Protecting Minors or Straining Rights? A Constitutional and Comparative Impact Assessment of Indonesia’s PP Tunas

Abstract

In March 2025 Indonesia enacted Government Regulation No. 17 of 2025 on the Governance of Electronic System Operations for Child Protection, popularly known as PP Tunas, with enforcement following in March 2026 alongside its implementing instrument, Ministerial Regulation No. 9 of 2026. The measure restricts minors’ access to digital platforms through a graduated, risk-based scheme rather than a blanket ban, and is frequently presented as a more sophisticated regional response than the under-sixteen prohibitions adopted in Australia and Malaysia. This article offers a legal and impact-assessment commentary on the Regulation. It proceeds doctrinally and comparatively, situating the measure within the hierarchy of Indonesian legal sources, testing it against the constitutional guarantees of Articles 28C, 28F and 28J of the 1945 Constitution, and assessing its likely effects across three axes: technical-institutional feasibility, the protection of minors, and market structure. The analysis finds that Indonesia’s difficulty lies less in the existence of protective norms than in the unfinished translation of those norms into operable, auditable standards, and that several of the Regulation’s own commands stand in unresolved tension with one another. The comparative survey of Indonesia, Australia and Malaysia shows that no jurisdiction has yet reconciled child protection, privacy and technical feasibility, and that Indonesia’s graduated model carries both a genuine advantage in proportionality and a distinctive set of implementation risks.