<![CDATA[Formal safety-reporting norms exist internationally, nationally and institutionally, yet protection for reporters in Indonesian pilot training remains inoperative. This study asks why, and what design closes the gap. It compares the Safety Management System Manual of the Indonesian Civil Pilot Academy of Banyuwangi (Issued 02, Revision 02) with ICAO Annex 19, Third Edition, using normative legal research with a documentary case study. Soekanto’s legal-effectiveness theory supplies the diagnosis; responsive regulation, developed by Ayres and Braithwaite and refined by Baldwin and Black, supplies the prescription. Three connected gaps emerge. First, reporter protection travels through six referring levels, from the Manual’s “to the extent permissible by law” clause down to the 2017 Director General Regulations, which provide administrative de-identification only and whose delegating basis Ministerial Regulation 2/2026 revoked without a transitional provision. Second, the Manual grants cadets disciplinary immunity but withholds identity confidentiality. Third, no enforcement rung exists between internal correction and criminal proceedings. Annex 19 permits a non-judicial competent authority; Articles 364–369 of Law 1/2009 already provide for one. Because Government Regulation 62/2013 implemented only the investigation half of Article 369, the article proposes operationalising the Aviation Profession Council as a technical-professional adjudicative filter, on the Maritime Court design precedent]]>
