Towards Mandatory Halal Certification on 18 October 2026: Legal Readiness and MSME Compliance Challenges
The countdown has begun. In less than two years, specifically by 18 October 2026, all micro and small enterprises (MSEs)—ranging from food and beverages to slaughtered products—will be required to possess halal certificates. This is not a new concept; the obligation has actually been written into law since the enactment of Law Number 33 of 2014 concerning Halal Product Assurance, and was further strengthened by Government Regulation Number 42 of 2024. What is new, and what makes this deadline feel different, is the enforcement instrument.
The question is simple yet crucial: if the norms have existed since 2014, and the sanction instruments have only just emerged for 2026, is our legal system truly ready to enforce them, or is this readiness merely on paper? To answer this, three layers must be examined individually: the readiness of the norms, the readiness of enforcement instruments, and the readiness of field implementation.
First Layer: Mature Norms
Normatively, there is no room for doubt. Law 33/2014 and PP 42/2024 have provided a clear foundation and have been implemented gradually over the past few years. From this perspective, legal readiness is complete; business actors have had years to adjust, rather than facing a sudden shock.
Second Layer: New Enforcement Instruments with ‘Teeth’
On 5 June 2026, the Halal Product Assurance Organizing Agency (BPJPH) promulgated BPJPH Regulation Number 2 of 2026 regarding the Imposition of Administrative Sanctions for Violations of Halal Product Assurance Implementation. For the first time, the enforcement of halal obligations has detailed technical guidelines: types of violations, sanction procedures, and mechanisms for business actors to lodge objections. The sanctions are tiered, ranging from written warnings, administrative fines, revocation of certificates, product recalls from circulation, to the freezing of operations and revocation of registration numbers.
In the field, implementation is becoming concrete. For instance, the Head of the Halal Product Assurance Organizing Agency (PJPH) for Lampung Province, Saluddin, detailed the stages of written warnings that will be applied in his region, namely one month, one month, and three months, before severe sanctions such as the cessation of buying and selling transactions are imposed. This is good news for legal certainty: rules that were previously mostly advisory now have ‘teeth’, in accordance with the mandate of Rechtssicherheit—norms must be able to be enforced consistently, not merely as moral appeals.
However, not all parties view these stages as being sufficiently firm. Some culinary business actors in Lampung actually believe that this five-month tiered warning scheme is too lenient and is considered insufficiently ‘deterrent’ for businesses that are reluctant to comply. This difference in perception is important to note: legal certainty on paper is not automatically accepted as convincing certainty in the field, especially by those who have been compliant from the start and feel they are being treated equally with those who are delaying their obligations. Regarding this second layer, legal readiness exists, but its legitimacy in the eyes of business actors still needs to be tested through consistent application.