AI Training and Copyright in Indonesia: What the Proposed Rules Could Mean for Businesses

Indonesia is proposing new Copyright rules that could require businesses to obtain licenses before using copyrighted works for commercial Artificial Intelligence (AI) training. The proposals also address transparency in training datasets and Copyright protection for AI-generated content.

On October 27, 2026, Indonesia’s Director General of Intellectual Property, Hermansyah Siregar, presented the government’s proposals in the Daftar Inventarisasi Masalah (DIM), or List of Issues, during discussions on the Draft Copyright Law.

The proposed provisions aim to balance technological innovation with the rights of creators and Copyright Holders.

  1. Commercial AI Training May Require Copyright Licensing

    One of the key proposals distinguishes between non-commercial scientific research and commercial activities involving copyrighted works.

    Under the proposed framework:
    • Non-Commercial Research: Text and data mining (TDM) conducted for non-commercial scientific research by researchers affiliated with universities or research institutions would not constitute Copyright infringement.
    • Commercial Activities: Commercial TDM, including AI model training, would require reasonable licensing arrangements, either individually or collectively through Collective Management Organizations (Lembaga Manajemen Kolektif or LMK).

      For businesses developing AI models, this could mean obtaining appropriate authorization before incorporating third-party copyrighted materials into commercial training datasets.

      The proposed licensing requirements could affect developers using books, articles, photographs, music, illustrations, and audiovisual works to train AI systems.

  2. Greater Transparency in AI Training Data

    The government has also proposed requiring AI developers to publish summaries of the data used to train their models. The objective is to provide greater transparency regarding copyrighted materials used in AI development and their sources.

    If enacted, this requirement could encourage businesses to strengthen their internal documentation of training datasets, including the origin of materials and applicable licensing arrangements. However, the detailed scope and implementation of these disclosure requirements have not yet been finalized.

  3. Will AI-Generated Works Receive Copyright Protection?

    Another important proposal concerns the authorship of AI-generated works. According to the government’s DIM, Copyright protection would require a qualifying human intellectual contribution.

    Works generated entirely by AI without human intellectual involvement are proposed to be excluded from Copyright protection. Meanwhile, works created with AI assistance may potentially qualify for protection where sufficient human creative contribution can be established.

    This distinction could affect businesses using generative AI for advertising materials, graphic designs, illustrations, audiovisual content, and other commercial assets. The proposals also address disclosure of AI use and restrictions on the imitation of expressive styles, although the precise scope of these provisions remains subject to legislative discussions.

  1. What Should Businesses Prepare?

    Although the proposed amendments have not yet become law, companies developing or commercially using AI should consider several preventive measures:
    • Review training datasets to identify copyrighted materials and their sources.
    • Examine licensing agreements to determine whether existing permissions cover AI training and other intended uses.
    • Document human creative contributions when developing copyrightable materials with AI assistance.
    • Monitor regulatory developments concerning licensing, dataset transparency, and authorship requirements.

For Copyright Owners, the proposed framework could also create additional opportunities to license their works for commercial AI development.

Universitas Hasanuddin has separately proposed that commercial AI training should require permission and remuneration, alongside data transparency and a mechanism allowing creators to refuse the use of their works.

Indonesia’s proposed Copyright Law amendments represent an important development in the relationship between AI innovation and intellectual property protection. If enacted, the proposed licensing and transparency requirements could affect how businesses develop AI models and manage copyrighted materials.

However, these provisions remain legislative proposals and are not yet legally binding. Businesses should continue complying with Indonesia’s existing Copyright Law while monitoring the progress of the proposed amendments.

Should you need more information about Copyright protection, licensing agreements, IP due diligence, or intellectual property matters related to AI-driven business activities in Indonesia, contact us through any of the following channels and get a FREE 15-minute consultation:

📩 E-Mail : [email protected]
📳 Book a Call : +62 21 83793812
💬 WhatsApp : +62 812 87000 889

Source: Directorate General Intellectual Property

About AFFA: 

Established in 1999, AFFA Intellectual Property Rights is an Indonesia-based boutique IP law firm serving international brands and innovators, offering full-service support—from prosecution and licensing to enforcement and commercialization—in Indonesia’s dynamic IP landscape. Our firm is widely recognized for its excellence, with accolades including “Best Boutique Law Firm in Indonesia” and “IP Enforcement Firm” at the Indonesia Law Firm Awards 2025 by Asia Business Law Journal, as well as being listed as a “Recommended Firm 2024 — Indonesia” by WTR 1000: The World’s Leading Trademark Professionals.

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