The construction schedule can be neatly arranged, but the Environmental Approval (PL) often becomes the most unpredictable part. Government Regulation Number 28 of 2025 concerning the Implementation of Risk-Based Business Licensing, established on June 5, 2025, now specifies deadlines for almost every stage of the PL. The unit is "Days," which according to Article 1 number 26 means working days.
Here are the figures, along with one often overlooked aspect: the fate of the time count when your documents are returned for corrections.
Amdal Path: from administrative check to SK
The examination of the terms of reference form still follows the regulations in the environmental field (Article 86 paragraph (3)). In PP 22/2021 Article 38 paragraph (3), the examination lasts a maximum of 10 working days from the complete receipt of the form. After the Andal and RKL-RPL are completed, the PL application is submitted through the OSS System.
| Stage | Deadline | Basis (PP 28/2025) |
|---|---|---|
| Administrative assessment | 3 Days from the application received by OSS | Article 87 paragraph (2) |
| Administrative correction | You 3 Days, re-evaluated 1 Day | Article 88 |
| Substantive assessment, feasibility test, recommendation | 50 Days from being declared complete and correct | Article 93 paragraph (1) |
| Correction of Andal and RKL-RPL | You 30 Days, evaluated 10 Days | Article 90 |
| Establishment of SKKL or unfeasibility | 10 Days from the recommendation received | Article 93 paragraph (4) |
The same procedure applies to amendments to Andal and/or RKL-RPL (Article 94).
UKL-UPL Path: the calculations are much shorter
- Administrative examination: 1 Day. If the document is declared incorrect, you have 1 Day to correct it, then the correction is checked for 1 Day (Articles 96 and 97).
- Substantive examination: automatically through OSS for specific standard forms of low to medium risk. For medium-high and high risks, the limit is 3 Days (specific standard forms) or 5 Days (standard forms). If the technical approval is processed simultaneously, the limit is 15 Days (Article 98).
- Issuance of PKPLH: 2 Days if no corrections are needed. If there are correction directives, you submit them no later than 5 Days, and PKPLH is issued no later than 2 Days after the corrections are received (Articles 99 and 100).
SPPL itself is automatically issued along with the NIB (Article 101 paragraph (2)).
Documents returned: correction time counted separately
This change is most felt by Amdal initiators. PP 22/2021 Article 48 paragraph (2) states that the 50 working days period includes the time for document corrections by the business responsible. PP 28/2025 Article 93 paragraph (3) reverses this: the 50 Days does not include the time for corrections of Andal and RKL-RPL by the business actors.
So, as long as the documents are in your hands, that time does not consume the assessor's quota. Conversely, the total project time continues to increase as you make corrections.
What if the corrections are late? For Andal and RKL-RPL, the OSS System sends a notification to halt the substantive assessment. You can still apply for an extension for a maximum of 180 days, and the continued assessment is again limited to 50 Days from the application received (Articles 91 and 93 paragraph (2)). If you exceed that limit without an application, the PL is rejected.
Other stages are stricter. Late corrections in the administrative assessment of Amdal, as well as at all stages of UKL-UPL, will directly result in rejection (Articles 88 paragraph (5), 97 paragraph (5), 99 paragraph (6), 100 paragraph (6)).
Technical approvals should not hold up the queue
Technical approvals in the form of technical studies are issued no later than 30 Days for wastewater and emission quality standards, and 16 Days for B3 waste management. Andalalin takes 23 Days for high and medium traffic generation, 3 Days for low generation (Article 83 paragraphs (1) and (2)).
If that limit is exceeded, you may directly apply for PL with proof of the technical approval application that has been declared complete and correct. The substantive examination can still proceed without the technical approval (Articles 83 paragraphs (3) to (7)). Hukumonline also notes that PL is now processed in parallel with technical approvals, no longer waiting for the technical approval to be issued first.
How to read these figures
All the figures above are the maximum deadlines, not a promise of turnaround time. The actual time is the assessor's quota plus your correction time and the evaluation rounds. Therefore, check the document's systematics against the preparation guidelines and the status of technical approvals before uploading. These two aspects are among those checked in the administrative assessment (Article 87 paragraph (1)).
One transitional note: applications that are currently in progress until the OSS System is fully adjusted will still be processed based on PP 5/2021 (Article 547 letter a PP 28/2025).
Sources
- Government Regulation Number 28 of 2025 concerning the Implementation of Risk-Based Business Licensing (copy), JDIH Ministry of Finance: https://jdih.kemenkeu.go.id/api/download/b71d04f2-c2be-4eaa-9637-c944ae584f46/2025PP028.pdf
- Status of PP Number 28 of 2025 (Effective, revoking PP 5/2021), JDIH BPK: https://peraturan.bpk.go.id/Search?keywords=Perizinan+Berusaha+Berbasis+Risiko&tentang=&nomor=28&jenis=10&tahun=2025
- Government Regulation Number 22 of 2021 concerning the Implementation of Environmental Protection and Management, OSS System: https://oss.go.id/en/regulasi/45cd0928-19d9-4f1c-b76e-3d738c8985a6
- PP Number 22 of 2021 (status Effective), JDIH BPK: https://peraturan.bpk.go.id/Details/161852/pp-no-22-tahun-2021
- Revisiting Environmental Approval and Amdalnet Post Issuance of PP 28/2025, Hukumonline: https://www.hukumonline.com/berita/a/mengenal-ulang-persetujuan-lingkungan-dan-amdalnet-pasca-terbitnya-pp-28-2025-lt68f8e764e4566