However, while technical systems are advancing, governance and regulatory frameworks remain underdeveloped. Uptake is hampered by inconsistent legal mandates, budgetary misalignment, and capacity gaps among frontline workers. Indonesia’s digital health governance is hindered by gaps between high-level laws (e.g., Health Law 17/2023, Personal Data Protection Law 27/2022) and the absence of detailed operational regulations that define how data should be governed across ministries and sectors. Ministerial-level regulations (Permenkes) are insufficient to enforce interoperability mandates, data rights protections, or cross-sector collaboration—particularly involving actors such as BPJS Kesehatan, Bappenas, and the Ministry of Home Affairs.
To contribute to strengthening the digital health governance by supporting development of a coordinated governance architecture for health data in collaboration with the Ministry of Health.
To support the Ministry of Health to adopt evidence-based and more coordinated investment decision making for digital health.
To enhance digital health competency among Primary Health Care workforce in collaboration with the Ministry of Health.
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.