Minister of Trade Regulation No. 19 of 2026: A Practical Guide to Indonesia's New E-Commerce Rules

This regulation serves as a key implementing rule of Government Regulation No. 80 of 2019 on Perdagangan Melalui Sistem Elektronik (PMSE), replaces the previous regime under Minister of Trade Regulation No. 31 of 2023 and also brings tighter compliance standards for marketplaces, social commerce platforms, and cross-border e-commerce players.

Below is a practical, business-focused breakdown of what has changed and what companies need to pay attention to.

1. Who Falls Under This Regulation?

The scope is intentionally broad. It covers all parties involved in e-commerce activities, including:

• Domestic merchants (Pedagang Dalam Negeri)
• Foreign merchants (Pedagang Luar Negeri)
• Platform operators (PPMSE)
• Intermediary service providers (PSP)

The regulation also clearly defines various business models, such as marketplaces, social commerce, online retail, ride-hailing, and online travel agents (Article 3). This classification is important because different obligations apply depending on the type of platform or activity.

2. Mandatory Business Licensing

All e-commerce players must:

• Obtain Business Licenses (Perizinan Berusaha); and
• Comply with relevant sectoral requirements (Article 4(1)–(2)).

For marketplaces, the obligation goes even further:

• They must reject merchants without proper licensing (Article 4(4));
• At minimum, merchants must have an NIB and relevant technical compliance (Article 4(5)).

There is a limited grace period. Platforms may temporarily onboard merchants under a “Dalam Proses Legalisasi” label, but only for 6 months. After that, access must be restricted if licensing is still incomplete (Article 17(3)–(5)).

A key message from this regulation is simple: no license, no business.

3. Tighter Requirements for Foreign Sellers

Foreign merchants now face stricter entry requirements. They must provide:

• Identity of the foreign trader, including the name and address of the foreign trade origin;
• Business license issued by an authorized institution in the country of origin, legalized by the competent authority or a representative official of the Republic of Indonesia in the country of origin;
• Proof of compliance with Indonesian standards (e.g., SNI, halal where applicable);
• Product descriptions in Bahasa Indonesia; and
• Clear information on origin and shipping country (Article 6(1)–(2)).

If these requirements are not met, the platform is required to reject the merchant’s registration (Article 6(5)).

4. Business Licensing for Platform Operators and Intermediary Service Providers

Beyond general licensing obligations, Permendag 19/2026 sets out specific rules for platforms and system operators.

• PPMSE and PSP that are not exempt must obtain a PMSE-specific Business License (Article 7(1)).
• This obligation also applies to state-owned and regionally owned enterprises engaging in PMSE (Article 7(2)).
• Importantly, merchants operating their own platforms are deemed PPMSE and are therefore subject to the same licensing requirement (Article 7(3)).

In terms of process:

• Applications must be submitted through the OSS system to the Minister of Trade (Article 8(1));
• The license is issued by OSS on behalf of the Minister (Article 8(3)); and
• Once granted, the license remains valid as long as the business continues operating (Article 8(4)).

Finally, all PMSE licensing must align with the relevant KBLI classification, depending on the business activity carried out (Article 9).

5. New Responsibilities for Marketplaces and Platforms

Permendag 19/2026 positions platforms as active compliance gatekeepers, not just intermediaries.

a. Transparent Fees

Platforms must clearly disclose all fees in a way that is easy to understand. These fees must be documented in written or electronic agreements, and any changes require merchant consent (Article 14(1)–(4)).

b. Complaint Handling System

Platforms must:

• Provide accessible complaint channels;
• Set response timelines (SLA); and
• Keep records of complaints and resolutions (Article 10).

c. Consumer Protection Access

They must also display consumer complaint contact details and government complaint channels (Article 12–13).

6. Product Transparency and Platform Accountability

Merchants are required to provide detailed product information, including:

• Certification (SNI, halal, product registration);
• Origin of goods; and
• Safety and compliance data (Article 15(1)).

At the same time, platforms that assign labels like “official store”, “authorized store”, “flagship store”, “mall”, “best seller”, “power merchant”, “official parter”, etc must:

• Verify the underlying claims based on information and/or documents proving the official relationship between the trader and the brand owner, manufacturer, distributor, and/or official agent;
• Apply clear and transparent criteria and classification of labels or information; and
• Maintain proper documentation (Article 16).

This is a clear move to prevent misleading representations in online marketplaces.

7. Focus on Fair Competition

The regulation directly addresses unfair pricing strategies.

Platforms must play an active role in:

• Providing equal business opportunities for traders; and
• Maintaining prices of goods and/or services free from price manipulation practices, both directly and indirectly.

Price manipulation practices shall include:

• Selling below reasonable cost on a sustained basis;
• Repeated, unjustified subsidies;
• Pricing tactics that distort the market; and
• Other practices in accordance with the provisions of laws and regulations on the prohibition of monopolistic practices and unfair business competition. (Article 18(2)).

Platforms are expected to actively monitor and prevent these practices, and coordinate with competition authorities where necessary (Article 18(3)–(6)).

8. Cross-Border Presence Requirement and E-Commerce

Another critical but often overlooked provision is the requirement for foreign platforms to establish a local presence in Indonesia.

• Foreign PPMSE that meet certain thresholds must appoint a representative in Indonesia (KP3A PMSE) (Article 22(1)).

These thresholds include:

• At least 1,000 transactions with Indonesian consumers in one year;
• At least 1,000 shipments to Indonesia; and/or
• Traffic reaching at least 1% of Indonesia’s total internet users (Article 22(2)).

The assessment is conducted by a government-appointed team involving relevant authorities (Article 22(3)).

In practice, this means that foreign platforms with meaningful economic activity in Indonesia can no longer operate purely offshore, they must establish a formal regulatory footprint in the country.

Thus, one of the most talked-about changes is the introduction of a minimum goods price threshold:

• Imported finished goods sold through cross-border e-commerce must have a minimum value of USD 100 per unit freight on board (FOB) (Article 23(2)).

This is clearly aimed at:

• Protecting local MSMEs;
• Preventing unfair pricing practices; and
• Creating a more level playing field.

9. Social Commerce Is Further Restricted

Permendag 19/2026 continues Indonesia’s cautious approach to social commerce:

• Social commerce platforms are not allowed to process payments (Article 25(3));
• Marketplaces and social commerce platforms are prohibited from acting as producers (Article 25(2)).

This reinforces the separation between platform function and commercial activity.

10. Digital Advertising Must Be Responsible

The regulation also introduces clearer rules on electronic advertising. Advertisements must:

• Not mislead consumers;
• Provide accurate and complete information;
• Disclose risks; and
• Include an option to skip or close the ad (Article 32(1)).

Businesses remain fully responsible for the content of their ads (Article 31).

11. What Businesses Should Do Now

From a practical standpoint, companies should:

• Review whether their business licenses are complete and up to date;
• Check marketplace onboarding procedures;
• Ensure all products meet Indonesian regulatory standards;
• Revisit pricing strategies for cross-border transactions; and
• Update platform terms, complaint systems, and internal SOPs.

Conclusion

Permendag 19/2026 represents one of the most comprehensive updates to Indonesia’s e-commerce regulatory framework in recent years. It reflects the government’s intention to create a more balanced, fair, and accountable digital marketplace, while safeguarding domestic businesses and consumers.

For companies operating in or entering Indonesia, early compliance is not just advisable, it is essential.

If you need assistance with PMSE licensing, OSS registration, or regulatory compliance in Indonesia, CPT Corporate can support you end-to-end.