Summary

  • The law creates a choice among accumulation, extension, transfer, compensation, refunds or another safeguard. A notice alone does not show that any option preserves usable value.
  • Regulators can test a privacy-safe customer journey: clear terms, a remedy choice before expiry, a visible resulting balance, and a complaint path when records disagree.

A mobile-data balance is easy to show on a screen and harder to protect in practice. A customer may see gigabytes remaining, receive an expiry alert, and still have no clear way to keep using what has already been paid for. Indonesia’s recent legal change puts that distinction at the center of the service relationship: the balance must remain active and usable, and the customer must have a choice of service design.

On 23 July 2026, Indonesia’s Constitutional Court issued its decision in case 273/PUU-XXIII/2025. It conditionally interpreted the telecommunications tariff provision to require service options that keep a user’s remaining data active and usable. The Court did not prescribe one standard package or make rollover the only acceptable design. Its summary lists several possible protections: accumulating a balance, extending validity, transferring benefits, compensation, a refund, or another protective arrangement.

It also stresses that information about price, volume, validity, usage rules and the treatment of remaining data should be clear to customers.

That choice matters. A single compulsory rollover product could fit some usage patterns and constrain others. A user who wants data to carry over may value accumulation; another may prefer an extension, a transfer, or compensation. The Court’s formulation leaves room for different packages while setting a boundary: a paid balance cannot be made meaningless by allowing it to lapse without a usable option. The article does not decide which remedy is best for every customer. It asks how a regulator can tell whether the available choice works.

The Ministry of Communications and Digital Affairs’ Circular No. 4 of 2026 gives the obligation an operating surface. The ministry’s legal-information service lists the circular as in force and dates it 26 August. A government summary says providers should offer flexible choices, protect prepaid and postpaid balances, avoid additional charges for preserving or using remaining data, make key terms understandable, provide an integrated way to monitor usage and balances, improve complaint handling, and report compliance by 28 September and monthly thereafter.

A reporting calendar creates a rhythm for supervision, but a report is only as useful as the question it answers. On 3 October, the ministry’s Digital Infrastructure Directorate described its first-month review as not yet optimal. It said that notifications alone did not provide substantive protection and called for a mechanism that preserves the economic value of data already bought. That public assessment identifies a real distinction in the policy: telling someone that a balance is about to expire is not the same as making the balance usable.

The release does not publish a reproducible subscriber-level test, a success rate for retrieving data, a sample, or a breakdown of complaint outcomes. It therefore cannot support a claim about how often customers nationwide were unable to use a balance, which designs performed best, or whether a named provider complied. The useful question is narrower: what evidence would demonstrate that the choice required by the Court exists for an ordinary customer at the point when a package expires?

A practical test could follow one customer journey without recording the customer’s identity or browsing history. First, the package terms should show the balance, its expiry condition, and the available remedies in language the customer can understand. Second, the customer should be able to choose a remedy before the balance is removed. Third, the system should show whether the remaining balance stayed available, was transferred, was compensated, or was refunded—and whether an extra fee was charged. Finally, a complaint should have a trackable path to resolution when the display and the customer’s experience disagree.

These are proposed measures, not a new legal test announced by the Court. They translate its words—active, usable, and chosen—into things an auditor can observe. A notice-only flow could pass a message-delivery check while failing the more important question of what happens to the paid balance. A monitoring channel could show a number but still leave the remedy unclear. Separating those steps helps regulators distinguish communication from protection.

The ministry’s monthly reporting obligation offers a place to make the distinction visible. A public summary could report, in aggregate, how many sampled service flows gave customers a remedy, kept the balance accessible, avoided additional fees, and resolved complaints. It need not disclose individual histories or compare company brands. A consistent method and a clear description of the sample would be more informative than a broad label such as “implemented” or “under review.”

The legal promise is already specific enough to guide this work. The remaining task is evidentiary: demonstrate that an available option leads to usable value. If a balance survives only as a notification, the customer has learned about its loss without receiving the protection the Court described. If a chosen remedy can be checked from the customer’s view through to the final account state, the monthly report can show whether the system preserved the right in operation.

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