Let’s be honest — Indonesia’s PDP Law is already in force, yet many organisations are still scrambling, delaying, or simply “nominating” someone as DPO just to appear compliant. This is happening even though the law is unambiguous: certain organisations must appoint a capable Data Protection Officer (DPO), not a symbolic one.

Under Article 53, the DPO requirement isn’t about filling a position. It’s about competence.
The law is explicit: a DPO must be appointed based on professionalism, legal understanding, knowledge of data-protection practices, and — most importantly — the capability to perform the role effectively. In short: the DPO must be qualified, not decorative.

And this is exactly where many organisations may be exposing themselves. Article 57 empowers regulators to issue administrative sanctions when a required DPO is not appointed — or when the appointment is essentially a nameplate role. Sanctions may include warnings, restrictions on processing, and eventually financial penalties once the implementing rules are finalised.

For organisations, the message could not be clearer:

If Article 53 applies, not appointing a DPO — or appointing an unqualified one — is already non-compliance.
A “name-only DPO” is a liability waiting to happen.
A capable DPO strengthens governance, reinforces trust, and reduces regulatory risk.

A DPO isn’t just a legal requirement. It’s not a checkbox. It is your organisation’s first line of defence — and a strategic advantage in the PDP Law era.