Learn from Digital Markets Act European Union dNature Planning Digital Governance in the Context of National Political Economy

Author: Hosea Immanuel Latumahina
Editor: Achmed Faiz Siregar
Over the past decade, Indonesia’s digital economy has experienced rapid growth and is projected to become a major driver of national economic growth. Temasek (2023) projects that Indonesia’s digital economy will reach over USD 200 billion by 2030, with e-commerce the largest contributor to the value of the digital economy.[1]On an ASEAN regional scale, Indonesia also generates growth in digital economic value through e-commerce, with a value Gross Merchandise Value(GMV) of US$65 billion in 2024 and growing by 14% to US$71 billion in 2025.[2]This growth not only makes digital platforms a strategic digital economic architecture, but also positions Indonesia as the epicenter of the digital economy in ASEAN.
Although e-commerce Indonesia is experiencing very rapid growth, this growth has also given rise to crucial issues, namely that the Indonesian digital market is still concentrated in a handful of large platforms and large business players who dominate the digital market through data, user networks, and an integrated transaction ecosystem.[3][4]The dominance of the digital market by a handful of actors has the potential to lead to behavior that abuses dominant positions, such as limiting the power of competitors, controlling the behavior of business partners, and manipulating the ecosystem and digital market algorithms.[5][6]
Current Dynamics of the Digital Economy
The development of Indonesia’s digital market is characterized by high internet penetration, a large user base, and the increasing adoption of platform-based services. From a user perspective, a study by CELIOS (2025) shows that 17% of Indonesia’s 181.9 million internet users actively conduct online transactions through e-commerce, and experienced an average increase of 15% per year.[7][8]Then from the sideplatform, based on data fromTech in Asia (2024), there are 164 startup e-commerce operating in Indonesia, with 15 of them being large platforms, including Lazada, Tokopedia, and Shopee.[9]Although the number of digital platforms is relatively large, the digital market has characteristic economies of scale, network effects, and data superiority that drives market concentration and shapes low barrier entry.[10] As a result, most of the economic value of digital markets tends to be concentrated in the hands of a few dominant actors.[11]
Data by Kurniawan (2025) reveals that the markete-commerceIndonesia is still dominated by several platforms, such as: 1) Shopee, which is able to achieve a GMV value of US$100 billion, sales of local products up to 200% in 2024, and dominates the number of visitors as much as 98.3 million in February 2025; 2) Tokopedia, which achieved sales results of Rp5.2 trillion in 2024; 3) Lazada, which earned net revenue of US$151.4 million in 2024, and; 4) Blibli, which earned net revenue of Rp16.71 trillion and gross profit of Rp3.29 trillion in 2024.[12][13]A study by INDEF (2024) also shows that the use ofe-commerceIn Indonesia, it is still dominated by Medium and Large Enterprises (UMB) with 69% sales activity and 55% purchasing activity.[14]
Concentrated digital markets have the potential to pose various serious risks and challenges to business competition. Dewi et al. (2025) show that marketplace platforms dominant in Indonesia has great potential to abuse its dominant position for economic interests (abuse of market power), either through price discrimination practices and control of market information, manipulation of algorithms and search preferences (self-preferencing), to strategybundling And cross-subsidization, namely the involvement of business units in one sector to expand their dominance in other sectors.[15]
For example, at the global level, the European Commission fined Google for manipulating Google’s search engine algorithm to prioritize its own commercial services,Google Shopping, in search results. Additionally, in Indonesia, the Indonesian Business Competition Supervisory Commission (KPPU) also sued Google and fined it for implementing a policy requiring apps downloaded fromGoogle Play Store to use Google’s payment platform,Google Play BillingThis limits the choice of payment methods available through other platforms.
Unfortunately, practices of abusing dominant positions in the digital market are still difficult to address using a competition law approach that focuses on conventional market structures and mechanisms. Law No. 5 of 1999 on the Prohibition of Monopolistic Practices and Unfair Business Competition, which is the framework and legal basis for business competition, is still limited to conventional markets.Khan (2017), through the conceptAmazon’s Antitrust Paradox, revealing that the approachantitrust Traditional approaches focused on consumer prices are no longer adequate to calculate the market power of digital platforms driven by data and vertical integration.[16] Jean Tirole (2020) also emphasized that the characteristics of competition in the digital market are no longer focused on physical market control, but domination through algorithmic and data control.[17]
In addition to still being oriented towards conventional market competition, the legal framework for business competition in Indonesia is also still reactive, where intervention is only carried out after market losses can be proven.[18]As in the case of a lawsuit antitrust The KPPU previously imposed a fine on Google LLC, where the KPPU only imposed a fine after conducting an investigation and calculating losses, instead of anticipating it with a relevant and contextual regulatory framework.[19]However, in a fast-moving and large-scale digital market, a reactive approach is often too late.
