New Standards for Business Licences for Special Hajj Pilgrimage Organizers and Umrah Pilgrimage Travel Organizers under Ministerial Regulation No. 2 of 2026

Introduction

On 30 July 2026, the Minister of Hajj and Umrah of the Republic of Indonesia enacted Minister of Hajj and Umrah Regulation No. 2 of 2026 on Standards for Business Activities, Procedures for the Implementation of Supervision, and Administrative Sanctions in Risk-Based Business Licensing for the Religious Sector (“Minister of Hajj and Umrah Regulation 2/2026”). Minister of Hajj and Umrah Regulation 2/2026 was established as the legal basis for the implementation of risk-based business licensing for Special Hajj Pilgrimage Organizers (“PIHK”) and Umrah Pilgrimage Travel Organizers (“PPIU”), including by regulating legality requirements, service standards, supervisory mechanisms, and classifications of administrative sanctions.

The enactment of Minister of Hajj and Umrah Regulation 2/2026 was prompted by the enactment of Law No. 14 of 2025, which transferred the authority to issue business licences for PIHK and PPIU to the Minister of Hajj and Umrah. In line with this, the regulation was formulated to establish systematic licensing governance through the implementation of risk-based business licensing and to facilitate the commencement and operation of business activities. In addition, Minister of Hajj and Umrah Regulation 2/2026 was established to implement Article 5 paragraph (7), Article 313, and Article 471 paragraph (2) of Government Regulation No. 28 of 2025 on the Implementation of Risk-Based Business Licensing, particularly to facilitate the commencement and operation of businesses through the continuous implementation of risk-based business licensing. Upon the entry into force of Minister of Hajj and Umrah Regulation 2/2026, Minister of Religious Affairs Regulation No. 5 of 2021 on Standards for Business Activities for the Organization of Umrah Pilgrimages and Special Hajj Pilgrimages is revoked and declared no longer in force.

Comparison

Minister of Hajj and Umrah Regulation 2/2026 revokes and declares no longer in force Minister of Religious Affairs Regulation No. 5 of 2021 on Standards for Business Activities for the Organization of Umrah Pilgrimages and Special Hajj Pilgrimages. The changes can be seen in the following provisions:

Key Provisions

• Additional Requirements for Business Licensing 

As stipulated in Articles 3 and 4, business licensing for PIHK and PPIU requires ownership and management by Indonesian citizens who are Muslim. Business actors are also required to submit the company's financial statements for the preceding 1 (one) year, audited by a Public Accountant with an Unqualified Opinion (WTP). Article 5 stipulates that business actors must provide a bank guarantee in the form of a deposit or bank guarantee valid for 6 (six) years, issued by a Bipih Deposit Receiving Bank (BPS).

• Strict Standards for Pilgrim Services and Accommodation

Pursuant to Articles 20 and 32, PPIU and PIHK are required to accommodate pilgrims in hotel facilities located no more than 1,000 metres from the Grand Mosque in Makkah and 700 metres from the Prophet's Mosque in Madinah. Occupancy of each room is limited to a maximum of 4 (four) persons, unless otherwise agreed in writing with the pilgrims. In addition, Articles 24 and 35 require organizers to provide life, accident, and health protection in the form of insurance, with coverage commencing from departure until return to Indonesia.

• System-Based Supervision Mechanism 

Pursuant to Article 39, supervision is conducted through two main approaches, namely routine supervision (through reports and field inspections) and incidental supervision (based on public complaints, the confidentiality of which is guaranteed). All supervisory personnel are required to use supervisory work tools that are fully integrated into the Ministry Information System.

• Escalation of Administrative Sanctions and Financial Penalties 

Article 46 stipulates that administrative sanctions may be imposed without following a graduated sequence where a violation directly endangers the safety and security of pilgrims. For organizers proven to have failed to dispatch pilgrims, failed to repatriate pilgrims, or failed to provide essential services (accommodation, transportation, and meals), the sanctions imposed are severe, ranging from an administrative fine amounting to 4 (four) times the value of the bank guarantee, restriction of system access or temporary suspension, suspension of the licence for 180 days, to permanent revocation of the Business Licence.

Transitional Provisions

Article 60 stipulates that applications for PIHK and PPIU business licences that have been submitted to the Ministry Information System prior to the promulgation of this Ministerial Regulation shall continue to be processed in accordance with the provisions of this Ministerial Regulation. Accordingly, the transitional provisions ensure that previously submitted applications are not discontinued, but continue to be processed by reference to the provisions applicable under Minister of Hajj and Umrah Regulation No. 2 of 2026.

Closing

Minister of Hajj and Umrah Regulation No. 2 of 2026 imposes stricter requirements on the conduct of PIHK and PPIU business activities. This regulation transfers licensing and supervisory authority to the Ministry of Hajj and Umrah, raises standards relating to legality, business capacity, services, and pilgrim protection, and strengthens organizers' compliance with system-based supervisory mechanisms.

For PIHK and PPIU, these changes have significant consequences, particularly with respect to fulfilling licensing requirements, enhancing operational standards, providing financial guarantees, and meeting service quality and pilgrim protection requirements. At the same time, the strengthening of administrative sanctions demonstrates that compliance is no longer merely administrative in nature, but constitutes an important component of efforts to ensure that the safety, security, and rights of pilgrims are optimally protected.

Accordingly, PIHK and PPIU need to make internal adjustments to satisfy requirements relating to licensing, corporate structure and documentation, financial condition, office standards, pilgrim services, accommodation, insurance, and reporting and compliance mechanisms. The transitional provisions also require attention to ensure that each application and ongoing licensing process can be appropriately adjusted to the new requirements in a timely manner. Overall, Minister of Hajj and Umrah Regulation 2/2026 is expected to strengthen the governance of special Hajj and Umrah pilgrimage services while enhancing the standards of professionalism and accountability of organizers in providing services to pilgrims.