The first question that arises after learning that the IMB (Building Permit) has changed to PBG (Building Approval) is usually not about the documents, but about the costs. The most common answer received sounds vague: it depends on the region. That is true, but not complete. The formula is national and the same throughout Indonesia. What differs between regions is only the value of several variables within it, and you can find those variables yourself before submitting your application.
There is one formula, regulated by PP 16/2021
For building construction, the PBG fee is calculated using the following formula:
Retribusi = LLt x (Ilo x SHST) x It x Ibg
- LLt: total floor area, in square meters
- Ilo: locality index, a percentage multiplier against the SHST set by the local government
- SHST: highest unit price standard per square meter in that area
- It: integrated index, reflecting the function and classification of the building
- Ibg: index of constructed buildings
For building infrastructure, such as fences, towers, or pools, the formula is different: V x I x Ibg x HSpbg, with V as volume and HSpbg as the unit price of infrastructure fees. PP 16 of 2021, which serves as the basis, has been in effect since February 2, 2021, and remains valid, replacing PP 36 of 2005.
Two variables that cause significant differences in numbers
SHST is set by the regency or city government, calculated using the Highest Unit Price Standard Calculation application provided by the Ministry of PUPR and can be downloaded at simbg.pu.go.id. Regions that have set the Standard Price for State Building can directly use that value as SHST.
The locality index acts as a brake. The guidelines from the Directorate General of Fiscal Balance at the Ministry of Finance state that Ilo can be set at a maximum of 0.5 percent, and its function is to ensure that the calculated results do not spike compared to the previous IMB fees in that area.
An example from the same guidelines shows the significant impact of this variable. A single-story house with an area of 100 square meters, with It 0.1, SHST Rp2,000,000, and Ibg 1, results in Rp20,000,000 before the locality index is applied. With Ilo at 0.5 percent, the amount becomes Rp100,000, equivalent to the old IMB fee in that city. One variable set through local regulations determines a difference of two hundred times.
One fee determination, several services at once
What is often overlooked: the PBG fee is not just the cost of issuing one letter. Its scope includes consultation services for meeting technical standards, issuing PBG, building inspections, issuing Function Feasibility Certificates and Building Ownership Evidence Letters, as well as printing SLF plaques. Treating it merely as a permit fee can lead to budget planning discrepancies, as inspection activities and SLF issuance are already included in the same determination.
Legal basis at the regional level and exemption loopholes
UU 1 of 2022 on Financial Relations between the Central Government and Regional Governments places the PBG fee as a specific licensing fee, and Article 94 requires regions to regulate all types of local taxes and fees in one local regulation. During the transition period, a joint circular from four ministries dated February 25, 2022, allows the IMB fee regulation to be used as the basis for collecting PBG fees until January 5, 2024, as long as the services are in accordance with PP 16/2021.
There is also an exemption pathway. Article 44 of UU 1/2022 and Article 63 of PP 35 of 2023 open the space for regencies and cities to exempt PBG fees. This space is utilized through a joint decree from three ministries in November 2024 to eliminate BPHTB and PBG fees for housing projects for low-income communities, with MBR criteria referring to the Decree of the Minister of PUPR Number 22/KPTS/M/2023. Its implementation still awaits the regulations from each regional head.
Three things to check before calculating
Everything is in the regional documents, not in central regulations: the applicable local tax and fee regulations, the latest SHST value, and the locality index size. Without these three, the figures circulating on the internet only apply to the regions that issued them, and using them as budget benchmarks carries a high risk of significant discrepancies.
If you are dealing with an existing building, you can first check the validity period of the SLF through the SLF validity check tool.
Sources
- PP No. 16 Tahun 2021 tentang Peraturan Pelaksanaan UU No. 28 Tahun 2002 tentang Bangunan Gedung, JDIH BPK RI
- Buku Retribusi Persetujuan Bangunan Gedung, Direktorat Jenderal Perimbangan Keuangan, Kementerian Keuangan
- Soal Nasib PBG, 4 Kementerian Akhirnya Terbitkan Surat Edaran Bersama, DDTCNews, 8 Maret 2022
- Pemda Diminta Hapus BPHTB dan Retribusi PBG untuk Proyek Rumah MBR, DDTCNews, 25 November 2024