Key New Regulations and Policies in 2025 Affecting Business in Indonesia

I. Government Regulation (PP) No. 8 of 2025 – Mandatory Placement of Natural Resource Export Proceeds (DHE SDA) in Domestic Banks.

1) Brief Description

• Effective March 1, 2025.

• Exporters of natural resources (mining except oil & gas, plantations, forestry, fisheries) must place 100% of export proceeds in Indonesian banks.

• Goal: strengthen foreign exchange reserves, stabilize the rupiah, and ensure export earnings circulate domestically.

• Business impact: affects cash flow for exporters used to holding export proceeds overseas. Requires adjustments in financial systems and liquidity management.

2) General implications that “MAY” affecting on Finance Accounting & Taxation, Legal, and Immigrations Service industries:

a. Accounting & Financial Reporting

• Foreign-exchange treatment

• If receive fees from natural-resource exporters that must now pay from domestic-currency accounts, timing of foreign-currency settlements may change.

• May need to adjust recognition of FX gains/losses if more client payments arrive in rupiah instead of foreign currency.

• Banking relationships.

• Any funds that hold temporarily on behalf of clients (escrow, retainer deposits) may need to be placed with Indonesian banks to stay compliant if those funds are sourced from export proceeds.

• Internal controls: update policies to ensure segregation of client money that falls under the DHE rule.

b. Taxation

• Withholding & VAT:

  - If more client invoices are paid from rupiah accounts, check that VAT and withholding tax calculations reflect correct exchange rates on payment dates (not just invoice dates).

  - Possible higher exposure to final tax on foreign-exchange gains.

• Corporate income tax:

  - No new obligation, but more domestic-currency transactions may slightly affect taxable profit calculation and deferred-tax positions.

c. Legal / Compliance

• Engagement contracts:

  - Review engagement letters to ensure payment clauses accommodate the requirement that clients’ export proceeds must first settle in domestic banks.

  - Add clauses clarifying who bears any regulatory risk or penalties if client funds subject to DHE rules pass through internal trust or client accounts.

• Regulatory reporting:

  - If any internal operate client trust or escrow accounts, confirm whether Bank Indonesia reporting duties (e.g., monthly DHE reports) apply when handling export-proceeds funds.

d. Visa / Immigration Services

• Work-permit administration

  - No direct change in visa rules.

  - Indirectly, if any foreign specialists are paid from funds classified as export proceeds, ensure employment contracts and payroll documentation reflect payments from Indonesian banking sources.

3) Key Internal Actions:

• Update accounting policies for FX recognition and client-fund segregation.

• Revise tax procedures for exchange-rate determination on VAT/withholding.

• Amend standard legal templates to cover DHE-related payment terms and liabilities.

• Conduct a compliance review to verify whether any of your trust or escrow arrangements fall within Bank Indonesia’s DHE reporting scope.

4) Final conclusions:

PP No. 8/2025 does not impose direct obligations on a finance, tax, legal, and visa service firm, but it can affect your internal accounting entries, tax calculations, and client-fund handling if you receive or manage money derived from regulated export proceeds. Tightening internal controls and contract language is the primary safeguard.

II. PP No. 28 of 2025 – Risk-Based Business Licensing (OSS-RBA).

1) Brief Description:

• Simplifies licensing: sets clear service-level agreements, introduces automatic approval (“positive fiction”) if agencies fail to respond within a set time, and requires all licensing through the OSS-RBA platform.

• Full enforcement begins October 5, 2025, after a transition period.

• Business impact: faster licensing and greater legal certainty, especially beneficial for MSE’s (Medium & Small Enterprises). Transition may require system upgrades and inter-agency coordination.

2) General implications that “MAY” affecting on Finance Accounting & Taxation, Legal, and Immigrations Service industries:

a. Accounting and financial reporting:

• Licensing-related costs:

  - Any future branch office, representative office, or service-line expansion will require all permits to go through OSS-RBA.

  - May need to adjust capitalization or expense recognition if fees are paid online in stages or refunded automatically when an application is rejected/approved by “positive fiction.”

  - Budgeting becomes easier because service-level agreements (SLA) give predictable timelines and fees.

• Internal controls:

  - Payment records and evidence of approvals must be stored digitally to match the OSS platform’s reporting format.

  - Periodic reconciliation between your general ledger and OSS fee receipts is advisable for audit readiness.

b. Taxation:

• Timely compliance:

  - Faster licensing means you can commence billable operations (new office, new service line) sooner, which may accelerate the start of tax obligations (VAT, corporate income tax registration).

  - Ensure tax registration aligns with the exact approval date issued by OSS to avoid mismatched reporting periods.

• Electronic documentation:

  - Digital licensing data can be directly linked to e-Faktur or e-SPT systems; your tax team should integrate or cross-check these datasets.

c. Legal/ Compliance:

• Entity & permit management:

  - All corporate permits—principal license, branch office license, updates to Articles of Association—must now be submitted and stored in the OSS-RBA system.

