Decree of the Minister of Communication and Digital Affairs Number 197 of 2026 Tightens Radiation Testing and Certification for Mobile Phones and Tablets

Introduction

On April 22, 2026, the Minister of Communication and Digital Affairs (“MoCDA”) issued the Decree of the Minister of Communication and Digital Affairs Number 197 of 2026 on the Specific Absorption Rate Limits for Mobile Phone and Tablet Computer Telecommunication Devices (“MoCDA Decree 197/2026”). MoCDA Decree 197/2026 regulates the testing of telecommunication equipment and/or devices as well as the issuance of telecommunication device certificates to ensure compliance with radiation safety limits for mobile phone and tablet computer users in Indonesia.

The government issued MoCDA Decree 197/2026 to update the provisions on the Specific Absorption Rate (“SAR”) limits for mobile phones and tablet computers in accordance with international technical standards. MoCDA Decree 197/2026 also re-establishes the technical radiation requirements that must be met by every device before being traded in Indonesia.

Comparison

MoCDA Decree 197/2026 repeals and replaces the Decree of the Minister of Communication and Informatics Number 177 of 2024 on the Specific Absorption Rate Limits for Mobile Phone and Tablet Computer Telecommunication Devices (“MoCIT Decree 177/2024”). The following is a comparison of the provisions in MoCDA Decree 197/2026 and MoCIT Decree 177/2024:

Key Provisions

Obligation to Comply with SAR Exposure Limits

The FIRST Dictum requires every mobile phone and tablet computer to comply with SAR limits in the form of electric and magnetic field exposure. The radiation exposure levels of these devices must not exceed the following thresholds:

1. The head; and

2. The torso/body and limbs.

The FIRST Dictum also requires the use of the specific absorption rate testing method in accordance with the Annex of MoCDA Decree 197/2026.

International Standard References and Technical Limits

The SECOND Dictum requires compliance with SAR limits based on the standards issued by the International Commission on Non-Ionizing Radiation Protection (“ICNIRP”), namely the 1998 and 2020 versions. Annex Part A regulates the electric and magnetic field exposure limits based on radio frequency bands as follows:

1. Frequency bands up to 10 GHz use the ICNIRP (1998) guidelines;

2. Frequency bands from 100 kHz up to 300 GHz with an average interval of ≥ 6 minutes use the ICNIRP (2020) guidelines; and

3. Frequency bands from 100 kHz up to 300 GHz with an average interval of > 0 to < 6 minutes use the ICNIRP (2020) guidelines.

Devices Required to Comply with SAR Standards

The obligation to comply with these SAR standards applies to mobile phone and tablet computer devices with criteria as stipulated in the THIRD Dictum. This obligation applies to devices that:

1. Are used at a distance of less than 20 (twenty) cm from the human body; and

2. Have a radiated power of more than 20 (twenty) mW.

Exemption from SAR Testing for Tablet Computers

MoCDA Decree 197/2026 exempts the obligation to comply with the head SAR limits for tablet computers not designed for voice communication using a speaker placed next to the ear as stipulated in the FOURTH Dictum. Nevertheless, these tablet computers must still comply with the SAR limits for the torso/body and limbs.

Administrative Requirements for Tablet Computer Testing

Companies applying for an exemption from head SAR testing for tablet computers must fulfill the administrative requirements as stipulated in the FIFTH Dictum. In the testing application, companies must attach:

1. A statement letter that the tablet computer is not designed for voice communication using a speaker placed next to the ear; and

2. Device specifications demonstrating that the tablet computer is not designed for voice communication using a speaker placed next to the ear.

Device Certificate Application Requirements

Companies must attach the required documents when applying for a telecommunication device certificate as stipulated in the SIXTH Dictum. These documents include:

1. The specific absorption rate (SAR) test result report;

2. Other requirements in accordance with the provisions of laws and regulations; and

3. For tablet computers not designed for voice communication using a speaker placed next to the ear, the statement letter and device specifications as submitted during the testing phase.

