Regulation Watch · Business Licensing · Indonesia
Indonesia's New OSS Business Licensing Framework
OSS has opened the 1–15 October 2026 LKPM window, making 15 October the filing deadline for Q3 reports from medium and large businesses under BKPM Regulation 5/2025.
- Published
- PP 28/2025 was established and promulgated on 5 June 2025. BKPM Regulation 5/2025 was established on 1 October and promulgated on 2 October 2025 in State Bulletin 2025 No. 738. OSS published the Q3 2026 filing notice on 1 October 2026.
- Effective
- PP 28/2025 took effect on 5 June 2025 and BKPM Regulation 5/2025 took effect on 2 October 2025. The Q3 2026 LKPM filing window runs from 1 through 15 October 2026.
- Updated
- 5 October 2026
Who is affected
Medium and large Indonesian businesses with an NIB, including PT PMA and PT PMDN companies at the preparation or operational/commercial stage; their directors, foreign and domestic shareholders, finance and compliance teams, and advisers responsible for OSS and investment reporting. The report is required for each business activity and project location. Micro businesses and activities funded by the national or regional budget are exempt from this LKPM obligation.
Practical impact
The official OSS notice confirms that the Q3 2026 reporting window is open through 15 October. Medium and large businesses must file through OSS for every registered business activity and location, reporting investment realization, workforce, production or services, licensing compliance, investment obligations and operational constraints. OSS issues a receipt, but the competent authority may request corrections; corrections can only be submitted before the reporting window closes. The notice also refers to Semester II reporting, but BKPM Regulation 5/2025 sets the statutory Semester II deadline for small businesses at 15 January 2027, so a small business should follow the period shown in its OSS dashboard and resolve any inconsistent task with OSS or the competent DPMPTSP.
Implementation update published 1 October 2026: OSS has opened the LKPM reporting period from 1 through 15 October. For medium and large businesses, this is the Q3 report covering July through September. BKPM Regulation 5/2025 requires an LKPM for every business activity and location after the business obtains its NIB, including both the main and supporting activities.
The filing is more than a headline investment total. It includes investment realization, Indonesian and foreign workforce, production or service realization, fulfillment of basic requirements, business licences and PB UMKU, investment obligations and responsibilities, and constraints faced by the business. Companies should reconcile these figures to their accounting, payroll, licensing and project records before submission.
Medium and large businesses report quarterly whether the project is still in preparation or is operational/commercial. A business that has started commercial activity should make sure the OSS project status and operational-readiness declaration are current rather than continuing to report it indefinitely as a preparation-stage project.
The Q3 deadline is 15 October 2026. OSS issues a receipt when the report is submitted, and the competent authority evaluates it through OSS. If a correction is requested, the company may correct the report only until the reporting period ends. Filing on the last day therefore leaves little time to resolve data or system issues.
The OSS notice also refers to Semester II reporting. Article 286 of BKPM Regulation 5/2025, however, sets 15 January 2027 as the statutory deadline for the July–December Semester II report of small businesses. A small company that sees a conflicting October task should follow its actual OSS dashboard and obtain clarification from OSS or its competent DPMPTSP instead of assuming that the Q3 deadline applies to it.
Non-filing is linked to graduated sanctions. Missing two consecutive reporting periods can trigger a first warning; repeated failure can move through further warnings to temporary suspension, a fine and ultimately revocation of the relevant business licence. Directors and compliance teams should keep the OSS receipt, supporting reconciliation, reviewer approval and any correction correspondence in the company's compliance file.
The broader licensing framework remains unchanged: PP 28/2025 replaced PP 5/2021, and BKPM Regulation 5/2025 provides the operational OSS procedures. Businesses should continue reviewing each project's KBLI, risk level, basic approvals, business licence, PB UMKU and transition treatment rather than assuming that an NIB alone completes the licensing position.
Required action
- Log in to OSS now and identify every project, KBLI and location for which the company has a Q3 2026 LKPM task; do not assume one consolidated company report covers all activities or locations.
- Reconcile July–September investment realization to the fixed-asset register, construction and fit-out invoices, capital and funding records, and prior cumulative LKPM figures before entering the report.
- Update Indonesian and foreign workforce figures, production or service realization, licensing and PB UMKU status, investment obligations, environmental and employment compliance, CSR or partnership data where applicable, and operational constraints.
- Confirm whether each project is still in preparation or has become operational/commercial, and complete the OSS operational-readiness declaration where the company has started commercial activity.
- Submit early enough to retain the OSS receipt, monitor the dashboard for an approval or correction request, and complete any correction no later than 15 October 2026.
- For any small-business Semester II task displayed in OSS, verify the applicable period against Article 286 of BKPM Regulation 5/2025 and obtain clarification from OSS or the competent DPMPTSP if the dashboard conflicts with the statutory 15 January 2027 deadline.
- Separately review each KBLI's current risk classification, basic requirements, business licence, PB UMKU and transition status under PP 28/2025 rather than relying on the former PP 5/2021 framework.