 2,617 new Regulations that were introduced across a diverse range of sectors. This edition of Indonesian Law Digest (ILD) summarizes key developments and draws on Hukumonlines daily Indonesian Legal Briefs (ILB) and Intelligence Updates (LIU) publications, offering readers a clear overview of the most impactful new frameworks and their implications across various industries.

Indonesia's Free Nutritious Meal (Makan Bergizi Gratis "MBG") Program, which is currently governed under Regulation of the President No. 115 of 2025, attempts to address critical child health and nutrition gaps within Indonesia by covering five beneficiary groups. In essence, this framework governs the implementation of the MBG program, including planning, food safety, nutrition and halal standards, as well as providing support for the program's implementation through coordination mechanisms, risk management, domestic product use, business participation and the management of food waste.

The use and processing of biometric data are increasing globally, particularly in the financial sector and residency administration in Indonesia. However, while offering various benefits, biometric processing also raises significant privacy and data protection concerns. As Indonesia lacks biometric-specific regulations beyond Law No. 27 of 2022 on Personal Data Protection, the regulatory approaches of the United States and Australia provide valuable insights for future policy and regulatory development.

The corruption conviction of three former PT ASDP directors, linked to the companys purchase of PT Jembatan Nusantara, drew national attention after authority claimed the deal caused Rp 1.25 trillion in state losses. Although the court declared them guilty, the President later granted rehabilitation following public input through the House of Representatives (Dewan Perwakilan Rakyat/DPR). This case revived debate over business judgment versus criminal liability in state-owned enterprise. This analysis compares the PT ASDP case with similar cases to review how courts apply the Business Judgement Rule and presidential prerogative powers.

Indonesia's most recent framework on risk-based business licensing, which introduces new service level agreements (SLA) and tighter compliance requirements, also applies to palm-oil plantations and processing facilities. This means that these types of businesses must meet various national and regional requirements relating to land acquisition, environmental approvals, reporting, waste management and other relevant business licensing. Ultimately, these palm-oil plantation companies must also secure mandatory Indonesian Sustainable Palm Oil (ISPO) certification by meeting all of the applicable sustainability principles and criteria.

The Bill on Criminal Procedural Law (Rancangan Kitab Undang-Undang Hukum Acara Pidana RKUHAP) introduces a comprehensive reform of Indonesias criminal procedure system, replacing Law No. 8 of 1981 after more than four decades. Although developed since 2004 through extensive drafting and consultations, its ratification has still prompted significant public debate, particularly over issues relating to wiretapping, blocking, seizure, and arrest and detention. It also updates core procedural stages and adds new provisions on corporate criminal liability and deferred prosecution mechanisms.

The Draft Bill on Criminal Adjustment (Draft Bill) marks a pivotal move for Indonesia and will align the countrys various sectoral laws with the updated framework of Law No. 1 of 2023, which sets out Indonesias new Criminal Law Code (Kitab Undang-Undang Hukum Pidana/KUHP). This move resolves sentencing inconsistencies and removes outdated provisions. In addition, the Draft Bill revises corporate criminal liability by clearly distinguishing between the responsibilities of corporations and individuals who work for them.