Associations in Indonesia: Key Changes Under the New Minister of Law Regulation
On May 19, 2025, the Minister of Law (“MOL”) issued Regulation No. 18 of 2025 on the Procedures for Submission of Applications for Ratification, Approval of Amendment to the Articles of Association, and Termination of the Legal Entity Status of Associations (the “Regulation”). The Regulation replaces and revokes the Minister of Law and Human Rights Regulation No. 3 of 2016 as amended by Minister of Law and Human Rights Regulation No. 10 of 2019 (the “Previous Regulation”).
The Regulation was issued to enhance service quality and provide legal certainty in the administration of associations (in Indonesian, Perkumpulan or an “Association”), particularly regarding the termination of an Association’s status as a legal entity. The Regulation came into force on May 28, 2025.
Below we set out the key highlights of the Regulation.
♦ Definition of an Association
The Previous Regulation defined an Association as “a legal entity which consists of a group of people established to realize certain common goals and objectives in the social, religious and humanitarian fields and does not distribute profits to its members.” The Regulation introduces a revised definition, referring to an Association as “a legal entity established by a group of people who have the same intentions and goals to develop and empower its members and is non-profit.”
The change in definition suggests the emphasis from broader social, religious, and humanitarian purposes to the development and empowerment of members, while retaining the Association’s non-profit nature.
♦ Application for Association Name Approval
In addition to the requirements as set forth in the Previous Regulation, under the Regulation, applicants submitting for an Association name approval must also provide: (i) a description of the purpose of establishing the Association and the background for the use of the proposed name, and (ii) the address of the Association.
The Regulation further clarifies that the verification process to obtain the Association name approval shall be at most 14 days since the application is submitted to the Directorate General of Legal Administrative Affairs in the Legal Entity Administration System (Sistem Administrasi Badan Hukum or “SABH”).
♦ Association Naming Conventions
The Regulation introduces new provisions related to the naming convention of Associations. The use of regional language or foreign language is allowed, as long as it has historical, customary, cultural, and/or religious value, and using synonyms for Association (e.g., persatuan, ikatan) are allowed as long as it is not used as differentiating words from the name of an already registered Association. For reference, below is a table of the list of criteria that applicants must adhere to for the naming of an Association as of the enforcement of the Regulation.
♦ Application for Approval and Amendment
Under the Regulation, application for an Association’s status as a legal entity must attach a list of Association members who have voting rights in members’ meetings (or other by terms). This also applies to applications for amendments to an Association’s articles of association. Amendments to the articles of association may include changes to the Association’s name, activities, management, legal domicile, and/or other information set out in the articles of association.
Similar with the procedures for other legal entities, applications for an Association’s status as a legal entity and for amendments to its articles of association must be submitted by a notary through the SABH.
Additionally, the Regulation now enforces that applications for the approval of an Association’s status as a legal entity must be submitted within 30 days since the signing of the Association’s deed of establishment.
♦ Application for Termination of an Association’s Status as a Legal Entity
The Regulation introduces provisions governing the termination of an Association’s status as a legal entity. Under applicable laws and regulations, an Association’s legal entity status may be terminated due to, among others, the Association has accomplished its goal or reached the end of its period according to its articles of association or there is a legal and binding court decision ordering the termination of the Association’s status as a legal entity.
Application for such terminations are done by the notary by submitting an electronic application to SABH.
AKSET
Please contact Inka Kirana (ikirana@aksetlaw.com), Thomas P. Wijaya (twijaya@aksetlaw.com), or Giorgio Alexander William Robot (grobot@aksetlaw.com) for further information.
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