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Indonesia Action Plan Review 2020-2022

This product consists of an IRM review of Indonesia’s 2020–2022 action plan. The action plan is made up of 24 commitments that the IRM has filtered and clustered into 14. This review analyzes the strength of the action plan to contribute to implementation and results. For the commitment-by-commitment data, see Annex 1. For details regarding the methodology and indicators used by the IRM for this action plan review, see Section III: Methodology and IRM Indicators.

Overview of Indonesia’s 2020–2022 Action Plan


Participating since: 2011

Action plan under review: 2020–2022

IRM product: Action plan review

Number of commitments: 24

Overview of commitments:

  • Commitments with an open gov. lens: 24 (100%)
  • Commitments with substantial potential for results: 4 (17%)
  • Promising commitments: 4 (17%)

Policy areas carried over from previous action plans:

  • Open parliament
  • Access to justice
  • Beneficial ownership transparency
  • Open contracting
  • Budget transparency

Emerging policy areas:

  • Civic space
  • Social accountability
  • Inclusion of marginalized people

Compliance with OGP minimum requirements for co-creation:

  • Acted contrary to OGP process: No

* For commitments that are clustered, the IRM assessed potential for results at the cluster level, rather than the individual commitments.

If fully implemented, Indonesia’s sixth action plan could better coordinate provision of social welfare, publish information on beneficial ownership, and increase transparency on public procurement and COVID-19 spending. Commitments with more concrete and ambitious targets would strengthen the plan’s impact. Implementation will require greater political commitment within implementing agencies, mechanisms for beneficiary engagement, and regular communication with civil society.

Indonesia joined the OGP as a founding member in 2011. This report evaluates the design of Indonesia’s sixth action plan.

This action plan consists of 24 commitments, 20 of which continue from the previous action plan. The commitments are closely aligned with the policy priorities of Indonesia’s 2020–2024 Medium-Term National Development Plan (RPJMN), as well as the Sustainable Development Goals (SDGs). Most commitments carry forward initiatives from the previous action plan, including open parliament, access to justice, and access to election data. The action plan also builds on past commitments on beneficial ownership transparency, open contracting, and budget transparency. Additionally, it continues to address public service complaint resolution, access to social welfare data, participatory village governance, access to online health services portals, and One Data Indonesia. The action plan introduces new policy areas, such as a cross-cutting focus on improving public service provision for marginalized populations, as well as new commitments on protecting civic space and implementing social accountability measures at the local level. To aid clarity and assessment, this report clusters commitments relating to judicial access (6–10), community development (4 and 12) and open parliament (19–24).

Indonesia’s action plan was developed in two separate parts. Commitments 1–18 were directly proposed by civil society, often many organizations acting together, and developed through a collaborative co-creation process. Compared to previous plans, there was increased engagement from groups working on women’s rights and legal aid, including civil society organizations from Papua, Aceh, and Bandung. While the secretariat provided informal feedback to CSOs on the seven suggested commitments that were not included in the action plan, in the future, it could document this feedback to fully meet the OGP Participation and Co-creation Standards. The open parliament commitments (19–24) were developed through a separate process at the House of Representatives, which expanded civil society participation compared to the previous plan but did not include parliamentarians’ participation. According to Open Government Indonesia and Open Parliament Indonesia, differences in regulations, budgets, and priorities pose challenges to an integrated co-creation process. However, if future commitments are to be presented in a unified plan, greater coordination between government and parliament would be beneficial. Overall, there is also need for expanded participation from parliamentarians, high-level government ministry stakeholders, and civil society organizations in the co-creation process, and for increased civil society participation within the multistakeholder steering committee.

The action plan includes several promising commitments, although fewer than the previous plan. Commitment 1 would strengthen the transparency of public procurement, particularly during states of emergency like COVID-19. Commitments to integrate social welfare data into the Social Welfare Information System–Next Generation (SIKS-NG) online platform (Commitment 11) and to open public online access to COVID-19 budget information (Commitment 15) also have substantial potential for results. Additionally, Commitment 17 would open public access to the national beneficial ownership registry.[1] This commitment also responds to IRM recommendations in the previous design report. These promising commitments are examined in the next section (II).

The plan includes a positive continued effort to address shortcomings in legal aid provision (Commitments 6–10), with a valuable, cross-cutting focus on judicial access for women, disabled people, and other vulnerable populations. The commitments directly respond to an IRM recommendation in the previous design report to create an online platform where citizens can access information on legal aid (Commitment 7). Commitment 8 will improve the quantity, geographic distribution, and quality of legal aid services. However, the commitments do not specify numeric targets, nor financial and other resources to be made available, leaving ambiguity in their potential scope. Meanwhile, the commitments to assess judicial access do not include milestones to implement the assessments’ recommendations. Implementing this cluster of commitments should prioritize tangibly increasing the number of legal aid organizations and paralegals, particularly in underserved regions, and strengthening legal aid efforts on access to information. This cluster will require a parallel increase in the budget for legal aid reimbursement.

