
The figure or the record
Indonesia's Ministry of Communication and Informatics signed Ministerial Regulation No. 5 of 2020 on Private Scope Electronic System Operators on 16 November 2020; it was promulgated and took effect eight days later, on 24 November 2020. Article 2 requires every private-scope electronic system operator to register, and Article 4 extends that duty explicitly to an operator incorporated abroad if it offers a service inside Indonesia, does business there, or has a system used and/or accessed by Indonesian users, language that reaches a foreign short-drama app with no local office at all.
What the documents establish
The regulation's sanctions ladder is graduated and specific: Article 7 states that an operator that never registers faces administrative access blocking directly, while one that has registered but fails to update its filed information first receives a written warning, then a temporary suspension, then access blocking and revocation of its registration mark if it does not respond within seven days. A later amendment, Ministerial Regulation No. 10 of 2021, signed and effective 21 May 2021, changed the registration deadline to run from a different trigger: an operator must now register within six months of Indonesia's separate risk-based business licensing system becoming effective, rather than a fixed calendar date, because that system's own rollout had been delayed.
Scope and caveats
What these two Indonesian regulations establish is a registration-and-access-blocking regime, not a content-classification or age-rating system; they say nothing about episode pricing, coin mechanics or minors' viewing limits, only about whether the operator has registered and can therefore legally keep operating. This account could not open a comparable primary text for Vietnam within this session: the Authority of Broadcasting and Electronic Information's site was unreachable, and the Ministry of Information and Communications' own domain now redirects to Vietnam's restructured Ministry of Science and Technology, reflecting the 2025 government reorganisation that folded the former ministry into it. No claim about Vietnam's specific OTT licensing requirements is made here beyond that redirect, which this account did verify directly.
What to watch
Editorially, the point worth tracking is whether the six-month registration clock, now tied to the risk-based licensing system's effective date rather than a fixed date, has actually run out for a given operator, since a foreign app can be in technical breach of Article 2 well before any public blocking action makes that visible.
- Is the app registered on Indonesia's public electronic-system-operator list, which the regulation requires the ministry to publish on its own website?
- Has the six-month registration window under the 2021 amendment already closed for an operator that entered the market after the risk-based licensing system went live?
- What does Vietnam's own current licensing authority, under its reorganised ministry structure, actually require of a foreign OTT app, a question this record leaves open?
Indonesia's rule is unambiguous and enforceable by a blunt instrument, access blocking, and it reaches a foreign operator with no local presence at all; this account stops short of making the equivalent claim for Vietnam, because it could not open a Vietnamese primary source to support one.
Sources & reading trail
Registration duty (Article 2), its extension to foreign operators (Article 4), and the graduated access-blocking sanctions (Article 7), with adoption (16 Nov) and effective (24 Nov) dates.
Source published: 16 November 2020 · Retrieved: 16 September 2026
Amends the registration deadline to run from the risk-based business licensing system's own effective date rather than a fixed calendar date.
Source published: 21 May 2021 · Retrieved: 16 September 2026
Filings, releases and official documents establish the record; the scope reading and the questions are Vertical Ledger editorial analysis. This retrospective draft does not imply the site published on the event date.