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A robust and effective competition law compliance programme is important for businesses to reduce the risk of competition breaches in the day-to-day activities of a company.
In Indonesia, the Indonesian Competition Commission (KPPU) takes compliance commitments one step further: in order to benefit from a reduction in penalty following a finding of infringement, a company must have registered its compliance programme with the KPPU.
Further information on the preparation and registration of compliance programmes can be found in KPPU Regulation No. 1 of 2022 on Business Competition Compliance Programmes (Compliance Programmes) (KPPU Reg 1/2022).
We summarise the key points and recent developments below.
Increased enforcement by KPPU
The KPPU's renewed emphasis on competition law compliance in the past year reflects a broader intensification of enforcement activity and a shift in strategic focus. In 2025, the KPPU concluded a higher number of cases than in prior years, issuing 13 final decisions involving 24 businesses. Enforcement was directed at complex and high‑impact matters, and involved late merger filing notifications, bid‑rigging in public procurement, and abuse of dominant positions, including in digital markets, infrastructure, and distribution chains.
This renewed emphasis on registering Compliance Programmes is tied to the higher fines imposed by the KPPU in recent cases. In 2025, the KPPU imposed total fines of 698.5 billion rupiah (US$41 million) for competition law violations – a significant increase on the total fines imposed in 2024 (56.5 billion rupiah, or US$3.35 million).
A registered Compliance Programme allows businesses to benefit from a reduction in the fine ultimately imposed by the KPPU. Another benefit of a registered Compliance Programme is participation in the KPPU's behavioural commitment programme. Under this programme, which operates at an earlier stage of the enforcement process, companies that are subject to an ongoing KPPU investigation may propose behavioural commitments aimed at addressing and correcting the conduct under investigation. If the KPPU accepts these commitments, and the company implements them, the investigation may be terminated early, without a finding of violation or the imposition of a fine. Importantly, participation in the behavioural commitment programme is conditional upon the company first having a registered Compliance Programme.
Compliance Programme rollout
While the Compliance Programme remains voluntary, implementation and registration is being encouraged by the KPPU through various incentives. Sixty business actors registered for the KPPU Compliance Programme in 2025. Of those, 25 have received a determination from the KPPU.
Preparing and registering Compliance Programmes
KPPU Reg 1/2022 sets out several steps that businesses should take to prepare their Compliance Programmes:
- Compliance Programme registration. This is done by submitting a registration letter to the KPPU Chair.
- Compliance Programme formulation. The Compliance Programme should include a code of ethics and compliance guidelines, and set out how the company will use socialisation, counselling, training and other activities to implement the Compliance Programme. The Compliance Programme formulation can be bespoke and developed in line with the needs of the business, taking into account the relevant industry, market structure, and interactions with suppliers, competitors and consumers.
- Report to KPPU on Compliance Programme. Implementation of the Compliance Programme should be documented in a report using the format provided by the KPPU.
- Evaluation of Compliance Programme. The Compliance Programme will be evaluated by the KPPU at a hearing held within 15 to 30 working days following submission of the report.
- Compliance Programme determination. Following the hearing, the KPPU will issue a determination in relation to the Compliance Programme which, if positive, will be valid for five years initially (and can be extended).
- Programme improvements. The KPPU's report on the Compliance Programme may include instructions for improvement, if the KPPU considers this necessary.
Key takeaways
While a Compliance Programme is not mandatory in Indonesia, it is recommended as part of good corporate governance.
A robust and effective Compliance Programme should be seen as a strategic investment for companies to minimise the risk of legal violations and regulatory/financial risks. Its importance should also be regularly emphasised by senior management to ensure that there is an overall compliance culture within the business.
Beyond risk mitigation, an effective Compliance Programme also creates long-term operational benefits as it helps to improve transparency, strengthen internal controls, and build long-term relationships with customers and investors.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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