Indonesia’s regulation on reporting online intellectual property (IP) infringement provides comprehensive procedural guidance for IP rights holders and their licensees in reporting online infringement complaints. Issued in December 2025 by the Ministry of Law as Regulation No. 47 of 2025 regarding Handling of Intellectual Property Infringement Reports in Electronic Systems, this regulation covers all types of IP rights. It also specifies documentation when reporting infringement, and lays out the procedures for examination, verification, and enforcement actions. Submission of Complaints Complainants may submit reports through the online system of the Directorate General of Intellectual Property (DGIP) or in person at the DGIP office. Complaints may also be filed through an authorized proxy. Under the regulation, complainants are required to provide the following information and documents: Personal details of the complainant; Brief description of the protected work or subject matter (i.e., type of IP and name or address of the infringing website, portal, account, or application, or a link to the location of the infringing content); Complete description of the alleged infringement; Certificate of registration or recordal of the relevant IP; Recordal of IP license agreement, if any; and Other supporting evidence. Verification and Examination Process Upon receiving a complaint, the responsible formality officer may request clarification or additional supporting documents. In the latter case, the complainant must then submit the necessary administrative documents within 14 days of the notification date. Once the documentation is deemed complete and sufficient, the case will be formally registered. Subsequently, the DGIP will establish a verification team to handle online IP violations, which will include the Civil Servant Investigator (PPNS), the Ministry of Communication and Digital Affairs, experts with relevant expertise in IP, and representatives from related associations such as AVISI (Indonesian Video Streaming Association). After examining the report, the team will prepare the Minutes

The Madrid System for international trademark registration provides the opportunity for a simplified and cost-effective way to register trademarks in multiple countries through a single application. Indonesia joined the Madrid System in 2018, and in 2024 alone, it received over 8,600 applications through this system. Despite the system’s effectiveness, it is important for trademark owners to be aware of the potential risks of refusal that can arise during the process of registration. Trademark applicants must pay close attention to these critical points when designating Indonesia. Appointing a Local Representative to Respond An applicant or representative of an international registration (IR) application that has been provisionally refused must appoint a local Indonesian representative in order to submit a response to the provisional refusal. This appointment is solely for the purpose of responding to the refusal in Indonesia; it is not necessary if the IR has not received any rejection. Furthermore, the local representative should not be registered with WIPO, as doing so would affect representation across all designated countries. Timing When it comes to calculating the deadline for responding to a provisional refusal, there is a discrepancy between the methods used by the DGIP and WIPO. Under the Indonesian Trademark Law, trademark owners can file a response within 30 working days, excluding weekends and national holidays. However, the WIPO cover letter accompanying the DGIP’s provisional refusal notice specifies both the start date and the deadline for responding to the notification, which is calculated as 30 calendar days, including weekends and national holidays. Therefore, a response to the provisional refusal of IR should be submitted in accordance with the WIPO cover letter to prevent any formality issue. Grounds for Refusal After an IR application is published in Indonesia’s Trademark Gazette, it undergoes substantive examination by the Directorate General of Intellectual Property (DGIP) examiners. The

Indonesia enacted a new franchise regulation, Government Regulation No. 35 of 2024 on Franchising (“GR 35/2024”), on September 2, 2024. Franchising in Indonesia was previously governed by Government Regulation No. 42 of 2007 on Franchising (“GR 42/2007”), along with an implementing regulation, Ministry of Trade Regulation No. 71 of 2019 regarding Implementation of Franchising (“MOT Regulation 71/2019”). This new regulation repeals GR 42/2007. However, MOT Regulation No. 71/2019 remains in effect until a new MOT regulation can be enacted. The new franchise regulation contains several amendments and provides more detailed requirements to complement MOT Regulation No. 71/2019. Comparison of GR 35/2024 to GR 42/2007 Minimum years of business operation. The new regulation reduces the minimum duration that a franchise registration applicant must have been operating from five years to three years. Intellectual property (IP) status. Any relevant IP must now be registered before a franchise registration application can be submitted. This is a change from the previous regulations, under which it was possible to obtain a franchise registration (STPW) while an IP application was still pending, and if the IP application could not be registered, the STPW would be canceled. Registration requirements for foreign franchisors. Under the new regulation, foreign franchisors must provide a legalized or apostilled business permit document from the country of origin in addition to the previously required franchise offering prospectus and statement letter from the relevant Indonesian authority. Administrative sanctions. The new regulation has adjusted the three escalating stages of administrative sanctions to (1) two warning letters, (2) a 14-day suspension from business activities, and (3) STPW revocation. This varies from the three stages under the previous regulation (three warning letters, fine, and STPW revocation). The new regulation also expands the list of noncompliant actions that are subject to these administrative sanctions. In addition to