On May 20, 2026, the Southeast Asia Freedom of Expression Network (SAFEnet) and Indonesia's National Commission on Disabilities (Komisi Nasional Disabilitas, KND) signed a memorandum of understanding to jointly advocate for digital accessibility policy, build referral pathways through KND's DiTA 143 contact center, and expand digital-security training for disabled internet users (SAFEnet). The MOU itself is unremarkable institutional housekeeping. What it surfaced is not: SAFEnet's own research found that most Indonesian public-service websites fail to meet WCAG 2.1 Level AA, the international baseline for accessible design, and KND used the signing to publicly flag that the ministerial regulation meant to fix this — Komdigi's draft rule on disability-friendly public communication and information services (KIP) — has sat unratified for roughly three years.
A Genuinely Hard Drafting Problem
Before arguing Komdigi dragged its feet, it's worth taking the delay seriously. The draft regulation (Rancangan Peraturan Menteri on Layanan Komunikasi dan Informasi Publik Digital, or RPM LKIPD) implements Government Regulation No. 70/2019 and Law No. 8/2016 on Persons with Disabilities, and Komdigi says work has proceeded in stages since 2022 — feasibility studies, service-guideline development, technical training, and accessibility-feature pilots (Liputan6). That is a real workload. Indonesia has no single central web platform to retrofit; public-service digital presence spans thousands of ministries, provinces, regencies, and state agencies, each with its own procurement cycle, legacy CMS, and IT budget. A national accessibility mandate imposed without technical guidance or transition time risks producing exactly the kind of box-ticking compliance — an alt-text field nobody fills in correctly — that helps no one. Building the guidance layer first is a defensible instinct, and Komdigi's own account shows real technical work, not just delay.
But Three Years Without a Deadline Is Not Caution — It's Drift
The problem is that none of that preparatory work has produced an actual binding rule, and nothing forces it to. Indonesia's Coordinating Ministry for Political, Legal, and Security Affairs (Kemenko Polkam) convened an interagency meeting on June 25, 2026 specifically to "accelerate" the regulation — itself a signal that after roughly three years of drafting, the file still needs a push from outside Komdigi to move (Berita Nasional). That is the pattern of an open-ended technical-committee process, not a regulation moving toward a defined finish line. Law No. 8/2016 already establishes the underlying right — Article 5 lists the right to expression, communication, and information access, and Article 24 specifies accessible-format formats including sign language and Braille for official interactions (UU No. 8/2016, JDIH USU). What's missing isn't the legal principle; it's a technical standard with teeth. A right without an enforceable implementing standard is advisory, and ten years after the law's passage, that gap is no longer a rounding error.
Adopt the Standard, Don't Reinvent It
The fastest, most proportionate fix is also the cheapest one: Komdigi doesn't need to author a bespoke Indonesian accessibility standard from scratch. WCAG 2.1 AA and its ISO equivalent, ISO/IEC 40500, are mature, widely adopted, and already the reference point cited in Komdigi's own draft. Adopting them by direct reference — rather than continuing to develop parallel "digital accessibility guidelines" — would let the ministry skip years of further technical study and move straight to a phased compliance timeline with a real enforcement date. This isn't a hypothetical failure mode: the WebAIM Million 2026 study found 95.9% of the world's top home pages still fail basic WCAG checks even in jurisdictions with mandatory accessibility law, showing that adoption alone doesn't guarantee compliance and that regulators should build enforcement and monitoring into the rule from day one, not bolt it on later (WebAIM 2026 findings via Change in Content).
The Regional Comparison Isn't Flattering
Indonesia currently ranks 66th of 120 countries on the Inclusive Internet Index, a result researchers directly tie to the absence of a binding domestic accessibility standard despite Law No. 8/2016 predating that ranking by nearly a decade (Adliya Journal, UIN Sunan Gunung Djati). That ranking is a symptom of the same gap SAFEnet and KND are now pointing at: a country with the legal architecture for digital-accessibility rights but no ratified technical rule compelling public agencies to build to it.
What Should Happen Next
The SAFEnet-KND MOU is a useful advocacy vehicle, but MOUs don't ratify regulations. The proportionate path forward is narrow and specific: Komdigi should convert the RPM LKIPD's existing technical work into a final rule that formally adopts WCAG 2.1 AA / ISO 40500 by reference, sets a realistic multi-year compliance runway for lower-capacity regional agencies, and assigns a named enforcement body — rather than leaving accessibility as a set of internal guidelines with no legal force. Kemenko Polkam's June intervention shows the political will exists to finish this. What's needed now is a ratification date, not another study.