This new Regulation has now refined and revised a wide array of aspects that specifically relate to privately owned and government-owned pawnbroker companies (?Companies?). These revisions include the removal of the distinction between privately owned and state-owned Companies, an explicit definition of sharia Companies and the introduction of Maximum Loan Limits (Batas Maksimum Pemberian Pinjaman ? BMPP) in order to ensure adequate levels of financial stability. Legal entity and ownership rules also now allow for foreign participation in line with strict conditions, with significantly higher capital requirements and stricter shareholder eligibility criteria being introduced.

This Fifth Amendment authorizes the Minister of Trade to suspend, freeze or revoke export-sector business permits based on the national interest, the public interest and/or Presidential Directives, thereby expanding official export policy beyond the existing compliance-based regime. Most notably, exports of goods for which pre-existing Customs Export Notification (Pemberitahuan Pabean Eskpor/PPE) registrations were completed prior to the suspension or revocation of relevant permits will continue to be processed by the Directorate-General of Customs and Excise.

This Regulation introduces a 100%, government-borne, Value-Added Tax (Pajak Pertambahan Nilai/PPN) incentive (PPN Ditanggung Pemerintah - ?PPN DTP?) for scheduled, domestic economy-class, air-transportation services, particularly for ticket purchases and flight periods that fall within the 25 April to 23 June 2026 window. In response, Airline Companies should prepare and electronically submit detailed PPN DTP transaction lists via the official portal of the Directorate-General of Taxes by 31 July 2026.

In addition to transfers, the settlement of customs obligations now also includes two other methods: re-export and destruction. Before executing these obligations, business entities must first secure approvals from the Head of the Customs Office responsible for the settlement of the relevant customs obligations (?Head?). Said approvals will remain valid for 60 days from their dates of issuance. Entities are also newly required to submit annual reports to the Head on the utilization of equipment and materials that are used to prevent or control environmental pollution (collectively referred to as ?Goods?). These reports must be submitted for the first five years following the date of the relevant import declaration, while any failure to comply with this reporting obligation will result in the suspension of the following import-duty exemption service.

The Regulation introduces a number of new compliance obligations that strictly limit the outsourcing of work to six specific types of supporting services, while also requiring stronger worker protections to be set out in written outsourcing agreements. The Regulation also introduces a two-year adjustment period, which companies should use in order to bring their outsourcing arrangements into line with the new framework, with any non-compliance resulting in the imposition of administrative sanctions, including written reprimands and restrictions on business activities.

The government redefines the state receivables management framework by introducing provisions on physical control and utilization of collateral and other assets, expanding the scope of assets subject to assessment, and regulating settlement through asset transfers.

In order to ensure compliance with consumer and public protection standards, financial services business actors (pelaku usaha jasa keuangan/PUJK) are required to submit annual self-assessment reports to the Financial Services Authority (Otoritas Jasa Keuangan ? ?OJK?) by 30 September of each year. These reports should be prepared through a set of working papers and should cover key areas such as data protection, disclosures of product information and the handling of complaints. A designated board of directors? member should also be appointed to oversee the preparation and presentation of said reports, which should primarily be submitted via the OJK?s online system.

The Draft Amendment enhances Indonesia?s electronic land registration framework by revising the various rules that apply to the content, access, verification and printing of Electronic Certificates (?e-Certificates?). The framework will also strengthen various procedural aspects, including timelines for the submission of documents, the conversion of media and data maintenance. In addition, the Draft Amendment also addresses a number of practical issues, including the replacement of e-Certificates in response to their damage/loss, as well as the handling of missing analog records and the clarification of various processes relating to the deletion, cancellation and restoration of land rights.

In response to formal judicial review petition filed against Law No. 37 of 2004 (?Law 37/2004?), Indonesia?s Constitutional Court officially declare Article 74 (1) of Law 37/2004 that require Receivers submit quarterly reports to Supervisory Judge contradicts with Article 28D (1) of the 1945 Constitution and conditionally unconstitutional, unless interpreted to require Receivers to simultaneously provide reports to creditors and debtors via registered mail, email or digital applications.

PT Bursa Efek Indonesia has now updated the ETF listing framework set out under Current Rule I-C by accommodating gold-based products as a new asset class. The new framework also strengthens class-based reporting and delisting mechanisms, while reinforcing the electronic document submission system. Taken collectively, these measures should increase both product flexibility and compliance complexity for Investment Managers that operate within Indonesia?s capital market.