This plan also continues a positive effort to open the parliamentary process (Commitments 19–24). Namely, commitments that intend to institutionalize open parliament (Commitment 24) and to institute multistakeholder forums between parliamentarians and the public on substantive parliamentary information disclosure and transparency polices (Commitment 22) are constructive steps toward parliamentary openness. However, most of the commitments from the parliament are internally focused and limited in scope. They involve creation or updates of parliamentary websites and applications without sufficient mechanisms to ensure public participation. For example, Commitment 19 includes a milestone adding a public participation channel to the Legislative Information System (SILEG), but does not address the fact that the legislative information on SILEG is frequently outdated, particularly on controversial bills, which has limited user uptake.[2] Open-parliament commitments on digitization and reiteration of parliamentary online platforms may overlook the lack of political commitment from parliamentarians to meaningfully open up the legislative process and create more substantive pathways to citizen engagement, particularly on critical pieces of legislation. Future commitments could update parliamentary information-disclosure regulation; establish a fixed timeline for public disclosure of information on legislative plans, drafts, debates, passage, and evaluation; and systematize citizen feedback on the parliamentary legislative process.

Additionally, the plan offers incremental progress on the critical area of protecting civic space (Commitments 16 and 18). Given that civic space in Indonesia is categorized as “obstructed,”[3] the previous IRM design report recommended commitments responding to shrinking civic space. However, this plan’s commitments do not offer sufficient measures to address this issue in a meaningful and comprehensive way. For example, although Commitment 18 would research the rights to information, expression, and assembly, it lacks milestones to implement the resulting recommendations. Future plans could offer a platform for both government and civil society leaders to safeguard civic space more ambitiously.

Overall, despite a diverse thematic focus, most commitments are too weak to generate substantial impact. Several commitments that develop assessments and policies lack enforcement mechanisms, such as Commitments 6, 10, and 18. Additionally, like Commitment 19, some commitments do not provide for sufficient engagement with beneficiaries. Other commitments introduce measures in nationally relevant policy areas, but do not set ambitious targets in terms of scope. For instance, social accountability at the local level could target a higher percentage of Indonesia’s villages in future action plans (Commitment 12). For commitments without clear targets, Open Government Indonesia and implementing agencies could work with stakeholders to concretize milestones and indicators.

Given frequent turnover in implementing agencies, civil society stakeholders expressed concern about government commitment to implementation. When faced with personnel changes, these agencies could improve the handover process to support preservation of institutional memory and ensure the new staff’s commitment to implement the action plan. The implementing agencies could also strengthen communication and collaboration channels between government and civil society through regularly scheduled meetings.

Promising Commitments in Indonesia’s 2020–2022 Action Plan

The following review looks at the four commitments that the IRM identified as having the potential to realize the most promising results. This review will inform the IRM’s research approach to assess implementation in the results report. The IRM results report will build on the early identification of potential results from this review to contrast with the outcomes at the end of the action plan’s implementation period. This review also analyses challenges, opportunities, and recommendations for the learning and implementation process of this action plan.

Table 1. Promising commitments

Promising Commitments
1. Open Contracting in Government Procurement: This commitment would open public access to previously inaccessible procurement information by revising the Information Commission Regulation on Public Information Service Standards and publishing emergency procurement information on the national procurement portal. Strengthening public procurement transparency could contribute to anticorruption efforts.
11. Integrating Welfare Data: This commitment would unify fragmented information on social welfare provision by expanding the SIKS-NG platform to integrate data from major social welfare programs. This could allow for analysis of gaps in social welfare provision and facilitate beneficiaries’ ability to establish their eligibility.
15. Information Portal on COVID-19 Response and Recovery Budget: This commitment would offer public access to COVID-19 spending information, to be published on the Ministry of Finance’s online portal. Given the size of this budget, meaningful disclosure of information could reduce risk of corruption.
17. Utilization of Beneficial Ownership Data: This commitment would provide public access to the online beneficial ownership database (which covers the extractives sector) established under the previous action plan. It would also increase the number of corporations disclosing beneficial ownership.

[1] Beneficial owners are widely defined as those who ultimately control a corporate entity, even though they are not necessarily recorded as the legal owners of the company.

[2] Ravio Patra and Agus Wijayanto (Westminster Foundation for Democracy), interviews by IRM researcher, 2 Mar. 2021 and 11 Apr. 2021.

[3] Civicus, “Critical Voices Silenced, Impunity for Excessive Force And Unlawful Killings in Indonesia” (2 Jan. 2021),


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