This article examines algorithmic risk governance in the regulation of artificial intelligence (AI) through a comparative analysis of the European Union and Indonesia. It proceeds from the premise that algorithmic systems represent not merely technological innovation, but a structural transformation of administrative authority, regulatory oversight, and democratic legitimacy within contemporary governance. Drawing upon risk regulation theory, public value governance, and institutional transfer theory, the study analyzes how the European Union institutionalizes a risk-based regulatory architecture through the AI Act, the General Data Protection Regulation (GDPR), and the Digital Services Act. It then evaluates Indonesia’s evolving digital governance landscape, characterized by the expansion of the Electronic-Based Government System (SPBE) and the national AI roadmap, yet lacking a structured risk-tiered AI regulatory framework. Using a qualitative comparative institutional design, the article identifies structural divergences in risk classification, accountability mechanisms, and institutional capacity. Based on these findings, it proposes an adaptive model of algorithmic risk governance that emphasizes phased implementation, proportional regulatory design, and capacity-sensitive institutional development. The theoretical contribution of this study lies in integrating risk-based regulation with governance maturity considerations in decentralized and capacity-variable administrative systems. From a policy perspective, the article offers strategic recommendations to strengthen algorithmic accountability, supervisory coordination, and democratic legitimacy in Indonesia’s digital transformation trajectory.
Kaplale et al. (2026) studied this question.