  - Engagement letters with clients may need updated representations/warranties about their compliance with OSS-RBA timelines and automatic approvals.

  - For legal teams should track SLA deadlines to leverage the “fiktif positif” clause (automatic approval if the authority misses the deadline).

• Risk & dispute considerations:

Positive-fiction approvals still carry potential challenges if an agency later disputes the automatic license. Prepare standard operating procedures to document every OSS submission and system log to defend your legal standing.

d. Visa / Immigration Services:

• Integration with foreign-staff licensing:

  - Work permits (RPTKA/IMTA) and related business licenses for foreign experts will route through OSS-RBA.

  - Your visa team must coordinate timelines so immigration filings match the accelerated licensing schedule and avoid overlap or expiry gaps.

3) Key Internal Actions:

• Digital readiness: Train staff on the OSS-RBA platform, including data security and document retention requirements.

• Policy updates: Align internal SOPs so tax registration, accounting entries, and legal documentation all use the OSS license date as the “start of business.”

• Compliance calendar: Create an SLA-based licensing tracker to monitor statutory deadlines and automatic-approval windows.

• Contingency planning: Establish procedures for challenging or clarifying “positive fiction” approvals if government agencies later contest them.

4) Final conclusions:

PP No. 28/2025 does not add new financial burdens, but it changes how business acquired, renewed, and evidences licenses. The main impacts are internal—digital documentation, tighter synchronization of accounting/tax dates with electronic license approvals, and careful legal monitoring of automatic approvals to protect internal operating rights.

III. Ministry of Trade Regulation (Permendag) No. 15 of 2025 – Trade Sector Standardization.

1) Brief description:

• Sets stricter standards for product quality, safety, health, environment, and workforce competence.

• Protects consumers and encourages domestic products to meet higher standards, aiding export readiness.

• Business impact: potential additional costs for companies whose products don’t yet meet standards but creates opportunities to access markets demanding higher quality.

2) General implications that “MAY” affecting on Finance Accounting & Taxation, Legal, and Immigrations Service industries:

a. Accounting and financial reporting:

• Compliance-related expenditures:

  - If a firm must obtain or maintain any professional or service-quality certifications (for example ISO standards for data security, office safety, or staff competence) to meet the new regulation, related audit and certification fees should be capitalized or expensed in line with accounting standards.

  - Potential need to track and depreciate new equipment or facility upgrades required for health, safety, or environmental compliance (e.g., workplace ergonomics, fire-safety upgrades).

• Internal controls:

  - Strengthen documentation of quality-management processes and staff training records so that any certification audits can be supported with verifiable financial evidence.

b. Taxation

• Deductibility of compliance costs:

  - Costs for mandatory certifications, training programs, and facility improvements are generally deductible, but your tax team should confirm treatment (capital vs. operating expense) and ensure proper supporting documentation for tax authorities.

  - If new certification results in reclassification of assets (e.g., office renovations to meet environmental standards), adjust depreciation schedules and deferred-tax calculations accordingly.

c. Legal / Compliance

• Service-quality requirements:

  - The regulation’s “workforce competence” clause could impose formal qualification standards on professionals delivering accounting, tax, or legal services. Ensure all staff licenses and professional certifications meet any new benchmarks.

  - Review employment contracts and HR policies to include mandatory training obligations and to document compliance with safety, health, and environmental provisions.

  - Update client engagement letters to reflect that your firm adheres to the new trade-sector quality standards, providing assurance of compliance in service delivery.

• Contractual risk:

  - If a sub-contract work (e.g., visa processing partners or freelance legal counsel), it may need clauses requiring those parties to maintain the same standardization certifications.

d. Visa / Immigration Services

• Staff qualification checks:

  - For foreign professionals you sponsor, ensure their credentials and professional certifications satisfy the new competence standards, as immigration authorities may reference these domestic requirements when issuing work permits.

  - Maintain a centralized record of staff training and certifications to support visa renewals or audits.

3) Key internal actions:

• Gap assessment: Conduct an internal audit comparing current workplace safety, environmental measures, and staff credentials against the new Ministry of Trade standards.

• Policy & training updates: Create or enhance staff-training programs and maintain detailed attendance/competency records.

• Financial planning: Budget for certification costs, facility upgrades, and recurring audits, and incorporate them into annual financial forecasts.

• Legal templates: Amend contracts with clients and subcontractors to include representations of compliance with the new standardization rules.

4) Final Conclusions:

Permendag No. 15/2025 primarily targets goods and trade, but service providers like professional firms may still affected through workplace safety, environmental, and staff-competence requirements. The key impacts are internal: verifying employee qualifications, updating legal documentation, properly accounting for certification and training costs, and ensuring tax deductibility of any compliance expenditures.