Administrative Relaxation for Test Result Reports

Companies may still apply for a telecommunication device certificate if a domestic testing center has not yet issued the SAR test result report, as stipulated in the SEVENTH Dictum. In such conditions, companies may attach a certificate from a domestic testing center stating the planned issuance date of the SAR test result report.

Submission of Test Result Reports to Authorities

Certificate holders using a testing center certificate must submit the SAR test result report to the Director of Digital Infrastructure Services, Directorate General of Digital Infrastructure, as stipulated in the NINTH Dictum. The test result report must be submitted no later than 14 (fourteen) calendar days from the issuance date stated in the testing center certificate.

Device Retesting

Certificate holders may apply for retesting if the test result report indicates that the device does not comply with the SAR limits, as stipulated in the TENTH Dictum. Retesting may only be conducted a maximum of 1 (one) time, subject to the following provisions:

1. The retesting is conducted together with the Directorate General of Digital Infrastructure;

2. Device samples are purchased randomly from the market; and

3. The costs of retesting and purchasing device samples are borne by the certificate holder.

Determination of Retesting Procedures

The Director General of Digital Infrastructure is authorized to determine the procedures for submitting an application for telecommunication device retesting, as stipulated in the ELEVENTH Dictum. Companies applying for retesting must follow the administrative procedures set forth by the Director General of Digital Infrastructure.

SAR Testing Methods

Annex Part B regulates the internationally recognized testing methods used for SAR testing. For head testing, companies must use the IEC/IEEE 62209-1528 and EN 50360:2017 standards, or KDB document series such as 941225 D01/D05/D05A and 447498 D01. Meanwhile, testing for the torso/body and limbs uses the IEC/IEEE 62209-1528 and EN 50566:2017 standards, or relevant KDB documents.

Administrative Sanctions

MoCDA Decree 197/2026 regulates the imposition of administrative sanctions for devices that do not comply with the SAR limits, as stipulated in the TWELFTH Dictum. If the initial testing or retesting results indicate that the device does not comply with the SAR limits, the certificate holder is subject to an administrative sanction for non-compliance with the telecommunication equipment and/or device certificate in accordance with the provisions of laws and regulations.

Transitional Provisions

The use of a testing center certificate as a substitute for a SAR test result report is valid only until July 31, 2027, as stipulated in the EIGHTH Dictum. After this date, every telecommunication device certificate application must attach the SAR test result report.

Closing

MoCDA Decree 197/2026 updates the specific absorption rate (SAR) limit regulations for mobile phones and tablet computers through the implementation of the ICNIRP 1998 and ICNIRP 2020 international standards, as well as the use of testing methods that refer to international standards set forth in the Annex of MoCDA Decree 197/2026. The obligation to comply with the SAR limits applies to devices used at a distance of less than 20 (twenty) cm from the human body and that have a radiated power of more than 20 (twenty) mW, with exposure limits covering the head, torso/body, and limbs. MoCDA Decree 197/2026 also provides an exemption from compliance with the head SAR limits for tablet computers not designed for voice communication using a speaker placed next to the ear, with the obligation to attach a statement letter and device specifications during both the testing phase and the telecommunication device certificate application. Furthermore, companies may still use a certificate from a domestic testing center as a temporary substitute for the SAR test result report until July 31, 2027, with the obligation to submit the SAR test result report to the Director of Digital Infrastructure Services no later than 14 (fourteen) calendar days from the issuance date of the test result report. MoCDA Decree 197/2026 also limits device retesting to a maximum of 1 (one) time, which is conducted together with the Directorate General of Digital Infrastructure using device samples purchased randomly from the market, with all costs borne by the certificate holder. If the initial testing or retesting results indicate that the device does not comply with the SAR limits, the certificate holder is subject to an administrative sanction for non-compliance with the telecommunication equipment and/or device certificate in accordance with the provisions of laws and regulations.