From Age Limits to Accountable Design: A Risk-Based Framework to Protect Children on Social Media in Indonesia

Abstract

Children’s participation in social media creates opportunities for communication, learning, and self-expression, but it also exposes them to risks associated with unwanted contact, harmful content, exploitation, and extensive personal-data processing. This article examines whether Indonesia’s child-protection framework has translated general legal duties into workable governance standards for social media. It employs doctrinal legal research using statutory, conceptual, and comparative approaches. Primary legal materials include Law No. 35 of 2014 on amendments to the Child Protection Law, Law No. 1 of 2024 amending the Electronic Information and Transactions Law, Law No. 27 of 2022 on Personal Data Protection, Government Regulation No. 17 of 2025, and Minister of Communication and Digital Regulation No. 9 of 2026. Comparative materials include Australia’s Social Media Minimum Age framework and the United States’ Children’s Online Privacy Protection Rule. The analysis finds that Indonesia’s framework now contains a more developed regulatory basis for age assurance, risk assessment, platform duties, supervision, and sanctions. The central challenge is therefore not a complete absence of regulation, but the practical implementation of proportionate age assurance, feature-level risk controls, transparent compliance evidence, and accessible remedies. The article proposes an integrated model combining risk-based age assurance, privacy-by-design, auditable platform accountability, and education-based prevention. The model treats age limits as one component of a broader governance system rather than as a stand-alone solution.