The implementation of the Risk-Based Approach (RBA) in Indonesia's Online Single Submission (OSS) system has fundamentally shifted the paradigm of business licensing. For PMA companies, understanding these changes is no longer optional—it is critical for survival.
Since the enactment of the Job Creation Law (Omnibus Law), the Indonesian government has moved from a "license-based" to a "risk-based" licensing regime. This means the level of regulatory scrutiny is now directly proportional to the risk level of your business activities.
1. Understanding Risk Levels
Under the current OSS RBA system, business activities (KBLI) are categorized into four risk levels:
- Low Risk: Requires only an NIB (Business ID Number) to start operations.
- Medium-Low Risk: Requires NIB and a Self-Declaration of standards.
- Medium-High Risk: Requires NIB and verification of standards (Standard Certificate).
- High Risk: Requires NIB and a full License (Izin) with government approval.
2. Key Compliance Steps for 2025
Foreign investors must ensure their LKPM (Investment Activity Report) is submitted quarterly. Failure to do so for two consecutive periods can result in the revocation of your NIB. Furthermore, ensure that your realized capital meets the minimum requirement of IDR 10 Billion (excluding land and buildings).
3. Conclusion
While the system aims to simplify bureaucracy, the initial setup requires precision. Choosing the wrong KBLI code can lead to unnecessary high-risk classifications and prolonged licensing delays. We recommend conducting a comprehensive legal audit before submission.