In addition to establishing the overall procedures and mechanisms for the handling of taxation-related crimes, this new Regulation also affirms that both individuals and corporations, regardless of their status as registered taxpayers, may be held liable for any criminal acts that are committed intentionally or that are the result of negligence. This Regulation also allows trial proceedings, including the issuance of verdicts, to be conducted in the absence of any defendants (in absentia).

Corporate criminal liability has now been specifically recognized and will cover both corporations and persons in charge (?PIC?) of corporations. In this regard, procedural rules on corporate representation during investigations, the enforcement of summonses and criminal sanctions, which have been limited to fines and additional penalties, will now be enforced. In addition, a Deferred Prosecution Agreement (?DPA?) framework will now allow the prosecution of corporate criminal cases to be deferred, subject to specific obligations in line with prosecutorial discretion, judicial reviews and court supervision. This means that clear consequences will now apply depending on the outcome of the DPA process.

Indonesia?s announced 2026 Provincial Minimum Wage (Upah Minimum Provinsi ? ?UMP?) policy is set to take effect on 1 January 2026 and must be determined and announced by individual provinces by no later than 24 December 2025. These changes will result in a variety of wage increases across the nation?s various provinces and will require employers to prepare to bring their operations into line with the new wage framework by adjusting their wage policies accordingly.

Buy-Now-Pay-Later (?BNPL?) services may be organized by commercial banks (?Banks?) and financing companies, either conventionally or based on sharia principles, in line with six core criteria (e.g. must be used in order to finance non-cash purchases of goods and/or services, must require no collateral, must set a specified limit [ceiling] and so forth). This Regulation also sets a grace period that will last until June 2026 for Banks and financing companies that are already offering BNPL services to bring said services into line with the new framework.

The 2025 Standard Classification of Indonesian Business Fields (Klasifikasi Baku Lapangan Usaha Indonesia ? ?KBLI?) further redefines the classification structure that originally featured under its predecessor, including an expansion of the list of KBLI categories to encompass a total of 22 categories. The new 2025 KBLI also accommodates various activities that previously featured under the 2020 KBLI, including: 1) Intermediary digital platforms; 2) Factoryless Goods Producers (FGP); 3) Activities that utilize Artificial Intelligence (AI); 4) Carbon Capture and Storage (CCS); and 5) The trading of carbon units and crypto-assets.

Under this new framework, the registration of limited-liability capital-partnership companies (?Companies?) now requires additional beneficial ownership documents to be submitted. This new Regulation has also revised the amendment process for capital-partnership Companies? articles of association and data from a simple registration system to a dual mechanism that comprises approvals and notifications. Additionally, the boards of directors of Companies are now required to submit annual reports to the Minister of Law through the Legal Entity Administration System (Sistem Administrasi Badan Hukum ? ?SABH?) within 30 days of the signing of any notarial deed. Any failure to comply with this requirement may result in the issuance of written warnings and restrictions being placed upon future SABH access.

The Second Amendment introduces a number of key changes to Indonesia?s minimum wage framework that will take effect during the 2026 wage year, including a revised minimum wage calculation formula that raises the labor contribution index to between 0.50 and 0.90 in order to better reflect an adequate standard of living for workers, while balancing the interests of both workers and employers. This new framework also reintroduces sectoral minimum wages at the provincial and qualifying regency/city levels, which will require governors to set said wages through the issuance of official Decrees within five days of the relevant regional minimum wages being determined, with an overall deadline of 24 December 2025 being set. In addition, sectoral minimum wages must be higher than the relevant applicable regional minimum wages and apply only to sectors that meet certain specific criteria, such as sectors that are covered by five-digit Indonesia Standard Classification of Business Fields (Klasifikasi Baku Lapangan Usaha Indonesia/KBLI) codes and that are associated with distinct sectoral characteristics or work-related risks.

Providers of digital financial asset trading (?Providers?) are required to draw up and submit annual business plans and realization reports on said plans to the Financial Services Authority (Otoritas Jasa Keuangan ? ?OJK?). Providers may amend their business plans once a year in the event that material internal or external factors affect their business operations. All business plans, amendments and realization reports must be submitted electronically through the OJK Reporting System, with alternative submissions being permitted via designated email addresses or courier services in certain circumstances.

Food safety training (?Training?) is now open to both State Civil Apparatus (Aparatur Sipil Negara/ASN) employees, as well as other human resources that work within the food safety sector (?Participants?). Training may be delivered through classical, blended or job-integrated learning methods. Meanwhile, Participants must comply with established standards of conduct, with administrative sanctions being imposed in response to violations. Participants will also be subject to clearer requirements relating to the successful completion of Training, including minimum assignment scores, a prohibition on plagiarism and certain attendance thresholds.

This Regulation has been issued as a follow-up to Article 48 of Government Regulation No. 42 of 2024 on the Organization of the Halal Product Assurance Sector (Regulation 42/2024), which replaced Government Regulation No. 39 of 2021 on the Organization of the Halal Product Assurance Sector (Regulation 39/2021), in order to address technical procedures for registrations, revocations of registrations and terminations of halal auditors. Under this new framework, all services must be organized through the integrated Halal Information System (Sistem Informasi Halal - SIHALAL), with detailed timeframes being set for each stage. This new Regulation also reinforces halal auditor commitments through mandatory documentation and stipulates the various consequences that may result from violations. The procedure for the revocation of registrations can be implemented either at the request of Halal Inspection Agencies (Lembaga Pemeriksa Halal LPH) or based on supervision results of the Halal Product Assurance Organizing Agency (Badan Penyelenggara Jaminan Halal BPJPH), with differing consequences applying in either case. Meanwhile, halal auditors may be terminated by LPH under certain conditions, with BPJPH supervision results becoming the basis for any such decision. This Regulation has also strengthened the governance of halal auditors and should ensure that registration services are organized effectively, efficiently and transparently with full accountability.