This article explores the legal framework of Unmanned Aircraft System (“UAS”) in Indonesia and European Union (“EU”). Both Indonesia and EU is similar in a way that both do not have a third-party liability regulation for UAS. As no uniform law on third-party liability is found in EU, national legislations (France and Spain) will be used as comparisons. This article aims to compare the different minimum amount of insurance coverage between Indonesia and the EU, and find out what lessons can Indonesia extract from the practice of EU. It is recommended that the Indonesian government refers to the practice of EU member states such as Spain and France where UAS operators are bound with more responsibilities for the operation of UAS, such as the requirement of the third- party protection system or establishing a protection area and safe recovery zone. The Indonesian regulation also needs to clarify on the party to seek compensation from. Lastly, the minimum requirement for insurance coverage should also be included within the regulation because it serves as a protection towards third-party in case the insurance purchased by the UAS operators could not cover the amount of loss that the injured party suffer.
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