摘要：In a democratic society, the criminalisation of spreading disinformation is deemed a violation of freedom of expression. The development of information and communication technology, specifically the Internet, has changed people's perceptions of both disinformation and freedom of expression. This research critically analyses criminal law intervention against disinformation and freedom of expression in Indonesia. The research is document research using a comparative approach that analyses laws and regulations on disinformation in Indonesia, Germany, and Singapore. For Indonesian law, this research focuses on the provision of Articles 14 and 15 of Law No. 1/1946, which criminalises disinformation in the public sphere. This research shows that Indonesia needs a new approach regarding the criminal prohibition of spreading disinformation. It recommends that criminal law intervention is limited only to disinformation that is spread on a massive scale and causes significant harm.
关键词：criminalisation;disinformation;freedom of expression;harm principles;Indonesia