According to UNCTAD (2021), the delay in government intervention in regulated markets can reduce market structures to become uncompetitive.[20] This implication is due to the reactive nature of government intervention, which results in dominant platforms being at risk of implementing these practices first.abuse of market power through its dominant position. This makes market competition less competitive and market access more limited, especially for smaller platforms and businesses.
Digital Markets ActThe European Union as a Policy Reference
Responding to the limitations of the digital market, the European Union has already designed and launchedDigital Markets Act (DMA) as a regulatory instrument that specifically targets digital platforms that act as gatekeepers.[21] In DMA, gatekeepers are defined as a large digital platform that provides basic services such as search engines, application distribution, instant messaging and social media. The large platforms identified asgatekeepersThis is mandatory to comply with the obligations (do’s) and limitations (don’ts) contained in the DMA, which was established from the beginning to ensure a fair, open, and free digital market, non-monopolistic business competition practices.[22]
The DMA is built on a thorough evaluation of the limitations of traditional competition law.[23]This approach marks a paradigm shift from reactive law enforcement to preventative structural regulation, particularly against platforms with systemic market power.Competition Policy for the Digital Eraby Crémer, de Montjoye, and Schweitzer (2019) is one of the foundations of DMA which emphasizes the need for a preventative approach to data-driven market power and user networks.[24]
For Indonesia, the DMA offers a relevant regulatory and policy framework, particularly in addressing the issue of platform dominance. However, according to Bradford (2023), European digital regulations interpret specific institutional, economic, and political contexts that cannot be directly transplanted to other countries.[25]
Could Indonesia Adopt DMA?.
Although DMA offers policy alternatives with more adaptive, anticipatory and holistic schemes and mechanisms, its adoptionDMAIn Indonesia, it cannot be implemented in a binary manner. The main challenge to DMA adoption lies in the digital market landscape, which still relies on services provided by large platforms, which is a problematic issue. Based on data from the Central Statistics Agency (BPS) (2025), business sales media and e-commerce still concentrated on instant messaging platform (94.7%), social media (29.66%), andmarketplace(17.23%), the majority of whom are associated or affiliated with big companies platform.[26]
Process policy implementation without policy transfer contextual ones risk producing ineffective symbolic regulation.[27]Therefore, adoptionDMAin Indonesia it is necessary to ensure that key principles, such as oversight, are mainstreamed.gatekeeper, algorithm transparency, and self-preferencing, gradually integrated into the national legal framework, including competition law and digital sector regulations. This concept is also in line with CSIS Indonesia’s analysis (2023) which shows that the adoption of European digital regulations such asDigital Services Act(DSA) must take into account the national political, social and institutional context so as not to give rise toover-regulation.[28]
Conclusion
The dominance of digital platforms in Indonesia is a structural problem that cannot be fully addressed through conventional, reactive business competition approaches. European Union Digital Markets Act (DMA) offers a preventively oriented framework, which is relevant as a policy reference, but not as a model that can be adopted outright.
For Indonesia, the challenge is not simply adopting and replicating the DMA, but rather contextualizing digital platform governance that is adaptive and relevant to the goals of national digital economic development and the safety of its users. Without a selective and contextual approach, DMA adoption risks becoming a normative solution that fails to address the real issues facing Indonesia’s digital market.

