OSS RBA after PP 28/2025: Major Regulatory Changes Creating New Opportunities and Challenges

Understanding Indonesia's Latest Business Licensing Framework

Indonesia continues to modernize its investment and business licensing environment through significant regulatory reforms. One of the most important developments affecting investors, entrepreneurs, consultants, and corporate service providers is the implementation of OSS RBA after PP 28/2025.

The latest adjustments to Indonesia's Online Single Submission Risk-Based Approach (OSS RBA) framework introduce important updates to licensing procedures, business classification requirements, investment regulations, and compliance obligations. These changes affect both domestic companies and foreign investment companies (PT PMA) operating across various sectors.

Understanding OSS RBA after PP 28/2025 is essential for businesses that wish to remain compliant while avoiding licensing delays, regulatory issues, and administrative complications.

This article explains the key changes introduced under OSS RBA after PP 28/2025, how they affect business licensing, and what companies should do to prepare.

The Connection Between OSS RBA after PP 28/2025 and KBLI 2025

One of the most significant developments accompanying OSS RBA after PP 28/2025 is the implementation of KBLI 2025.

KBLI (Klasifikasi Baku Lapangan Usaha Indonesia) serves as Indonesia's official business classification system.

Starting from the implementation of KBLI 2025, business actors must ensure that:

• Company purposes and objectives match selected KBLI codes
• OSS licensing reflects actual business activities
• Articles of Association remain aligned with operational activities
• Future amendments follow the latest classification standards

The integration of KBLI 2025 into OSS RBA after PP 28/2025 means that businesses can no longer rely on outdated classifications when establishing or modifying corporate structures.

The Expanded Role of Notaries

One topic highlighted during socialization sessions regarding OSS RBA after PP 28/2025 is the increasing importance of notaries.

Notaries are now expected to carefully verify:

Identity of Founders

Verification includes:

• KTP data
• Passport information
• Tax identification data
• Contact details
• Email addresses

Business Activities

Business activities selected within company documents must accurately reflect the intended commercial operations.

Capital Structure

The company's capital structure must also comply with applicable investment regulations.

The increased role of notaries under OSS RBA after PP 28/2025 aims to improve legal certainty and reduce inconsistencies between company documents and OSS licensing data.

New Business Activity Structure

Another important feature introduced under OSS RBA after PP 28/2025 is the distinction between primary and supporting business activities.

Businesses are now expected to clearly identify:

Primary Business Activities

Primary activities are the main revenue-generating activities of the company.

These activities become the core purpose of the business and generally determine the company's primary licensing obligations.

Supporting Business Activities

Supporting activities help facilitate or complement the main business operations.

However, supporting activities must remain relevant to the primary business activity.

Under OSS RBA after PP 28/2025, regulators are placing greater emphasis on ensuring that supporting activities are genuinely connected to the company's main operations.

Introduction of Special KBLI Categories

One of the more technical but significant developments under OSS RBA after PP 28/2025 is the introduction and clarification of special KBLI categories.

These categories include:

Single Purpose

A Single Purpose company may only conduct specific business activities identified by regulation.

Certain sectors require the company to focus exclusively on one designated business purpose.

The concept of Single Purpose entities becomes increasingly relevant within OSS RBA after PP 28/2025, especially in regulated industries.

Limited Purpose

Limited Purpose business entities may conduct only certain approved activities.

This concept commonly appears in highly regulated sectors such as healthcare and public service industries.

Businesses operating under Limited Purpose classifications must ensure that all activities remain within the permitted scope under OSS RBA after PP 28/2025.

Single Majority

Single Majority classifications relate to sectors where foreign ownership restrictions remain applicable.

In these situations, Indonesian shareholders must maintain majority ownership.

The clarification of Single Majority classifications under OSS RBA after PP 28/2025 provides greater certainty for investors evaluating ownership structures.

Impact on PT PMA Companies

Foreign investment companies should pay particular attention to OSS RBA after PP 28/2025.

