In addition to the already mandatory application of Anti-Money-Laundering (Anti Pencucian Uang "APU") and Prevention of Terrorism Financing (Pencegahan Pendanaan Terorisme "PPT") efforts, business actors operating within the financial sector under the supervision of Bank Indonesia ("BI") ("Organizers") must also now apply measures that specifically relate to the Funding of the Proliferation of Weapons of Mass Destruction (Pencegahan Pendanaan Proliferasi Senjata Pemusnah Massal "PPSPM"). Organizers have been given a grace period of between six months and one year (depending on their classification) in order to bring their operations into line with the updated APU, PPT and PPSPM requirements.
The Controlling Shareholders (Pemegang Saham Pengendali "PSP") and/or Ultimate Controlling Shareholders (Pemegang Saham Pengendali Terakhir "PSPT") of financial conglomerates ("Conglomerates") are now required to establish Financial Holding Companies (Perusahaan Induk Konglomerasi Keuangan "PIKK") by submitting applications by no later than 23 June 2025. Any failure to meet this obligation may result in the imposition of administrative sanctions that range from written reprimands to a prohibition on serving as main parties in Conglomerates.
The new framework has now expanded the types of halal certification ("Certification") services that are available through the SIHALAL platform by adding two new options (i.e. self-declared certification with independent funding and self-declared certification for product development or expansion). In addition, this Decree also introduces various criteria and requirements that must be met by micro- and small-scale enterprises ("MSE") in order for them to qualify for Certification.
The Draft Bill ("Draft Bill") on the Fourth Amendment to Law No. 4 of 2009 on Mineral and Coal Mining ("Law 4/2009") introduces revisions to a total of seven existing articles originally set out under Law 4/2009 and also includes five new articles. The various revisions that feature under the Draft Bill include: 1) New priority granting of Metal Mineral Mining Business License Areas (Wilayah Izin Usaha Pertambangan/WIUP) to private business entities (for down-streaming purposes) and universities; and 2) Rather than being guaranteed by the government, extensions and transformations of Contracts of Work (Kontrak Karya/KK) and Coal-Mining Concession Work Agreements (Perjanjian Karya Pengusahaan Pertambangan Batubara/PKP2B) into Special Mining Business Licenses (Izin Usaha Pertambangan Khusus/IUPK) as a continuation of KK/PKP2B will become optional in nature.
The new framework of Regulation 22/2024 establishes a set of procedures for submissions of reports that specifically address the implementation of competency standardization in relation to payment systems (Standardisasi Kompetensi di Bidang Sistem Pembayaran/SK SP) for both banks and non-banking institutions. These reports include both periodic (i.e. quarterly and annual) and incidental reports. Any failure to meet the applicable reporting deadlines may result in the imposition of penalties such as written warnings, suspensions of business activities or revocations of licenses.
The maximum funding limits for Information Technology-Based Joint Funding Services (Layanan Pendanaan bersama Berbasis Teknologi Informasi "P2P Lending") have been updated and now stand at the following values: 1) A maximum consumption funding limit of up to Rp. 2 billion and 2) A maximum productive funding limit of up to Rp. 5 billion. Moreover, any organizers of P2P Lending services ("Organizers") who offer productive funding levels of between Rp. 2 billion and Rp. 5 billion will be required to ensure that their non-performing loans do not exceed 5% over the previous six months and must not currently be subject to any OJK sanctions in the form of business restrictions or suspensions.
The government has decided on an official name for the employment information system, which will now be known as the Employment Information System and Services Application (Sistem Informasi dan Aplikasi Pelayanan Ketenagakerjaan "SIAPkerja"). Offering a total of 25 employment-related services spanning five categories, SIAPkerja will be made available to various stakeholders operating within the employment sector (e.g. job seekers, employers, education and training agencies, the government and so forth).
Refund applications that are submitted by individual taxpayers and that address overpayments amounting to a maximum of Rp. 100 million will be handled in line with specific special provisions. These provisions state that the refund process will be conducted based on criteria that are established for certain types of taxpayers. Furthermore, in cases where tax underpayment assessments result from refund reviews, then relevant taxpayers will be granted a reduction in their administrative sanctions, specifically a reduction in interest penalties, in accordance with the applicable Laws.
The types of incentives that are available to companies that manage and develop industrial areas ("Industrial Area Companies") and industrial companies that operate within said areas (collectively referred to as "Companies") have been expanded. Said incentives have been categorized into three types: 1) Fiscal incentives (e.g. taxation, customs, non-tax state revenue); 2) Non-fiscal incentives (e.g. immigration, land and labor); and 3) Regional incentives (e.g. regional tax and/or regional retribution exemptions). Additionally, the benefit of ease in terms of the construction and management of electrical power facilities for personal use remains available to Companies.
While continuing to mandate that customs export notifications ("Notifications") should be submitted in electronic data form via the Computer Service System (Sistem Komputer Pelayanan - "SKP"), exporters may now submit their Notifications through the following methods if the SKP at relevant customs offices are experiencing operational disturbances or force-majeure events: 1) Manually through the submission of filled out forms; 2) Through the submission of electronic data storage media; or 3) Via email.