Under this new framework, prospective providers of crowdfunding services must meet a stricter set of requirements, including a minimum paid-up capital of Rp. 25 billion and a maintained equity amounting to at least Rp. 5 billion. Furthermore, phased compliance will be permitted for existing or pending applicants. Prior to securing a business license, providers must also secure a principal approval from the OJK, which will remain valid for up to 12 months, during which time no business activities are permitted to be conducted. Additionally, the OJK now requires certain parties to undergo fit-and-proper testing, including controlling shareholders, cooperative founders and members of boards of directors and boards of commissioners.

While maintaining the core provisions that specifically address the mandatory publication of reports (Reports) by commercial banks (Banks) that engage in conventional business activities, this new framework has now expanded the scope of said Reports to encompass the following additional Report types: 1) Sustainability Reports; 2) Annual integrated governance implementation Reports for Banks that act as the Holding Companies of Financial Conglomerates (Perusahaan Induk Konglomerasi Keuangan/PIKK); and 3) Annual financial statements for Banks that are issuers or public companies. Moreover, Regulation 18/2025 now also newly requires Banks to draw up semesterly financial statements and financial performance information for data at the end of June and/or December. These statements and information should be drafted in a comparative format in accordance with financial accounting standards.

Although the core procedures that address the handling of judicial review petition cases through the Constitutional Court (Mahkamah Konstitusi MK) have been retained, the new framework of Regulation 7/2025 now clarifies that the MK will officially render verdicts on formal judicial review cases within 60 business days of receiving relevant statements from the Indonesian President and/or Indonesias House of Representatives (Dewan Perwakilan Rakyat/DPR) during legal proceedings. Furthermore, Regulation 7/2025 has also narrowed the definition of other parties that have an interest in filed judicial review petitions (Related Parties) so that it now only encompasses parties that have a direct interest in the subject matter of a given petition case.

Draft Circular of the Financial Services Authority (Otoritas Jasa Keuangan OJK) 2025 (Draft Circular) on Transparency and the Publication of Reports by Conventional Commercial Banks (Banks) is set to enhance overall bank transparency through the addition of a semi-annual reporting period and the introduction of new valuation, leverage, credit quality and risk formats. Banks must also ensure oversight by their boards and should submit monthly, quarterly, semi-annual and annual reports. In this regard, December has been set as the key deadline.

The framework of Regulation 24/2025 clarifies the scope of products that are defined as New Drug Development (Obat Pengembangan Baru OPB), as well as the various types of business actors that are eligible to submit applications to secure OPB approvals (Approvals). Said business actors now include hospitals and cell and/or stem-cell processing facilities/laboratories. Furthermore, in addition to redefining the applicable phases that relate to the development of new drugs and that ultimately lead to assessments of OPB (Assessments), Regulation 24/2025 also clarifies that Approvals have a five-year validity period from their dates of issuance.

The Minister of Energy and Mineral Resources has now revised the framework for renewable energy Power-Purchase Agreements (Perjanjian Jual Beli Tenaga Listrik/PJBL) through Regulation No. 5 of 2025 on Guidelines for Power-Purchase Agreements with Power Plants That Utilize Renewable Energy Sources (Regulation 5/2025). This new framework introduces more detailed contractual terms, updated risk-sharing between PT PLN (Persero) and Power Plant Developers (Pengembang Pembangkit Listrik/PPL), as well as new obligations that apply to intermittent Power Plants.

the policy of expenditure efficiency is now extended beyond the year 2025 through the issuance of Regulation of the Minister of Finance No. 56 of 2025 on the Procedure for the Implementation of Expenditure Efficiency within the State Revenue and Expenditure Budget, which sets out the ground rules on the implementation of expenditure efficiency within the state budget. The result of the efficiency itself shall be utilized for the Presidents priority programs.

One newly introduced category of Non-Tax State Revenue (Penerimaan Negara Bukan Pajak PNBP) for the forest plant seeding activities (perbenihan) sector is now applicable to the byproducts of research into superior forest plant seeds (Seeds) and other services (e.g. pest and disease identification for Seeds and seedlings, drone photography and entrance tickets for domestic and international tourists). Moreover, in addition to not continuing to process permit or certificate applications, any failure to settle a given PNBP tariff will result in the imposition of an administrative fine amounting to 2% per month of outstanding PNBP. Furthermore, this sanction will not be imposed beyond a period of 24 months.

The Third Amendment has now revised several provisions that specifically address procurements of goods and services for subsequent use by Cooperation Contract Contractors (Kontraktor Kontrak Kerja Sama KKKS). During contract preparations, KKKS must only list domestically produced goods that meet the technical standards that are set out on the Approved Manufacturer/Vendor List (AML/AVL), while all payments must be processed through state-owned banks, regionally owned banks, or national private banks. In terms of the available tender mechanisms, the Third Amendment has now shortened the award issuance deadline to three business days, extended the contract signing period to 45 business days and also now requires Special Task Force for Upstream Oil-and-Gas Business Activities (Satuan Kerja Khusus Pelaksanaan Kegiatan Usaha Hulu Minyak dan Gas Bumi/SKK Migas) approvals to be issued for any tender awards that exceed Rp. 300 billion or US$ 20 million.

Under this new regulatory framework, the halal certification process for Micro- and Small-Scale Business Actors (Usaha Mikro dan Kecil UMK) involves a self-declaration mechanism that has now been revised to include stricter eligibility and compliance requirements. In this regard, UMK must now have annual sales figures that do not exceed Rp. 15 billion and must also fulfill an expanded set of application obligations that encompass documentation, halal ingredients, product naming and labeling. UMK must also ensure that they engage in production processes that are capable of guaranteeing hygiene, strict separation from haram materials and ongoing conformity with halal standards.