PT PMA companies often operate in sectors that involve:

• Foreign ownership limitations
• Additional licensing requirements
• Sector-specific regulations
• Investment reporting obligations

The implementation of OSS RBA after PP 28/2025 may affect:

• Company establishment
• Business expansion
• Shareholder restructuring
• Additional business activities
• Licensing amendments

Foreign investors should carefully review whether their current KBLI classifications remain suitable under the new framework.

Changes to Business Licensing Procedures

One objective of OSS RBA after PP 28/2025 is to improve consistency between business licensing and actual business activities.

Businesses may experience increased scrutiny when:

• Applying for new licenses
• Expanding operations
• Adding KBLI codes
• Amending Articles of Association
• Updating shareholder structures

Authorities may verify whether selected KBLI codes genuinely reflect the company's operations.

This verification process under OSS RBA after PP 28/2025 aims to prevent misuse of business classifications.

KKPR and Spatial Planning Integration

Another topic emphasized within OSS RBA after PP 28/2025 is the integration of KKPR (Land Utilization Suitability Confirmation).

Businesses seeking operational licenses may need to demonstrate compliance with:

• Zoning regulations
• Spatial planning requirements
• Land use restrictions
• Regional development plans

This integration supports better coordination between investment licensing and land-use governance.

As a result, OSS RBA after PP 28/2025 encourages businesses to assess land suitability before committing to investments.

AMDALNET and Environmental Compliance

Environmental licensing remains a critical component of OSS RBA after PP 28/2025.

Businesses in sectors with environmental impacts may be required to utilize AMDALNET and related environmental systems.

Requirements may include:

• Environmental approvals
• Environmental management plans
• Environmental monitoring obligations
• Sector-specific environmental permits

Compliance with environmental regulations remains essential under OSS RBA after PP 28/2025.

Continued Importance of LKPM Reporting

Investment reporting remains a major obligation under OSS RBA after PP 28/2025.

LKPM (Investment Activity Report) continues to play an important role in monitoring investment realization throughout Indonesia.

Companies that fail to submit LKPM reports may encounter:

• Administrative warnings
• Licensing complications
• Increased regulatory scrutiny
• Difficulties processing amendments

Businesses should ensure that LKPM compliance remains part of their overall strategy under OSS RBA after PP 28/2025.

Potential Challenges for Businesses

While OSS RBA after PP 28/2025 aims to simplify licensing, businesses may face several transitional challenges.

Common issues include:

• Incorrect KBLI classifications
• Mismatch between company documents and OSS data
• Ownership structure complications
• Incomplete licensing records
• Unreported supporting business activities

These challenges highlight the importance of conducting a compliance review.

Opportunities Created by OSS RBA after PP 28/2025

The reforms also create positive opportunities.

Businesses that properly adapt to OSS RBA after PP 28/2025 may benefit from:

• Faster licensing processes
• Improved legal certainty
• Better regulatory transparency
• Stronger investor confidence
• Easier business expansion
• Reduced administrative disputes

For many companies, proactive compliance can become a competitive advantage.

Practical Steps Businesses Should Take

To prepare for OSS RBA after PP 28/2025, companies should consider the following actions:

• Review existing KBLI codes
• Verify OSS licensing data
• Review Articles of Association
• Evaluate ownership structures
• Check LKPM compliance
• Review environmental obligations
• Assess zoning and KKPR requirements
• Prepare for future amendments

Conducting a comprehensive compliance review can help identify potential risks before they become regulatory problems.

Navigating the Future of Business Licensing in Indonesia

The implementation of OSS RBA after PP 28/2025 represents another major step in Indonesia's effort to create a more transparent, efficient, and investor-friendly licensing system.

Businesses operating in Indonesia should not view these changes as merely administrative updates. The integration of KBLI 2025, special business classifications, licensing verification, environmental compliance, and investment reporting demonstrates the government's commitment to strengthening corporate governance and regulatory oversight.

Whether you operate a PT PMA, local PT, hospitality business, construction company, trading company, healthcare facility, or technology startup, understanding OSS RBA after PP 28/2025 is essential for maintaining compliance and supporting sustainable business growth.

Companies that proactively align their operations with OSS RBA after PP 28/2025 will be better positioned to navigate future regulatory developments and capitalize on Indonesia's growing investment opportunities.