In its latest effort to improve its investment climate, Indonesian government has recently issued Government Regulation No. 28 of 2025 on Implementation of Risk-Based Licensing (“GR 28/2025”), replacing Government Regulation No. 5 of 2021 regarding the same GR 28/2025 appears to offer greater ease for investors in navigating their licensing process, as outlined below.
- The Online Single Submission (“OSS”) System Now Covers More Sectors
The coverage of the OSS system operated by Indonesia Investment Coordinating Board / Badan Koordinasi Penanaman Modal (“BKPM”) has now been expanded to include several additional sectors such as holding companies, funeral business, creative economy, and third party professional certification.
Now Investors in these sectors should benefit from a more streamlined and efficient licensing process.
- Basic Operational Permits: Exemptions
GR 28/2025 explicitly exempts those trading and services business activities conducted at an office building or within a commercial building complex that the building owner already possesses basic operational permits, such as, spatial planning confirmation, environmental permits, building construction permits, and building worthiness certificates – from a requirement to obtain these permits. This exemption streamlines the licensing procedures, allowing the qualified business actors to directly apply for a business license and commence commercial operations more quickly once such business license is issued – hence, offering the investors easier experience.
- Other Updates
Compare with the previous regulatory regime where administrative sanctions were applied on a sector-specific basis, under the regime of GR 28/2025 administrative sanctions are imposed based on the severity and nature of the non-compliance, regardless the sectors. Therefore, the investors need to watch out this space particularly once the implementing regulations are issued, which according to GR 28/2025 are to be issued within four (4) months as from 5 June 2025 (the date of promulgation of this regulation).
In addition to, GR 28/2025 is also expected to introduce a revised list of requirements to obtain and service levels for licenses across various sectors, as outlined in the annexures of GR 28/2025.
We will issue another newsletter to discuss such topics once the annexures are publicly available.
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