The Government of Indonesia has modernized the toll road transaction system by implementing the multi-lane free-flow (MLFF) project, set to operate commercially by the end of 2024. This project leverages Global Navigation Satellite System (GNSS) technology to identify vehicles using toll roads and establish a transaction mechanism that allows the MLFF Project Company to charge road users according to distance, vehicle category, and tariff levels. The project has result in a complex business arrangement between the Indonesia National Toll Road Authority (INTRA), Toll Road Companies (TRCs), and the MLFF Project Company. The aim of this paper is to review the regulatory and institutional framework of the MLFF project and analyze its challenges. The methodology employed is a qualitative framework for legal research, utilizing international literature reviews and current regulatory frameworks. The study assesses the proposed transaction architecture of the project and identifies commercial, political, and other risks associated with its implementation. Based on the analysis, the research identifies opportunities for regulatory improvements and better contracting arrangements. This research provides valuable insights into the regulatory landscape and offers policy recommendations for the Government to mitigate the identified risks. This contribution is significant to the academic field as it enhances understanding regulatory and institutional challenges in implementing advanced toll road systems.