The new requirements document received by Insimen shows that the process of establishing a representative office now requires not only administrative documents, but also proof of technical ability, track record of large projects, financial reports, certification of competence, and anti-smoking compliance.

The change of attention came as Indonesia continued to maintain a balance between foreign investment needs and protection of the national construction services market. The government gave space to foreign enterprises, but the space did not stand free.

The risk-based rules also form the backdrop of the process. PP No. 28 of 2025 has been in force since 5 June 2025 and replaces PP No. 5 of 2021 on the Maintenance of Risk-based Business Permits.

Alt text image: KP BUJKA in the license of the representative office of the foreign construction services enterprise.

New requirements for the construction company attract foreign construction workers' attention

The new requirements of the BUJKA KP show a more selective policy direction.The government not only looks at the existence of foreign enterprises from the formal legal side, but also from the real capabilities of the parent company in the home country.

In the documents received by the Insimen, the requirements list contains fifteen components, most of which relate directly to the validity of the enterprise, technical capacity, project experience, and operational integrity.

KP BUJKA documents include legality and trace records

The initial requirement starts with a management power of attorney when the process is enforced. This document is required in the Indonesian and English versions.

In addition, the applicant must prepare the general data of the foreign BUSINESS. These data form the basis for the authorities to read the identity of the company, the country of origin, the structure of the activity, and the position of the company in the construction services sector.

The most prominent part is the list of company experience over the last nine years. The document requires project experience with a value of over Rp100 billion per project, accompanied by proof of receipt or completion of work and a summary bill of quantity.

The CCP needs verified maternal documents

The incorporation documents also become an important part. Applicants need to attach a legalised incorporation deed in the English version. On the other hand, documents such as Letter of Appointment, Letter of Intent, and Letter of Statement are also included in the list of requirements.

The requirements of the recommendation of the embassy of the home country stress that this process is not only corporate to the government. There is an element of formal recognition of the home country of the company, so that the identity and existence of foreign business entities can be traced more strongly.

The PU Ministry explained that the BUJKA Representative Office can only be formed by foreign construction services enterprises that have high qualifications and have certificates in the field of construction services in the home country.

Risk-Based Permits Change the Way Governments Read Legality

Risk-based licenses make the legality of a business no longer seen as static documents. Each license must be connected to standards of activity, capacity, supervision, and reporting obligations.

In the context of the BUJKA KP, this is important because construction activities often involve large project values, safety risks, the use of expert staff, and technology transfer.

The OSS system becomes the license entry line

The Ministry of Public Affairs noted that registration of representative permits is conducted through the Online Single Submission system, which includes issuance of permits based on commitment, fulfillment of commitment, verification and validation, payment of permit fees, and then effective issuance of permits.

In practice, the applicant is not satisfied with simply filling in the data. Fulfillment of the commitment is proved by the possession of SBU qualified high as provided.

The PU Ministry also said that the permits sought by the BUJKA Representative Office are valid for three years and can be extended before the expiry of the validity period.

The KJKA should remain in contact with the National KSO

For foreign enterprises, KP BUJKA is not allowed to operate independently in the Indonesian construction market.

The criteria for national partnership are also not light. The BUJKN that becomes a KSO partner must be a limited company law entity, have a large qualified construction SBU, and have a subclassification similar to the BUJKA Representative Office.

For construction work and integrated construction work, at least 50 percent of the value of the work must be done domestically. In addition, at least 30 percent of the value of the work must be done by KSO's partner BUJKN. For construction consulting services, all work is done domestically, and at least 50 percent of the value of the work must be done by KSO's partner BUJKN.

Technical Compliance and Anti-Smoke Enter the Center of Attention

The new documents received by Insimen also set the technical aspects and compliance as the main requirements.

This combination shows that the permits do not only serve as an administrative gateway, but also that the government wants to see if foreign enterprises have the right technical capabilities, management standards, and operational readiness to take responsibility.

SKK and SBU become technical skills filters

The Certificate of Enterprise becomes one of the key documents. In Perm PUPR No. 8 of 2022, SBU is described as a proof of recognition of the classification and qualification of the capabilities of construction services enterprises, including the results of the equalization of capabilities of foreign construction services enterprises.

The requirements document received by the Insimen requested the SBU to be equated from the institution still in force, as well as the SBU from the country of origin in the English version and legalized.

The requirements of the 9th tier of the SKK for PJT and PJSK also emphasize the need for high-level expert staff.

The risk of compliance with the BUCK Code increases

The PU Ministry also called on the BUJKA Representative Office to report on annual business activities, record experience, implement safety, safety, health, and sustainability standards, and prioritize the use of construction materials and technology in the country.

Other duties also lead to national benefits. BUJKA's representative offices are required to have high technology, state-of-the-art, efficient, environmentally-minded, pay attention to local awareness, implement technology transfer, and employ more Indonesian labor than foreign labor on expert ranks.

In 2025, the PU Ministry also delegated the authority to impose administrative sanctions on construction services coaching. The document includes the BUJKA KP which does not have a SBU, the BUJKA which does not form an Indonesian representative office or business body with legal status, and the BUJKA KP which does not meet certain obligations.

Implications for Foreign Construction Investors and Local Partners

These new requirements may make the process of entry into the market longer for foreign companies, but for governments, more selective processes provide protection for project quality and legal certainty.

For local partners, these rules open up a more structured space for cooperation. BUJKN not only serves as an administrative complement, but also plays a role in job sharing, experience recording, and national capacity building.

KP BUJKA Changes the Market Entry Strategy

Foreign companies need to prepare a strategy from the home country. The master legality, construction certificates, audit financial reports, large project experience, and embassy recommendations must be prepared before the process of entry into Indonesia goes too far.

If the document is not ready, the risk of delays will arise. Permit management may be delayed because a document has not been legalized, a certificate has not been filed, or project experience has not had sufficient proof of completion.

Companies that are accustomed to cross-border projects are usually more prepared because they have a track record, audit documents, and complete compliance standards.

The National Construction Market is Still Protected

For Indonesia, the KP BUJKA model ensures that foreign investment does not remove the role of national enterprises.

However, implementation still requires oversight. The government needs to ensure that KSOs are not only written in the document, but properly run in the division of labour, local labour use, and knowledge transfer.

At this point, the new KP BUJKA requirements signal that the Indonesian construction market remains open, but not without fences. Foreign companies wishing to enter must bring real capacity, strong compliance, and willingness to work with national actors.