Under Government Regulation 71 of 2019 on the Implementation of Electronic Systems and Transactions, Electronic System Organizers (“ESO”) are required to be registered with the Ministry of Communication and Informatics (“MOCI”). In addition, under MOCI Regulation 5 of 2020 (as amended by MOCI Regulation 10 of 2021), this registration obligation must be complied with within 6 months of OSS-RBA licensing coming into effect. The MOCI has issued Circular Letter 3 of 2022 on the Effective Date of Private ESO Registration as a follow up to the above requirement.

The key points of the Circular Letter include among others, the following:
1. Private ESOs (both domestic and foreign) must be registered within 6 months of 21 January 2022;
2. for not registering by 20 July 2022 a Private ESO will be subject to an administrative sanction imposed by the MOCI (i.e., access blocking);
3. they must register through the OSS-RBA website (https://oss.go.id); and
4. registration guidelines are available at https://komin.fo/pendaftaranpseprivat