Government Socialises New Risk-Based Business Licensing Regulation PP 28/2025
The government has begun socialising Government Regulation (PP) Number 28/2025 on the Implementation of Risk-Based Business Licensing, which was officially issued on 5 June 2025. The new regulation replaces PP 5/2021 and marks an improvement to the risk-based business licensing system, making it more measurable, digital and integrated through the Online Single Submission Risk Based Approach (OSS-RBA).
"This regulation affirms the government's commitment to strengthening the business licensing ecosystem that supports investment growth and provides legal certainty for business operators," said Coordinating Ministry for Economic Affairs Secretary Susiwijono Moegiarso during a socialisation event at the ministry's office on Monday (30/6/2025).
Susiwijono explained that there are three key substantive differences between PP 28/2025 and the previous regulation.
First, the implementation of service level agreements (SLAs). For the first time, every stage of the business licensing process, from registration to permit issuance, will be given clear service time limits. "Business operators have long complained about uncertainty over timeframes. Under PP 28, for example, the process for approving spatial use conformity at ATR/BPN is set at a maximum of 25 working days without revision, or 40 days if amendments are required," he explained.
Second, a constructive approval (fiktif positif) policy whereby business permits will be issued automatically if the relevant agency fails to make a decision within the stipulated SLA timeframe. This policy will be implemented in phases across permit-issuing ministries and agencies, including ATR/BPN, the Ministry of Environment and Forestry (KLHK), the Ministry of Marine Affairs and Fisheries, the Ministry of Public Works and Housing (PUPR), as well as technical sectors such as agriculture, energy and mineral resources, industry, tourism and manpower.
Third, all licensing processes — whether basic, sectoral or supplementary — must be conducted through the OSS-RBA system managed by the Ministry of Investment/BKPM. "This regulation requires all ministry and agency systems to be integrated into OSS-RBA. There will no longer be sectoral licensing systems operating independently," said Susiwijono.
In addition to the three existing systems (information, services and supervision), OSS-RBA will also be strengthened with three new subsystems: basic requirements, business facilities and partnerships.
PP 28/2025 also establishes OSS-RBA as the sole legal reference for risk-based licensing. Accordingly, no additional requirements or permits beyond those stipulated in this regulation are permitted, whether imposed by central ministries or agencies, regional governments or zone administrators.
"The primary objective of this regulation is to create business certainty and alignment between central and regional policies, so that Indonesia's investment climate becomes increasingly competitive," said Susiwijono.
The government has provided a four-month transition period during which the OSS-RBA system will be adjusted to comply with the new provisions of PP 28. Full implementation is scheduled to take effect from 5 October 2025.
"During this transition period, we will conduct thematic socialisation sessions together with the relevant sectoral ministries and agencies, to ensure understanding and readiness on the part of all stakeholders," said Susiwijono.
"This regulation affirms the government's commitment to strengthening the business licensing ecosystem that supports investment growth and provides legal certainty for business operators," said Coordinating Ministry for Economic Affairs Secretary Susiwijono Moegiarso during a socialisation event at the ministry's office on Monday (30/6/2025).
Susiwijono explained that there are three key substantive differences between PP 28/2025 and the previous regulation.
First, the implementation of service level agreements (SLAs). For the first time, every stage of the business licensing process, from registration to permit issuance, will be given clear service time limits. "Business operators have long complained about uncertainty over timeframes. Under PP 28, for example, the process for approving spatial use conformity at ATR/BPN is set at a maximum of 25 working days without revision, or 40 days if amendments are required," he explained.
Second, a constructive approval (fiktif positif) policy whereby business permits will be issued automatically if the relevant agency fails to make a decision within the stipulated SLA timeframe. This policy will be implemented in phases across permit-issuing ministries and agencies, including ATR/BPN, the Ministry of Environment and Forestry (KLHK), the Ministry of Marine Affairs and Fisheries, the Ministry of Public Works and Housing (PUPR), as well as technical sectors such as agriculture, energy and mineral resources, industry, tourism and manpower.
Third, all licensing processes — whether basic, sectoral or supplementary — must be conducted through the OSS-RBA system managed by the Ministry of Investment/BKPM. "This regulation requires all ministry and agency systems to be integrated into OSS-RBA. There will no longer be sectoral licensing systems operating independently," said Susiwijono.
In addition to the three existing systems (information, services and supervision), OSS-RBA will also be strengthened with three new subsystems: basic requirements, business facilities and partnerships.
PP 28/2025 also establishes OSS-RBA as the sole legal reference for risk-based licensing. Accordingly, no additional requirements or permits beyond those stipulated in this regulation are permitted, whether imposed by central ministries or agencies, regional governments or zone administrators.
"The primary objective of this regulation is to create business certainty and alignment between central and regional policies, so that Indonesia's investment climate becomes increasingly competitive," said Susiwijono.
The government has provided a four-month transition period during which the OSS-RBA system will be adjusted to comply with the new provisions of PP 28. Full implementation is scheduled to take effect from 5 October 2025.
"During this transition period, we will conduct thematic socialisation sessions together with the relevant sectoral ministries and agencies, to ensure understanding and readiness on the part of all stakeholders," said Susiwijono.