<![CDATA[This study analyses the regulatory gaps surrounding the position and accountability of substitute notaries in Indonesia, with a particular emphasis on problematic authentic deeds and the consequences they generate for the definitive notary who returns to office. As a state founded on the rule of law, Indonesia demands legal certainty, justice, and adequate protection for every party engaged in notarial services. Pursuant to Law Number 30 of 2004 as amended by Law Number 2 of 2014 concerning the Notary Office (UUJN) and Minister of Law and Human Rights Regulation Number 19 of 2019, recently strengthened by Minister of Law Regulation Number 22 of 2025, substitute notaries are vested with the temporary authority to perform notarial duties during the leave or unavailability of the definitive notary. Although their authority is normatively equivalent, the qualification thresholds for substitute notaries are noticeably less stringent, which heightens the risk of substantive defects in the deeds they execute. Using a normative-juridical approach, this paper examines statutory provisions, doctrinal writings, and scholarly opinion to map the gaps relating to (i) the boundary between civil and criminal liability between substitute and definitive notaries, (ii) post-leave accountability when a substitute notary disappears or is insolvent, (iii) the absence of specific rules on the loss of minuta deeds after handover, (iv) the constitutional construction of leave for substitute notaries facing prolonged physical or mental incapacity, and (v) the protective mechanism for summoning substitute notaries and their immunity rights under Article 66 UUJN. The study concludes that, while the substitute notary bears full personal responsibility, administrative, civil, and criminal, for every deed produced during the leave period, persistent regulatory ambiguity continues to expose definitive notaries to administrative scrutiny, civil entanglement, and reputational harm. The paper therefore proposes legislative refinement, stricter Majelis Pengawas Daerah (MPD) supervision, and a robust internal cooperation agreement grounded in Article 1365 of the Indonesian Civil Code as practical mitigation measures.]]>
