The digital health landscape continues to be constrained by major systemic challenges. A review by the Ministry of Health found that over 400 siloed digital health applications—developed at various national and subnational levels—are still in operation despite the establishment of the SATUSEHAT platform, resulting in fragmented systems, duplicate investments, and data quality concerns. While Indonesia has enacted foundational legislation such as the Health Law (No. 17/2023), the Electronic Information and Transactions Law (No. 19/2016) (link), and the Personal Data Protection Law (No. 27/2022) (DLA Piper Summary), these do not yet translate into clear operational guidance for health data governance. Questions of data ownership, access protocols, and institutional accountability remain unresolved.

The urgency for a national Health Data Governance (HDG) framework is growing—particularly as sensitive personal health data requires heightened protection under Indonesian law. Inconsistent policies across ministries limit interoperability, while the lack of regulatory mandates undermines trust and risks data misuse. A further structural shift occurred in early 2024 when the Digital Transformation Office (DTO) was moved from the Ministry of Health to GovTech Indonesia at Peruri (Antara News, 2024). While this presented an opportunity for cross-sector harmonisation, it also introduced uncertainty around public health prioritisation, continuity of leadership, and the role of civil society in shaping Indonesia’s digital future.