Many prospective business operators delay obtaining the Space Utilization Activity Suitability (KKPR) due to a mistaken belief: thinking they must first hold a land certificate. This belief is costly, as KKPR is a fundamental requirement that opens the entire licensing process for business operations. Delaying it means delaying everything.
The rules have changed since Government Regulation Number 28 of 2025 on Risk-Based Business Licensing came into effect on June 5, 2025, simultaneously revoking Government Regulation Number 5 of 2021. Any old material still referencing Government Regulation 5 of 2021 needs to be reviewed.
Two forms of KKPR, and what determines them
For business locations on land, KKPR only has two forms (Article 15). What determines the form is not the size of your business, but the availability of the Detailed Spatial Plan (RDTR) in that location.
If the RDTR is available and integrated with the OSS System, what is issued is a KKPR confirmation. The approval is automatically issued by the head of the OSS Agency, and the rejection is also automatic (Article 17). If the RDTR is not available, what applies is a KKPR approval, which must go through registration, examination, assessment, and then issuance (Article 18).
What is requested is land ownership information
This is the part that is most often misunderstood. The proposal documents that must be completed when registering consist of seven items (Article 19 paragraph (1)): location coordinates, land area requirements, land ownership information, type of activity information, planned number of building floors, planned building floor area, and technical building plans or master area plans.
What is written is ownership, not possession. None of the items request proof that you have purchased the land. The common practice is actually the opposite: KKPR is processed first to ensure that the planned activities comply with spatial planning, before significant funds are spent on land that may not be usable.
The ticking clock, and one deadline with a different unit
Government Regulation 28/2025 sets deadlines for almost every stage:
- Payment of Non-Tax State Revenue (PNBP): no later than 7 calendar days from the issuance of the first payment order. If the deadline is missed, the letter is void, and the system issues a second payment order with another 7 calendar days deadline. If the second is also missed, the application is considered withdrawn, and you must re-register (Article 19).
- Document examination: no later than 5 Days from the payment being fulfilled (Article 20).
- Document assessment: no later than 20 Days from the documents being declared correct (Article 21).
- Documents returned for correction: you have 5 Days, followed by a re-examination of 3 Days (Article 23).
Note the difference. The word "Days" in uppercase in this regulation has a specific meaning, namely working days (Article 1 number 26). The only deadline calculated in calendar days is the payment of PNBP, and it is precisely this deadline that is the shortest and most easily overlooked when it falls during long holidays.
One more provision that is rarely mentioned: if the technical land consideration is not completed within the assessment period, the KKPR approval will still be issued without that consideration (Article 22 paragraph (3)).
Who assesses, and a shorter pathway
Document examination, assessment, and technical land considerations are carried out by the Minister of Agrarian Affairs and Spatial Planning/Head of BPN, governors, or regents and mayors according to their respective authorities (Article 26). However, there is a single entry point: for business activities, KKPR must be requested and issued through OSS, no longer outside that system.
There are two more streamlined pathways. Micro business operators with low risk can simply use a self-declaration through the OSS System, which is then assessed for compliance with spatial planning within a maximum of 10 Days (Articles 32 and 33). Additionally, there are seven specific conditions that allow KKPR approval to be issued without the assessment stage (Article 27 paragraph (2)), including locations in special economic zones or industrial areas whose coordinate polygons are already registered in the OSS System, land that already has KKPR and is then transferred or leased with the same KBLI, type of activity, and area, as well as the construction of housing for low-income communities covering no more than 5 hectares that complies with spatial planning.
If you want to understand why this document determines the legality of land use, the discussion is available in the article about PKKPR and spatial risk. Questions about the necessity of purchasing land first are also discussed in the short clip from the PPR class if you prefer to see the explanation directly.
Sources
- Copy of Government Regulation Number 28 of 2025 on Risk-Based Business Licensing, JDIH Ministry of Investment/BKPM: jdih.bkpm.go.id
- Metadata and status of Government Regulation Number 28 of 2025 (effective June 5, 2025, revoking Government Regulation Number 5 of 2021), JDIH BPK: peraturan.bpk.go.id
- Government Regulation Number 21 of 2021 on Spatial Planning Administration, JDIH BPK: peraturan.bpk.go.id
- Hukumonline, "Important! Here’s What You Need to Pay Attention to in the KKPR Application Process According to PP 28/2025", July 23, 2025: hukumonline.com