New Era for Business Permits: Highlights of Government Regulation No. 28/2025 on OSS-RBA
- Juni 26, 2025
Government Regulation No. 28/2025 strengthens and refines the legal framework for Risk-Based Business Licensing (OSS-RBA). This amendment restructures risk classifications, clarifies the roles of technical ministries and regional authorities, and enhances system integration and compliance oversight. Key sectors affected include mining, import-export, and automotive.
Key Provisions
 ♦ Article 3A: One Activity, One License
Each business activity may only be issued one main license (NIB, Standard Certificate, or Permit) to avoid duplication and enforce integration.
♦ Articles 7A–10A: Empowered Technical Ministries and Local Governments
Ministries such as Energy and Mineral Resources (ESDM), Industry, and Trade, along with local governments, are authorized to conduct technical validation and oversee medium-to-high-risk business activities.
♦ Articles 26A–28A: Compliance Evaluation and Sanctions
Introduces regular evaluations of business operator compliance. Non-compliance may result in automatic license revocation via the OSS system.
♦ Articles 30A–34: OSS-RBA System Enhancement
OSS must integrate with sectoral databases (e.g., spatial planning, environmental), include a monitoring dashboard, and enable auto-verification for low-risk activities.
♦ Article 143: KKPR Exemption for Early-Stage Mining & Renewable Energy
Spatial Use Approval (KKPR) is not required for survey and exploration stages in mining and renewable energy subsectors, streamlining early-stage permits.
Legal Note
- Legal Basis:
Law No. 6 of 2023 (Omnibus Law)
• Government Regulation No. 5 of 2021
• Government Regulation No. 28 of 2025 (partial amendment) - Effective Date: June 5, 2025
- Transition Period: 90 working days for OSS implementation adjustment
- Attachment to GR 28/2025:
Contains 1,692 risk-classified KBLI codes across 22 sectors.
Highlights include:
• Mining – High risk, requires AMDAL and IUP integration
• Import-Export – Medium to high risk, requires technical verification
• Automotive – Medium to high risk, requires standard certification and technical validation
Commentary
GR 28/2025 marks a fundamental upgrade to OSS-RBA by addressing overlapping licenses and reinforcing regulatory oversight. While the regulation is effective as of June 5, 2025, businesses should monitor the issuance of relevant ministerial regulations that will govern technical implementation. Adjustments to existing licenses and compliance documentation should be made in alignment with these forthcoming sector-specific rules.
Recommended Actions:
- Monitor the issuance of implementing regulations from relevant ministries (e.g., ESDM, Industry, Trade) that detail technical requirements.
- Conduct an internal review of existing business licenses and compliance readiness under the new OSS-RBA framework.
- Prepare to align business documentation (technical, environmental, operational) once sectoral rules are in effect.
Consult legal or regulatory advisors, such as MyLegal Indonesia (www.mylegalindonesia.com), for sector-specific guidance
MyLegal is to provide professional services for environmental and industrial permitting, mining, and legal affairs in Indonesia. The company specializes in helping clients obtain permits and comply with regulations related to environmental protection, mining operations, and other industrial activities.
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