The Government Regulation No. 28 of 2025 (GR 28/2025) marks a significant transformation in Indonesia’s business licensing system. As part of the country’s ongoing regulatory reform agenda, this new regulation refines the risk-based business licensing approach introduced by GR 5/2021. With a focus on streamlining procedures and broadening regulatory oversight, GR 28/2025 impacts multiple sectors and imposes new obligations on businesses seeking to complete company registration in Indonesia.
Whether you are a foreign investor, a local entrepreneur, or a legal consultant, understanding GR 28/2025 is critical. The regulation not only affects how your business is categorized under the risk-based system but also expands the scope of compliance across new industrial sectors. For those initiating or updating their company registration in Indonesia, the implications of GR 28/2025 must be assessed carefully.
Understanding the Reform in Licensing Under GR 28/2025
Why GR 28/2025 Was Introduced
Indonesia’s regulatory reform efforts are designed to simplify investment procedures, foster economic growth, and increase ease of doing business. GR 28/2025 complements previous legal reforms by refining definitions of business risks, updating licensing criteria, and expanding the scope of sectors covered under the Online Single Submission (OSS) system.
In essence, the government seeks to bridge existing gaps, provide legal certainty, and facilitate smoother processes for company registration, while safeguarding public welfare and the environment through updated risk assessments.
Expansion of Regulated Sectors
One of the most impactful changes in GR 28/2025 is the expansion of sectors requiring licensing. Under this regulation, 22 new business sectors have been added to the existing licensing framework, bringing the total to 327. These include diverse sectors such as:
- Electric motor vehicle production
- Employment placement services
- Pharmaceutical product marketing authorization holders (Holders of Nomor Izin Edar – NIE)
The expansion directly affects business actors previously operating without the need for OSS licensing or those who were categorized under low-risk businesses. As a result, entities that plan to complete their company registration in Indonesia must now evaluate if their sector falls under these updated categories.
New Licensing Layers Based on Risk Levels
GR 28/2025 further elaborates on the categorization of businesses into low, medium-low, medium-high, and high-risk levels. Each risk level corresponds with specific licensing obligations:
- Low Risk: Requires only a Business Identification Number (NIB)
- Medium-Low Risk: NIB + Standard Certificate (self-declared)
- Medium-High Risk: NIB + Standard Certificate (verified)
- High Risk: NIB + Business License
This tiered licensing framework affects the timing and complexity of company registration in Indonesia. Businesses may need to prepare supporting documents such as environmental approvals or building permits, depending on their assigned risk level.
Legal and Administrative Implications for Business Actors
Stronger Legal Sanctions
GR 28/2025 introduces clearer enforcement measures for businesses operating without proper licensing. Administrative sanctions now include warnings, temporary suspension of activities, blacklisting, and revocation of business licenses.
Companies must ensure their licensing documentation aligns with the OSS system and the updated sector classifications. Failure to do so during or after company registration Indonesia could result in delays, fines, or legal disputes.
Coordination Between Ministries and Regional Governments
A notable element of GR 28/2025 is the mandated coordination between central and regional authorities. Regional governments are now explicitly required to adjust local licensing regulations in accordance with GR 28/2025 within six months of its enactment. For companies seeking regional permits, this could temporarily complicate company registration as different jurisdictions adjust to the national framework.
Impact on Foreign Investors and PT PMA Registration
Additional Scrutiny for Foreign-Owned Entities
Foreign investors establishing a PT PMA (foreign-owned company) in Indonesia must now consider the expanded list of regulated sectors and risk-based assessments. For instance, foreign ownership in certain sectors may trigger higher risk levels, resulting in stricter licensing obligations and longer processing times.
OSS Adjustments and Real-Time Monitoring
The OSS system has been updated to reflect GR 28/2025’s risk adjustments and sector expansion. The system now integrates real-time risk level assessments and licensing pathways. PT PMA applicants must navigate this enhanced OSS interface to complete their company registration in Indonesia, which may require legal consultation or advisory support.
Strategic Considerations for Company Registration Post-GR 28/2025
Legal Due Diligence Is Now Essential
Given the sweeping changes, legal due diligence during the company registration phase has become more critical. Business founders must examine whether their proposed business activities fall into newly regulated categories and what risk level applies.
Legal professionals and compliance advisors are vital in helping navigate this landscape, ensuring businesses obtain the correct licenses and avoid future complications.
Role of Corporate Secretarial Services
To stay compliant with GR 28/2025, many businesses are relying on Corporate Secretarial Services to handle administrative updates, filings, and communications with the OSS system. This support is particularly crucial for foreign entities or multi-branch companies that face more complex bureaucratic requirements.
CPT Corporate’s Company Registration Service
Navigating the intricacies of GR 28/2025 can be daunting, especially for new businesses and foreign investors. CPT Corporate offers expert Company Registration services tailored to help you adapt to these regulatory changes. Our legal consultants provide end-to-end support—from risk classification analysis and OSS registration to obtaining licenses and Standard Certificates. With our deep understanding of Indonesia’s legal framework and commitment to compliance, we help ensure your company registration process runs smoothly and legally sound.
Conclusion
The implementation of GR 28/2025 represents a major shift in how businesses are regulated in Indonesia. From the expanded sector list and revised risk assessments to stricter enforcement and system integration, these changes directly impact how company registration in Indonesia must be approached. Business actors must stay informed, conduct legal audits, and seek expert assistance to remain compliant.
As the regulatory environment continues to evolve, aligning your business with updated legal standards is not just a formality—it’s a strategic necessity.
Need help navigating your company registration under GR 28/2025? Contact CPT Corporate today to ensure your business complies with Indonesia’s latest legal requirements and gets the support it needs to thrive. Contact us to learn more or schedule a consultation with our legal team.
