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.
Organizers of transaction facilities ("Organizers") are now required to allocate training and education funds amounting to approximately 3.5% of their current annual budgets to electronic trading platform providers and 1% of their current annual budgets to brokerage companies based on the previous years gross salary expenditures. Annual reports must also be submitted that address the development of human resources. These two obligations will become effective in January 2026 and April 2027 respectively. In addition, the audit reporting obligation has been replaced with a requirement to submit reports on the implementation of risk management and governance, which are elements of system audits.
Distinct from other Free-Trade Zone and Free Port (Kawasan Perdagangan Bebas dan Pelabuhan Bebas "KPBPB") development authorities, the Batam KPBPB Development Authority (Badan Pengusahaan KPBPB Batam "BP Batam") is now authorized to issue ground requirements (e.g. forest area approvals), business permits and Business Licenses to Support Business Activities (Perizinan Berusaha untuk Menunjang Kegiatan Usaha/PB-UMKU) to entrepreneurs who establish and operate businesses within Batam KPBPB areas.
Vessel registrations may soon encompass not only the issuance of permanent measurement certificates but also temporary measurement certificates. Moreover, the scope of vessel registrations is set to be expanded to include: 1) Ownership transfers; 2) Continuous synopsis records; 3) Deletion of ownership; and 4) Recording and documentation. Furthermore, registered vessels may also be used as collateral through vessel mortgages, which are enforceable through grosse mortgage deeds with executorial power.
Under this newly updated framework, the qualifying criteria that must be met by taxable entrepreneurs (Pengusaha Kena Pajak "PKP") in order for them to be classified as low-risk have been expanded from eight to nine. The new addition in this regard comprises PKP who file value-added tax (Pajak Pertambahan Nilai/PPN) periodic tax returns (Surat Pemberitahuan "SPT") for overpayment restitution of up to Rp. 5 billion. Furthermore, the new framework has now revised the applicable procedures for preliminary tax overpayment refunds by extending the resubmission period for previously unaccounted tax credits to up to three years, and by requiring that decisions on corrected SPT be issued within one month of any complete correction application being received.
Oil-and-gas contractors are now allowed to form partnerships in order to manage their working areas under various cooperation agreements, including operational and/or technological cooperation and oil-well production cooperation. Operational and technological cooperation may be implemented in conjunction with qualified business entities or permanent establishments ("Partners") for idle or producing wells and fields/structures. Meanwhile, oil-well production cooperation may involve Regionally Owned Enterprises (Badan Usaha Milik Daerah/BUMD), Cooperatives or Micro-, Small- or Medium-Scale Enterprises (MSME) during a temporary period that will extend until 10 June 2029, with Contractors obliged to compensate any community members who are responsible for the direct operation of any wells.
Companies are required to complete annual compliance assessments of their Oil-and-Gas Safety Management Systems (Sistem Manajemen Keselamatan Minyak dan Gas Bumi/SMKM) through a self-assessment mechanism. The results of said self-assessments should be submitted to the Director of Oil-and-Gas Engineering and Environment, who also serves as the Head of Oil-and-Gas Inspections, by a deadline of 1 March for the previous assessment year. Assessment results are rated from Outstanding to Poor across six categories based on the relevant total and core substance scores. In addition, Companies are also required to submit corrective action plans within 30 calendar days of receiving their assessment results.
Regulation of the Government No. 28 of 2025 on the Organization of Risk-Based Business Licensing ("Regulation 28/2025") represents a significant update to Indonesias risk-based business licensing framework through the expansion of its scope from 16 to 22 sectors while retaining the two-phase structure for the founding and operation of businesses. One notable change that has been made to the framework covering this area is the clear separation of licensing processes for general businesses from business licensing for micro and small enterprises, with each now having its own designated authorities. The Online Single Submission ("OSS") system has also been upgraded through the addition of three new service subsystems. Moreover, a unified set of administrative sanctions has also been introduced for the first time, allowing authorized officials to impose penalties through the OSS platform.
The eligibility criteria for receiving government aid in the form of salary/wage subsidies (Bantuan Subsidi Upah "BSU") have been revised, meaning that workers are now required to be active participants in the Social Security Agency for Employment (BPJS Ketenagakerjaan) program as of April 2025. Furthermore, BSU is no longer available to any state civil apparatus (Aparatur Sipil Negara/ASN) employees, expanding the previous restriction that applied only to civil servants (Pegawai Negeri Sipil/PNS). Instead, BSU is being prioritized solely for workers who have not received any assistance through the Hopeful Family Program (Program Keluarga Harapan/PKH). The subsidies are distributed as cash payments of Rp. 300,000 per month for periods of two months and are paid as a lump sum.
The Second Amendment has now broadened the range of livestock that are eligible for import to include both feeder and dairy cattle, as well as buffalo. The Second Amendment has also now lifted the previously applicable restrictions that limited animal product imports to boneless meat from cattle and/or buffalo. This new framework also now permits the importation of livestock from countries that are not entirely free from animal pests and diseases, provided that any such countries have official foot-and-mouth disease control programs in place that are recognized by the relevant authorities and meet all of the required animal health standards and import procedures. In addition, State-Owned Enterprises (Badan Usaha Milik Negara/BUMN) and other business actors must now secure import approvals from the National Food Agency (Badan Pangan Nasional/BPN).