  1. Google, Temasek and Bain & Company, 2023. e-Conomy SEA 2023. Singapore: Bain & Company. ↑
  2. Huda, N., Ayu, D., Septyarini, R., 2024. Digital Economy Outlook 2025. CELIOS. Available at:https://celios.co.id/digital-economy-outlook-2025/ ↑
  3. Kurniawan, Ivan., 2025. The Progress of E-commerce in Indonesia: Statistical Data and Popular Platforms. Dewatalks Blog. Available at:https://www.dewatalks.com/blog/data-pengguna-ecommerce-di-indonesia/#Data_Statistik_Perkembangan_E-commerce_di_Indonesia ↑
  4. Rachbini, E, M., 2024. Evaluation and Perspective of the Indonesian Economy: Development of the Digital Economy. INDEF. Available at:https://indef.or.id/wp-content/uploads/2024/01/Sektor-Ekonomi-Digital.pdf ↑
  5. Dewi, R., Andriani, R., Gunawan, J., Salamatuddaroen, S.N. and Indriarti, J., 2025. Abuse of dominant position by digital marketplace companies in Indonesia. RIO Law Journal, 6(2), pp.1168–1181. ↑
  6. Ibid. ↑
  7. Huda, N., Ayu, D., Septyarini, R., 2024. Digital Economy Outlook 2025. CELIOS. Available at:https://celios.co.id/digital-economy-outlook-2025/ ↑
  8. Central Bureau of Statistics., 2023. National Socio-Economic Survey 2023. BPS. Available at:https://silastik.bps.go.id/v3/index.php/mikrodata/detail/U1BGcE5sYzFvamI2SGw0YmVUYUlDZz09 ↑
  9. Putri, K, U, J., 2025. [Update] Indonesian e-commerce data: a complete guide. Tech in Asia. Available at: https://id.techinasia.com/data-ecommerce-indonesia-panduan-lengkap ↑
  10. OECD, 2019. An introduction to online platforms and their role in the digital transformation. Paris: OECD Publishing. ↑
  11. OECD, 2022. Competition policy in the digital age. Paris: OECD Publishing. ↑
  12. Kurniawan, Ivan., 2025. The Progress of E-commerce in Indonesia: Statistical Data and Popular Platforms. Dewatalks Blog. Available at:https://www.dewatalks.com/blog/data-pengguna-ecommerce-di-indonesia/#Data_Statistik_Perkembangan_E-commerce_di_Indonesia ↑
  13. Putri, K, U, J., 2025. [Update] Data e-commerceIndonesia: The complete guide. Tech in Asia. Available at:https://id.techinasia.com/data-ecommerce-indonesia-panduan-lengkap ↑
  14. Rachbini, E, M., 2024. Evaluation and Perspective of the Indonesian Economy: Development of the Digital Economy. INDEF. Available at:https://indef.or.id/wp-content/uploads/2024/01/Sektor-Ekonomi-Digital.pdf ↑
  15. Dewi, R., Andriani, R., Gunawan, J., Salamatuddaroen, S.N. and Indriarti, J., 2025. Abuse of dominant position by digital marketplace companies in Indonesia. RIO Law Journal, 6(2), pp.1168–1181. ↑
  16. Khan, L.M., 2017. Amazon’s antitrust paradox. Yale Law Journal, 126(3), pp. 710–805. ↑
  17. Tirole, Jean., 2020.Competition and the Industrial Challenge for the Digital Age. Toulouse School of Economics. Available at:https://www.tse-fr.eu/sites/default/files/TSE/documents/doc/by/tirole/competition_and_the_industrial_challenge_april_3_2020.pdf ↑
  18. Business Competition Supervisory Commission (KPPU), 2025. Fair business competition, prosperous consumers, efficient and innovative economy. Jakarta: KPPU. Available at:https://kppu.go.id/wp-content/uploads/2025/12/Persaingan-Usaha-Sehat-Konsumen-Sejahtera-Ekonomi-Efisien-Inovatif-Optimized.pdf ↑
  19. Heriani, F, N., 2025. Knock! KPPU Imposes Rp202.5 Billion Fine on Google. Hukum Online. Available at:https://www.hukumonline.com/berita/a/tok-kppu-jatuhi-denda-rp202-5-miliar-kepada-google-lt679024db7982f/ ↑
  20. UNCTAD, 2021. Competition policy and consumer protection in the digital economy. Geneva: United Nations. ↑
  21. European Union, 2022. Regulation (EU) 2022/1925 on contestable and fair markets in the digital sector (Digital Markets Act). Official Journal of the European Union. ↑
  22. Ibid. ↑
  23. Ibid. ↑
  24. Crémer, J., de Montjoye, Y.-A. and Schweitzer, H., 2019.Competition policy for the digital era. Brussels: European Commission. ↑
  25. Bradford, A., 2023. Digital empires: The global battle to regulate technology. Oxford: Oxford University Press. ↑
  26. Central Bureau of Statistics., 2025. E-Commerce Statistics 2024 Vol. 7, 2025. BPS. Available at:https://www.bps.go.id/id/publication/2025/11/28/647323224ecc656c2933571b/statistik-e-commerce-2024.html ↑
  27. World Bank, 2020. Competition in the digital economy: An overview. Washington, DC: World Bank. ↑
  28. Centre for Strategic and International Studies (CSIS) Indonesia, 2023. Should Indonesia adopt the EU Digital Services Act to improve its content moderation policies?Available at:https://blog.csis.or.id/should-indonesia-adopt-eu-digital-services-act-to-improve-its-content-moderation-policies-e2db6ee5f968 ↑