ABSTRAKOver the past few years, one of Indonesias state-owned enterprises, PLN, has conducted dialogues focusingon developing a new value-creative business model to transform itself, a sleepy regulated utility, into a trulycompetitive electricity service provider. However, efforts to preserve the prominence of the Countrys electricitysector have been ongoing as the sector is still experiencing sustained rolling blackouts, net import dependencyand lack of transmission facility enforcement throughout the Indonesian archipelago. Such efforts have beenvaried from the incentivise policy and programs such as the Public-Private Partnership and the two phasesof Fast Track Program. The reformation of electricity law dated back on the 1985, 2002 and 2009 to attractinvestors in the development of Indonesias electricity sector have been enacted, but a controversial issue arosefrom the annulment of the Law No. 20 Year 2002 on Electricity by the Constitutional Court Decision No. 001-021-022/PUU-I/2003 stating that such law which clearly stating that the requirement to privatise electricityoperation was unconstitutional. This article will try to provide a comprehensive comparative analysis of suchdecision with the common practice adopted by the EU which has successfully implemented its deregulationand separation of the electricitys business chain through unbundling the sector as part of liberalisation.