Dinda Shabrina, Jakarta – The Southeast Asia Freedom of Expression Network (Safenet), a civil society organization advocating for digital rights, has warned that the new system from the Ministry of Communication and Digital (Komdigi), called the National Moderation and Complaint Administration System (SAMAN), has the potential to narrow civil space and encourage excessive censorship in the digital sphere in Indonesia.
Safenet Director Nenden Sekar Arum explained that SAMAN was introduced earlier this year as a derivative of the implementation of the Electronic Information and Transactions Law (ITE Law). She noted that the system is fundamentally an administrative tool owned by Komdigi, designed for two major functions: as a content moderation mechanism and an enforcement instrument.
However, she strongly criticized the regulatory design underpinning SAMAN's operation. According to Nenden, the government has failed to provide clear and measurable definitions regarding the categories of content that warrant a takedown.
"For example, they use vague phrases such as 'disturbing the public,' 'disrupting public order,' and other highly ambiguous indicators," she said when contacted on Friday, November 21, 2025.
The dual threat of ambiguity
These vague phrases, Nenden argued, create a wide space for interpretation for both the government and Komdigi, the body responsible for processing complaints from the public or state institutions.
According to Nenden, the ambiguity of these definitions poses a dual threat: one from the government and another from the digital platforms themselves. The threat of a fine of up to Rp500 million per content under the SAMAN scheme could make platforms overly cautious, leading them to excessively censor anything considered ambiguous.
"However, the content that is considered disturbing could be legitimate, a vital form of public aspiration," she stressed.
Furthermore, digital platforms may opt for voluntary self-censorship to pre-empt the risk of being warned or fined by Komdigi. "This is dangerous. In addition to government restrictions, platforms are also being forced to impose excessive restrictions," she asserted.
Call for clarity and public participation
Nenden emphasized that the trend of restricting expression has been visible even before SAMAN officially came into effect. Requests for content takedowns by Komdigi to digital platforms are already frequent, and with SAMAN, the process has the potential to become more automatic and massive. "We anticipate more frequent efforts to take down or requests to remove content from the government to digital platforms," Nenden added.
She assessed that this system has the potential to significantly narrow civil space, stifle criticism, and make the public's digital expression more vulnerable to censorship. Safenet, Nenden concluded, urges the government to clarify the definition of problematic content, open up public participation in the drafting of regulations, and ensure that the moderation mechanisms do not become a tool for controlling and suppressing freedom of expression.
Source: https://en.tempo.co/read/2067772/komdigis-saman-system-raises-concerns-over-freedom-of-expressio