Regulation 25/2025 introduces a standardized framework for the issuance of Franchise Registration Certificates (Surat Tanda Pendaftaran Waralaba - "STPW") by regional governments through the Online Single Submission ("OSS") system. In this regard, STPW applications may be submitted by the franchisees of domestic franchisors, as well as by the sub-franchisees of both foreign and domestic franchisors. Alongside their applications, applicants must upload two key documents to the OSS system, specifically a Franchisee Registration Form and a Franchise Agreement. A Franchise Agreement must contain 15 mandatory clauses covering various aspects that specifically relate to the operations of franchise businesses.

The Employment Information System and Services Application (Sistem Informasi dan Aplikasi Pelayanan Ketenagakerjaan "SIAPkerja") is Indonesias central platform for the implementation of Competency-Based Training (Pelatihan Berbasis Kompetensi Kerja "PBK"), and PBK organizers are required to register through SIAPkerja in order to secure Vocational Identification Numbers. Moreover, this framework also introduces Tailor-Made Training, which is a new, collaborative training format aimed at producing graduates whose skillsets are more in line with market requirements for specific types of workers.

This new framework introduces a number of significant updates to the Digital Gold Physical Market by revising the technical requirements that must be met by gold in order for it to be deemed eligible for trading. Specifically, all gold must be stored with a Gold Storage Manager and must meet certain specific criteria, including a purity rating of 99.9% purity, proper certification, standardized or approved weight units and a declaration confirming that the gold in question is unencumbered and was legally sourced. Furthermore, the Regulation now categorizes Traders into two types based on capital thresholds. In this regard, Type-A Traders are required to have a minimum level of paid-up capital amounting to Rp. 100 billion, while the paid-up capital level for Type-B Traders has been set at Rp. 50 billion, each with a specific minimum ending balance. In order to ensure regulatory compliance, administrative sanctions may be imposed and range from written warnings and fines to business suspensions, license revocations and registration cancellations.

This new import framework has now revised requirements for the conversion of General Importer Identification Numbers (Angka Pengenal Importir Umum/API-U) into Producer Importer Identification Numbers (Angka Pengenal Importir Produsen/API-P) by eliminating the previous obligation to fully realize imports and instead mandating assessments of the current validity and realization status of import approvals or Surveyors Reports (Laporan Surveyor/LS). This new Regulation also introduces a tiered sanctions framework for specific violations, which may escalate from written warnings to one-year revocations and suspensions of issued import licenses and certificates. Additionally, the new framework has now revoked existing import approvals for five specific commodities (e.g. forestry products, plastic raw materials and subsidized fertilizers). This means that importers will now have to reapply in line with the updated regulatory scheme, as previously submitted applications will not be processed.

Securities companies that operate as Securities Underwriters (Penjamin Emisi Efek "PEE") and Securities Brokers (Perantara Pedagang Efek "PPE") are required to implement certain specific internal control functions and operate in line with a set of defined business conduct standards. In this regard, PEE must establish five internal control functions, while PPE are required to implement a total of eight functions. In addition, Regional Securities Companies (Perusahaan Efek Daerah "PED"), a type of PPE that operates at the provincial level, must also maintain at least seven internal control functions similar to those of PPE. Additionally, PPE and PED are now permitted to collaborate with social-media influencers in order to engage in advertising or promotional activities in line with written agreements.

While maintaining the obligation for businesses operating within the cosmetics sector ("Businesses") to ensure that all manufactured and/or imported cosmetics that will be distributed within Indonesia are in compliance with relevant safety and efficacy requirements, specifically cosmetics contamination ("Contamination") limits, the new framework also now specifies that Businesses comprise the following types of entities: 1) Manufacturers of cosmetics products operating within Indonesia; 2) Individuals or business entities operating within Indonesia that operate under production contracts with manufacturers of cosmetics products; and 3) Importers operating within the cosmetics sector.

The Draft Circular addresses three types of submissions that are required to be made by pawnshop companies ("Companies"). The first of these is licensing applications, which include business licenses, conversions to sharia-compliant entities and the establishment of sharia business units (Unit Usaha Syariah "UUS"). The second type of submission is approval applications, which cover matters such as voluntary UUS spin-offs, UUS closures and the employment of foreign workers. The third type of submission relates to reporting obligations, which encompass the implementation of business activities, resolutions from general meetings of shareholders that approve conversions to sharia-compliant entities and the implementation of said conversions.

Electronic Mediation ("E-Mediation"), as initiated within the commodity futures trading sector, allows futures brokers and their customers (collectively referred to as "Disputing Parties") to resolve disputes remotely through information and audiovisual communications technologies. In order to qualify for E-Mediation, Disputing Parties must mutually agree on its use or the relevant customer must be unable to travel for medical reasons or reside in a remote, frontier or outlying (3T) region of the country. Throughout the E-Mediation process, the Disputing Parties are required to attend the relevant sessions, ensure that video cameras remain active and participate in the process in good faith. Any settlement that is ultimately reached must be documented in a written agreement and signed electronically before it will become final and binding.

The Amendment states that imports of personal goods that belong to passengers, that are intended for their own personal use ("Personal-Use Goods"), that are acquired from locations lying outside Indonesian customs areas and that have maximum customs-and-excise values of FOB US$ 500 are now exempted from the imposition of value-added tax (Pajak Pertambahan Nilai "PPN"), luxury-goods sales tax (Pajak Penjualan atas Barang Mewah "PPnBM") and income tax (Pajak Pertambahan Nilai "PPh"). This tax exemption also applies to Personal-Use Goods that are brought into the country by transportation crews up to a maximum customs-and-excise value of FOB US$ 50. Meanwhile, imports of goods other than personal belongings that are carried by passengers or transportation crews will now be subject to an import-duty rate of 10%, as well as PPN and PPnBM, and also PPh at a rate of 5%.

The Financial Services Authority (Otoritas Jasa Keuangan "OJK") has now clarified a detailed set of procedures for the submission of reports on share ownership and changes to the share ownership of public companies, as well as reports on share pledging activity undertaken by public companies through an electronic system managed by PT Kustodian Sentral Efek Indonesia and the Indonesian Stock Exchange (BEI). Said reports must be submitted within three days of any acquisition, ownership change or signing of a pledging agreement. In cases where technical disruptions or force-majeure events occur, then reports may be submitted via email or directly to the OJKs head office, although electronic submissions will still have to be completed within five working days of any such technical disruption being resolved.