(BSA): Recommendations for Indonesia's National AI Roadmap and Ethical Guidelines

Key Chapter Title List

1. BSA Resource Overview
2. AI Ethical Guidelines Should Be Voluntary
3. Definition Setting Aligned with International Understanding
4. Roles and Responsibilities in the AI Ecosystem
5. Risk-Based Approach
6. Self-Assessment and Incident Reporting
7. Consultation with Stakeholders
8. Conclusion

Document Introduction

This document is a formal policy recommendation submitted by the Business Software Alliance (BSA) to the Indonesian Ministry of Communication and Digital (KOMDIGI) on August 22, 2025. This recommendation addresses the public consultation conducted by the Indonesian government on the "National Artificial Intelligence Roadmap White Paper (Draft)" and the "Artificial Intelligence Ethical Guidelines (Draft)". It aims to provide professional opinions from the perspective of the global leading enterprise software industry for Indonesia to build its national AI strategy and governance framework. As a global industry association covering dozens of top technology companies such as Adobe, Microsoft, Amazon Web Services, IBM, and OpenAI, BSA has long been concerned with the development of Indonesia's digital policies and has previously been deeply involved in issues such as personal data protection laws, electronic system operators, and national data centers.

The core issue of the report is how to balance the incentives for AI innovation with risk control. BSA clearly recommends from the outset that the Indonesian government should clarify the non-binding and voluntary compliance nature of its "AI Ethical Guidelines" to avoid imposing unnecessary restrictions on technological development. The document emphasizes that if the government intends to make certain provisions legally binding, it must issue a clear declaration and supplement it with multiple rounds of in-depth stakeholder consultations to ensure the clarity, feasibility, and alignment of the provisions with international best practices. This position sets the tone for all subsequent BSA recommendations, advocating for a flexible, risk-based, and internationally aligned governance model.

At the specific recommendation level, the report focuses on three main pillars. The first is the international alignment of definitions and frameworks. BSA strongly recommends that Indonesia adopt the updated definition of artificial intelligence from the Organisation for Economic Co-operation and Development (OECD) and, in defining roles (such as developers, integrators, deployers) and allocating responsibilities, refer to the risk management frameworks of the OECD, the Association of Southeast Asian Nations (ASEAN), and the US National Institute of Standards and Technology (NIST). This international coordination is seen as key to reducing regulatory conflicts, promoting cross-border cooperation, and establishing global safety benchmarks. Secondly, the report advocates for a strictly risk-based, tiered governance approach. Governance efforts should focus on high-risk AI application scenarios that could cause significant harm to individuals or society (such as decisions related to housing, credit, employment), while maintaining a relaxed approach for low-risk applications to unleash their economic benefits. Thirdly, regarding implementation mechanisms, BSA recommends that any self-assessment requirements should be limited to clearly defined high-risk use cases and undertaken by the most appropriate party in the supply chain (e.g., developers assess training data, deployers assess usage scenarios). The report particularly opposes establishing an independent, duplicate reporting framework for AI incidents, arguing that existing cybersecurity and critical infrastructure incident reporting channels should be utilized to avoid imposing unnecessary compliance burdens on businesses.

Finally, BSA offers recommendations on the policy-making process itself. Citing the complexities encountered during the legislative process of the EU's AI Act as an example, the report warns that overly rushed timelines could lead to flawed frameworks or impractical recommendations. Therefore, BSA recommends that the Indonesian government extend the consultation deadline by one month to September 19 and set clear milestones for the implementation of the ethical guidelines. This aims to allow space for more adequate dialogue with experts, industry, and civil society, thereby developing balanced and effective guidelines that align with both global best practices and Indonesia's unique national conditions and priorities. The entire document reflects the industry's urgent desire to collaborate with policymakers to jointly shape an AI governance environment that can both foster innovation and manage risks responsibly.