Kapan Jasa Pertambangan Wajib IUJP, Kapan Cukup Sertifikat

Many service companies sign contracts with mining license holders first, and only then find out what permits are actually needed. This order is reversed, and the costs are real: ongoing work can be temporarily halted because the permits do not match the type of work being done.

The dividing line is not the size of the company, nor the value of the contract. What determines it is the type of activity.

Three types of activities, two licensing doors

Government Regulation Number 96 of 2021, as last amended by Government Regulation Number 39 of 2025, divides mining service business activities into three: consultation, planning, and implementation (Article 137 paragraph (3)).

This division directly determines the licensing:

Consultation and planning only require a Business License in the form of a standard certificate (Article 137 paragraph (4)).
Implementation must have a Mining Service Business License (IUJP) (Article 137 paragraph (5)).

Companies that have only been preparing studies and designs are at a different door than companies that deploy equipment and personnel to the field. Once the scope of the contract shifts from designing to executing, the licensing door also shifts.

Ten fields counted as mining services

Article 137 paragraph (2) mentions ten fields: general investigation, exploration, feasibility studies, mining construction, transportation, mining environment, reclamation and post-mining, mining safety, mining, and processing.

Holders of IUJP must base their activities on these fields (Article 137 paragraph (12)). Work outside the listed fields is not an expansion that can be carried out quietly.

There is one restriction that is often overlooked. Mining activities may only be delegated to others for the excavation of alluvial mineral deposits, and the recipient must be an IUJP holder with domestic investment status whose license is issued by the local governor (Article 137 paragraph (7)). Indonesian legal entities providing services for foreign investment can only be used if there are no local or national companies capable of meeting the criteria for license holders (Article 137 paragraphs (8) and (9)).

Subsidiaries also need the Minister's approval

Article 137A prohibits holders of IUP or IUPK from involving subsidiaries and affiliates in mining service business activities in the areas they operate, except with the Minister's approval.

This approval is only granted if one of three conditions is met: there are no similar service companies in the area, no one is capable, or no one is interested. Its use must still adhere to the principles of propriety, transparency, and fairness.

Responsibilities do not transfer

Delegating work to contractors does not transfer responsibility. Article 138A emphasizes that the responsibility for mining business activities remains with the holders of IUP or IUPK, including the selection of service companies, contract preparation, work execution, and risks arising from service companies that do not even have a direct contract with them.

Obligations that continue after the permit is issued

Minister of Energy and Mineral Resources Regulation Number 17 of 2025 requires IUJP holders to submit periodic reports on the technical principles of mining service businesses every three months (Article 19 paragraph (8)), no later than the 15th of the following month after the quarter ends (Article 21). If the Minister or Governor responds to the report, the response must be followed up within a maximum of five working days (Article 23 paragraph (2)).

The sanctions are tiered and time-bound:

Written warnings, a maximum of three times, each with a duration of 30 calendar days (Article 26).
Temporary cessation of part or all of the business activities, for a maximum of 60 calendar days from the end of the warning period (Article 27).
Revocation of the license if obligations are still not met by the end of the temporary cessation period (Article 28).

Check the year of the regulation before copying

Old references can be misleading in this field. Government Regulation Number 96 of 2021 has been amended twice, most recently by Government Regulation Number 39 of 2025, which is effective from September 11, 2025. Law Number 4 of 2009 is now read together with its fourth amendment, Law Number 2 of 2025, which is effective from March 19, 2025. Minister of Energy and Mineral Resources Regulation Number 17 of 2025 itself revokes Minister of Energy and Mineral Resources Regulation Number 10 of 2023 and its amendments.

Before you copy provisions from internal documents, training materials, or circulating articles, ensure that the numbers and years of the regulations are still valid. In this sector, one incorrect year number is enough to make all the procedures you have drafted refer to rules that have already been revoked.

Mining Services: When is a Standard Certificate Sufficient, and When is an IUJP Mandatory?