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PP 28/2025 is the Prabowo administration's first-term overhaul of the OSS (Online Single Submission) risk-based licensing system that has governed Indonesian business permitting since the Job Creation Law (UU Cipta Kerja) and PP 5/2021. The new statute is structurally broader than its predecessor — sector coverage expands to creative economy, geospatial information, cooperatives, investment, electronic system & transaction operators, and environment — but its IPTM significance lies in Appendix 1F, which is the technical specification of permit-eligible business activities (KBLI codes) in the mining-processing sector.
Appendix 1F omits new-issuance pathways for KBLI codes covering ferronickel, nickel pig iron (NPI), nickel matte, and mixed hydroxide precipitate (MHP) — all of which are intermediate nickel products sitting between raw laterite ore and battery-grade Class-1 nickel sulphate. Administratively, this means an investor cannot obtain a new IUI (Industrial Business License) or operating permit through OSS for plants whose primary output is one of these four intermediate-nickel categories. Existing operating licenses are grandfathered; capacity expansions and greenfield-line additions are the binding constraint.
The intent is to force Indonesia's downstreaming (hilirisasi) chain to skip the intermediate stages and move directly into higher-value battery-precursor chemistry (nickel sulphate, precursor cathode active material, cathode active material) — a structural extension of the 2020 nickel-ore export ban (2020-01-01-indonesia-nickel-ore-export-ban), the 2025 KEPPRES 1/2025 hilirisasi task force (2025-01-03-indonesia-keppres-1-2025-hilirisasi-task-force), and the 4th-amendment Minerba law (2025-03-19-indonesia-uu-2-2025-fourth-amendment-minerba).
A four-month grace period elapsed between promulgation (5 June 2025) and OSS enforcement; the platform began issuing automated notifications to smelter projects October–November 2025, prompting the FINI (Indonesian Nickel Smelting Association) exemption-petition flow.
capped at existing licenses, marginal expansion is forced toward battery-grade chemistry — likely raises Indonesian nickel sulphate premium over LME Class-2 reference price; bearish for NPI/FeNi spreads vs Class-1 nickel.
Tsingshan, Huayou, and Lygend joint ventures with deployed capex but no operating permit as of October 2025 face stranded-asset risk if FINI exemption petitions fail. Watch BKPM-FINI negotiations through Q2 2026.
(Huayou JV), Tesla/Ford battery-grade nickel offtake agreements, and the Korean (LGES/Hyundai) and Chinese (CATL) precursor JVs gain a structural advantage as the only OSS-eligible expansion pathway.
LME's 2026 deliberations on a Class-1 nickel sulphate contract and the IEA's critical-minerals supply-chain stress on beneficiation-margin capture suit this regulation's structural intent.
permitting integrated into OSS means an additional layer of centralised approval delay; affects all 6 expanded sectors but most material for capital-intensive mining-processing.
carve-out) for partially-built intermediate-nickel projects, or will exemptions remain discretionary case-by-case decisions?
implementing rules on Class-1 nickel sulphate certification and battery-precursor downstream targets?
intermediate-metal products (e.g., cobalt sulphate intermediates, copper concentrate beyond the existing Permendag 10 ban)?
regulation (Permen) operationalising Appendix 1F enforcement procedures and audit triggers?