TL;DR
Hukumonline's Legal Intelligence report dated 7 October 2026 says the investment ministry/BKPM is preparing a revision to Ministerial Regulation…
The Facts
A reported revision is still a proposal
Hukumonline's Legal Intelligence report dated 7 October 2026 says the investment ministry/BKPM is preparing a revision to Ministerial Regulation 5/2025. It attributes the announcement to Deputy for Investment Planning Ichsan Zulkarnaen and describes clearer, measurable service time standards among the changes being prepared. Hukumonline report.
The accessible report supports a story about preparation. It does not establish a new enforceable processing deadline for a particular Bali business application. Its full analysis requires subscriber access, so this article does not claim to have reviewed material behind that access restriction.
For a PT PMA planning a restaurant, shop or another activity, that distinction matters: a reported reform should not become an assumed opening date in a lease or operating budget.
SLA is not a new concept in OSS
BKPM's own explanation of PP 28/2025 already describes Service Level Agreements and defined licensing timelines. Its official June 2025 guidance also explains fiktif positif, or deemed approval, for qualifying complete applications that are not acted on within the applicable deadline. BKPM: PP 28/2025 implementation. BKPM: fiktif positif.
It would therefore be misleading to say the planned revision introduces licensing time limits for the first time. The question is what the final amendment changes within the existing framework.
This publication has not verified a final amendment text implementing the reported proposal. An announcement alone is insufficient evidence that new conditions apply to an application.
What to check when a final text appears
Compare the instrument's number, publication details and effective-date clause. Do not assume every rule begins on the day a news article appears. Then identify whether its provisions cover the particular licence, sector, risk category and processing stage involved.
Ask separately how it treats applications already submitted. A change affecting new applications may not settle the treatment of an older file. Any transition provisions need to be read before revising a project schedule.
These are review questions for the eventual text, not predictions about what the ministry will enact.
What a business can prepare now
Create one application record containing the submission reference, dated acknowledgements, document requests and responses. Name the person responsible for monitoring messages and keeping the record current.
Distinguish time spent completing the applicant's documents from time awaiting an authority's action. That makes a follow-up clearer and avoids presenting an incomplete submission as a fully processed application.
When discussing a commercial opening date, identify which permissions remain outstanding and what evidence will demonstrate completion. Avoid promising a shorter timeline solely because a revision is being discussed.
Bali Zero take
The practical benefit of better service standards is predictability. Until the reported revision can be checked against a published instrument, keep planning tied to the current application record and requirements.
Source distinction: the planned revision is reported by Hukumonline; the existing SLA and fiktif-positive framework is documented by BKPM. This is a policy-development update, not notice that a new licensing deadline has taken effect.
Bali Zero Take
Our Analysis
The practical benefit of better service standards is predictability. Until the reported revision can be checked against a published instrument, keep planning tied to the current application record and requirements.
Source distinction: the planned revision is reported by Hukumonline; the existing SLA and fiktif-positive framework is documented by BKPM. This is a policy-development update, not notice that a new licensing deadline has taken effect.
Primary Source
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