Under the new regime business licensing is expressly structured as a risk-based licensing chain. While the Business Registration Number (“NIB”) remains the initial identifier, the lawful operation of business activities, particularly medium-and high-risk activities depends on fulfillment and verification of applicable basic requirements and licensing obligations. Therefore, the companies should not rely solely on the issuance of an NIB as evidence of operational readiness. This marks a shift from earlier practice under GR 5/2021, where NIB issuance was less tightly linked to upstream compliance.
Sector Exceptions :
- Finance
- Education
There is an indication that certain sectors: finance and education are treated differently. The NIB in these sectors may function mainly as a business registration identity, while the actual business license is issued separately by the relevant ministry without full OSS integration.
Article 167 (2) of GR 28/2025 outlines the riskbased
business licensing framework for educational institutions. It specifies that educational institutions must comply with the prevailing laws and regulations in the field of education, including the regulations issued by the minister administering governmental affairs in the sub-sector of primary and secondary education, as well as the minister administering governmental affairs in the sub-sector of higher education and in the field of science and technology, before the NIB can be issued.
Seperately, regarding the financial sector, it is also required to obtain the sectoral business license from the Financial Services Authority (OJK) before the NIB can be issued.
History & Nomenclature
Old Regime
Online Single Submission “OSS” 1.0 (2018)
Legal Basis: Government Regulation (GR) No. 24
of 2018 on Integrated Electronic Business
Licensing.
OSS 1.1 (2019)
Transferred to the Investment Coordinating
Board (BKPM).
Improvements: Better database structure,
enhanced data validation, and improved
coordination between ministries and local
governments.
OSS-RBA (Risk-Based Approach) August 2021
Legal Basis: Presidential Regulation (PR) No. 5 of
2021 on Risk-Based Business Licensing.
To simplify permits, accelerate investment, and
integrate all sectors under a unified risk-based
system.
New Regime
Reformed OSS-RBA (2025, after GR 28/2025) GR
No. 28 of 2025 replaces PR 5 of 2021
BKPM Regulation No. 5 of 2025.
Focus on System alignment, refined risk
classification, and simplified licensing for
medium- and large-scale enterprise
Accordingly, ongoing and existing businesses
should review their OSS status to ensure
alignment with the updated framework. In
addition, business actors shall reassess their
conditions precedent in business licensee
documents to reflect the new requirements.
How Regulatory
Transformations Affect Business
Actors Under the Transitional
Provisions
Transitional Provisions
The “Transitional Provisions” means that businesses that have already obtained licenses under the previous regulatory regime are allowed to continue operating under those existing licenses.
The new regulatory regime stipulates that companies that initiated their licensing applications
before the enactment of GR 28/2025 shall continue to have their applications processed under the
previous regulatory framework under the PR 5/2021, until such process is completed.
- Article 547 GR 28/2025 ⟶ Only after the new system is operational will the applications transition to the new rules of GR 28/2025.
- Article 388 BKPM 5/2025 ⟶ business actors who are registered in the OSS system comply with the
new risk-based licensing regulations outlined in GR 28/2025. The replacement of access rights is
meant to ensure that all data and information regarding business permits or investments align
with the updated system and standards.
Lower Paid up Capital Requirement for
PMA
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Under Article 26 of BKPM Regulation No. 5 of 2025, the minimum paid-up capital requirement for foreign investment companies (PMA) has been reduced from IDR 10 billion to IDR 2.5 billion. This regulatory change significantly lowers the entry barrier for medium-scale investors seeking to enter the Indonesian market.
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Previously, the IDR 10 billion threshold was stipulated under Article 7 of PR No. 10 of 2021 on Investment Business Fields, which served as the legal basis before the enactment of BKPM Regulation No. 5 of 2025.
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This policy shift is expected to enhance Indonesia’s investment attractiveness and support the acceleration of broader economic transformation.
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