Electronic System Operator Liability under Indonesia’s GR 71/2019: A Comparison with Singapore’s Cybersecurity Framework

Abstract

This article examines the effectiveness of Government Regulation No. 71 of 2019 in regulating the liability of Electronic System Operators in Indonesia, using Singapore’s cybersecurity framework as a comparative benchmark. The discussion is situated within increasing cybersecurity risks, data breach incidents, and the growing dependence of public and private services on electronic systems. This study contributes to Indonesian cyber law scholarship by positioning Indonesia as the main object of analysis while using Singapore’s Cybersecurity Act 2018 to identify lessons for regulatory improvement. Using a normative juridical approach and comparative legal method, the article analyzes statutory provisions, scholarly literature, and selected cyber incident reports. The findings show that GR 71/2019 provides an important foundation for operator responsibility by recognizing obligations related to system reliability, security, and accountability. However, compared with Singapore’s framework, Indonesia’s regulation remains limited in operationalizing liability through incident reporting, audits, risk assessments, supervisory coordination, and remedies. The article concludes that Indonesia needs a more precise, risk-based, and enforceable liability framework to strengthen cybersecurity governance and public trust.