Your Indonesian Premises Have No IMB or PBG? PP 28/2025 Lets You Go Straight to SLF

A recurring situation for foreign-owned businesses in Indonesia: the warehouse, shophouse or office you have taken has stood for years, and nobody can produce an IMB for it. The assumption that follows — that licensing cannot proceed until the old permit is reconstructed and converted into a PBG — costs months, and is frequently wrong.

Government Regulation No. 28 of 2025 on Risk-Based Business Licensing provides a far shorter route for buildings that already stand. This article sets out the provision, who can use it, and what remains mandatory. All citations are from the official text at JDIH BPK.

Article 123, and why it is not widely known

Article 123(1) is unambiguous:

A business actor that owns a building which already stands but does not yet hold a building construction permit (IMB)/PBG before this Government Regulation entered into force is not required to obtain a PBG, and may submit an application for SLF directly when applying for or extending an application for a Business Licence and/or PB UMKU through the OSS System.

Three points follow:

• The building must already have stood before PP 28/2025 entered into force. This is not a route for new construction.
• The PBG is not required at all — not deferred, not pursued in parallel.
• The SLF application is filed together with the licence application or extension through OSS, not as a separate earlier process.

Article 123(2) covers the other case: a business actor whose building already stands and already holds an IMB or PBG may likewise apply for SLF directly when applying for or extending a Business Licence or PB UMKU through OSS. Both paths converge on the same place — SLF, through OSS, attached to the licence application.

Where PBG and SLF sit in the licensing chain

Article 12(1) names three basic requirements:

Article 12(2) ties issuance to the location of the activity. Article 12(4) carves out exceptions: in a Special Economic Zone (KEK) the basic requirements are issued by the KEK Administrator, and in a Free Trade Zone (KPBPB) by the authority there.

One limit is frequently overlooked. Article 106 states that PBG and SLF are required for business actors that need to construct a building as a business facility. The operative words are "need to construct". If you are not building anything, you are in a different situation from the outset.

Tenants: Article 13 may exempt you entirely

This is the provision that most often rescues tenants, and the one least often cited. Article 13 reads:

Where the business activity is conducted in a building or trade/services complex used in common and the manager already holds KKPR, PL, PBG and/or SLF, the trade/services business actor is not required to satisfy the basic requirements and may proceed directly to the application for a Business Licence and/or PB UMKU through the OSS System.

So if your operation sits in a mall, an office tower, a shophouse inside a managed complex, or a logistics estate whose manager holds those documents, you do not need to obtain KKPR, PL, PBG or SLF in your own name. You go straight to the licence application.

The action item is simple: ask the manager for copies before signing the lease. If they cannot produce them, you have fallen back to the ordinary route — and that cost and delay belong in your rent calculation, not in a surprise three months later.

How an existing building is assessed for SLF

Article 122(1) provides that SLF must be obtained by the business actor before the building can be used. Article 122(2) states that SLF constitutes fulfilment of the building's functional worthiness.

For buildings that already exist, Article 122(3) sets the mechanism: fulfilment of SLF is based on the results of a functional worthiness inspection carried out by:

• a technical assessor (pengkaji teknis); or
• a technical appraisal team formed by the regional government, comprising the relevant building administration agencies.

What is assessed is the building's present physical condition — structure, fire safety, sanitation, electrical systems — rather than the completeness of a paper trail from decades ago. That is precisely what makes the Article 123 route workable for older premises.

Article 122(4) provides that, in respect of that inspection, the ministry responsible for public works establishes a standard service fee charged to business actors. The regulation does not state amounts, and real costs vary by region and building complexity — check directly with OSS and the local technical agency rather than relying on figures circulating without a source.

Building from scratch: PBG still comes first

The Article 123 relief does not extend to new construction. Article 108(1) requires a business actor to hold a PBG before construction is carried out. Under Article 108(3) the process has two stages: planning consultation and issuance.

Planning consultation itself comprises registration, examination of compliance with technical standards, and a statement of compliance (Article 109(1)). Worth noting: Article 109(2) states that planning consultation is provided free of charge.

Registration is submitted through the OSS System with applicant or owner data, building data, and technical plan documents (Article 110(1)). Technical plan documents are prepared during technical planning under Article 107(1). Proof of payment of the regional levy is then submitted through OSS before the PBG document and its annexes are issued.

Dates, and what was repealed

PP 28/2025 was enacted and promulgated in Jakarta on 5 June 2025, published in State Gazette of the Republic of Indonesia 2025 No. 98. Article 552 provides that it enters into force on the date of promulgation.

Article 550 does two things: existing rules on basic requirements, Business Licences and PB UMKU remain in force so far as they do not conflict with this regulation; and Government Regulation No. 5 of 2021 on Risk-Based Business Licensing is revoked and declared no longer in force.

A practical filter for advice you receive: guidance still treating PP 5/2021 as live law predates June 2025.

Four mistakes that stall the process

1. Chasing a PBG for an old building. For premises standing before PP 28/2025 took effect without an IMB or PBG, Article 123(1) says the PBG is not required. Pursuing it wastes months.
2. Treating SLF as a standalone earlier process. Article 123 places the SLF application alongside the licence application or extension in OSS.
3. Tenants doing the basic requirements when Article 13 applies. Check the building manager's documents first.
4. A KBLI that does not match the activity at the site. Basic requirements and sector licensing both attach to the classification; an approximate code early becomes a correction everywhere later.

IzinBeres has handled licensing for more than 6,000 clients since 2014, and "old building, no IMB" is among the most common files we open. Our office is at Ruko South Sorrento Square No. 18, Gading Serpong, Kab. Tangerang, Banten 15332, 09.00–19.00 WIB, seven days a week.

FAQ

Our building was constructed in 2010 with no IMB. Must we obtain a PBG first?

No. Article 123(1) of PP 28/2025 provides that a business actor with a building that already stood but held no IMB or PBG before the regulation entered into force is not required to obtain a PBG, and may apply for SLF directly when applying for or extending a Business Licence or PB UMKU through OSS.

Our building has an old IMB. Must it be converted to a PBG?

Article 123(2) provides the same route: a building that already stands and already holds an IMB or PBG may apply for SLF directly when applying for or extending a Business Licence or PB UMKU through the OSS System.

We lease a unit in a mall. Do we need our own SLF?

Most likely not. Article 13 provides that a trade or services business actor in a shared building or complex whose manager already holds KKPR, PL, PBG and/or SLF need not satisfy the basic requirements and may proceed directly to the licence application. Ask the manager for copies as evidence.

Who inspects an existing building?

Under Article 122(3), the inspection is carried out by a technical assessor or by a technical appraisal team formed by the regional government from the relevant building administration agencies.

How much does it cost?

PP 28/2025 states no figures. Article 122(4) provides that the ministry responsible for public works sets a standard service fee for the inspection, while PBG levies are set regionally. Check directly with OSS and the local technical agency. One point in your favour: planning consultation for PBG is provided free of charge under Article 109(2).

Is PP 5/2021 still in force?

No. Article 550(b) of PP 28/2025 revokes it and declares it no longer in force as of the date PP 28/2025 took effect, 5 June 2025.

Sources

• JDIH BPK — Government Regulation No. 28 of 2025 on Risk-Based Business Licensing (Arts. 12, 13, 106, 107, 108, 109, 110, 122, 123, 550, 552; State Gazette 2025 No. 98)
• OSS Institution — oss.go.id