Government Pushes Back Risk-based OSS System Launch

Following up on the Ministry of  Investment or Capital Investment Coordinating Board’s (“BKPM”) decision to launch the Risk-based Licensing Online Single Submission System (“Risk-based OSS System”)  through its Circular Letter No. 17 of 2021 on the Shift of Business Licensing System to Risk-based Business Licensing through the OSS System dated July 27, 2021 (“CL 17/2021”), the government has decided to postpone  the implementation of the Risk Based OSS system as stipulated in Circular Letter No. 18 of 2021 on Amendment to CL 17/2021 (“CL 18/2021”) dated July 29, 2021 and BKPM Announcement No. 8 of 2021 dated August 2, 2021 (the “Announcement”).

The initial plan was to launch the Risk-based OSS System with a majority of the KBLI Codes under Government Regulation No. 5 of 2021 on the Implementation of Risk-based Licensing dated February 2, 2021 (“GR 5/2021”) while relying temporarily on a BKPM Decree for the 353 KBLI codes not yet accounted for in the system. However, there are several changes and revisions to the list of 353 KBLI codes as can be seen in CL 18/2021, such as Account and Audit Activities being placed under the Ministry of Finance (previously under Ministry of Tourism and Creative Economy), Toll Road Activities being under the Ministry of Public Works and Public Housing (previously under Ministry of Transport) and various other changes. The Announcement then explains that since there are revisions to the KBLI codes, the system must be updated accordingly.

As the current OSS system has already been suspended in preparation for the initial launch, the BKPM has decided that business licensing will be temporarily suspended until the system is up and running. Currently, there is no detail as to when the Risk-based OSS will launch.

We expect to hear more about the hopefully imminent launch of the Risk-based OSS System in the near future.



August 3, 2021

Please contact Inka Kirana (, N. Sekar Lestari ( or Caleb K. N. Sitorus ( for further information.



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