<![CDATA[Artificial intelligence (AI) has transformed the digital information ecosystem by enabling the rapid creation and dissemination of disinformation at an unprecedented scale. Existing legal frameworks, however, remain largely designed to regulate human conduct and conventional digital platforms, creating significant regulatory gaps in addressing AI-generated disinformation. This study examines the adequacy of Indonesia's current legal framework and develops an appropriate regulatory model through a comparative analysis of the legal approaches adopted by the European Union, the United States, and China. This study adopts a doctrinal legal research methodology and employs statutory, conceptual, comparative, and case-based approaches. The analysis draws on theories of legal certainty, legal responsibility, AI sovereignty, and spatial ontology. The findings demonstrate that Indonesia's existing legal framework remains fragmented and does not specifically regulate AI-generated disinformation. Comparative analysis shows that while the European Union adopts a comprehensive risk-based model, China emphasises platform accountability and administrative control, and the United States relies on sector-specific governance, none fully addresses the jurisdictional challenges arising from the transnational operation of AI systems. This study argues that regulating AI-generated disinformation requires moving beyond purely territorial legal approaches towards a post-territorial understanding of jurisdiction. Accordingly, this study proposes a phased regulatory roadmap for Indonesia comprising a Presidential Regulation, amendments to the existing digital regulatory framework, and a comprehensive Artificial Intelligence Act. By integrating comparative legal analysis with emerging theories of AI governance, this study proposes a legislative framework that can address AI-generated disinformation while safeguarding democratic integrity, legal certainty, and fundamental rights.]]>
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