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Legal Updates

New Standards for the Creative Economy Sector under the Regulation of the Minister of Creative Economy No. 7 of 2025

4 November 2025
Ivonnie Wijaya, Steven Aristides Wijaya
Legal Updates
Standar Baru Sektor Ekonomi Kreatif dalam Permen Ekonomi Kreatif Nomor 7 Tahun 2025

Summary

The Regulation of the Minister of Creative Economy/Head of the Creative Economy Agency of the Republic of Indonesia Number 7 of 2025 concerning Business Activity Standards and/or Product/Service Standards in the Implementation of Risk-Based Business Licensing for the Creative Economy Sector (“Regulation 7/2025”) was enacted on 21 October 2025 and took effect on 22 October 2025. This regulation was issued to implement the provisions of Government Regulation Number 28 of 2025 concerning the Implementation of Risk-Based Business Licensing (“GR 28/2025”) by establishing business activity standards and product/service standards that must be fulfilled by business actors in conducting Risk-Based Business Licensing (RBBL) within the creative economy sector.

 

Background and Context

Regulation 7/2025 was issued to implement the mandate of Articles 333 and 517 paragraph (2) of GR 28/2025, which require the establishment of business activity standards and/or product/service standards. This regulation provides legal certainty and clear guidance for 16 business activities in the creative economy sector, all of which are now classified as low-risk business activities.

 

Comparison with Previous Regulations

Regulation 7/2025 revokes and replaces two prior regulations, namely:

  1. Regulation of the Minister of Tourism and Creative Economy/Head of the Tourism and Creative Economy Agency Number 7 of 2021 concerning Norms, Standards, Procedures, and Criteria for Risk-Based Business Licensing in the Creative Economy Sector (“Regulation 7/2021”); and
  2. Regulation of the Minister of Tourism and Creative Economy/Head of the Tourism and Creative Economy Agency Number 8 of 2021 concerning Administrative Sanctions for Risk-Based Business Licensing in the Tourism and Creative Economy Sectors (“Regulation 8/2021”).

The substantive differences between Regulation 7/2025 and Regulations 7/2021 & 8/2021 are as follows:

Aspect

Regulations 7/2021 and 8/2021

Regulation 7/2025

Scope of KBLI

Covered only 5 KBLI within the Creative Economy Sector (e.g., Visual Communication Design, Photography Activities).

Expanded to 16 KBLI, including new fields such as Sound Recording, Music Publishing, Cultural Parks, Public Relations Activities, and various Performing Arts Activities.

Obligations & Business Standards

Required compliance with Occupational Safety, Health, and Environmental Standards (K3L).

Requires compliance with clarity of product/service information standards, such as portfolio availability, workflow transparency, and competent human resources.

Details of Business Standards

K3L standards were issued concurrently with the Business Identification Number (NIB) through the OSS System. No detailed standards per KBLI.

Includes detailed standards for each KBLI focusing on: (a) design processes and workflows, (b) product/service portfolios, and (c) competent human resources. These are specifically detailed in the annex.

Sanctions Regulation

Regulated separately under two ministerial regulations.

Regulated under a single regulation, distinguishing between “assistance” for Micro and Small Enterprises (MSEs) and “administrative sanctions” for medium or large enterprises.

Legal Remedies (Appeal)

Provided an internal “Administrative Appeal” through a specially established Appeal Commission.

The internal Appeal Commission is no longer regulated. Article 12 states that Business Actors may file “administrative remedies” pursuant to applicable laws and regulations.

Key Provisions

Regulatory Aspect

Description of Provision

Article Reference

Classification of Business Activities

Establishes 16 KBLI under the creative economy sector and classifies all of them as “Low Risk.”

Article 2

Business Activity Standards

Business actors must comply with standards emphasizing “clarity of product/service information,” which include: (1) design processes and workflows, (2) product/service portfolios, and (3) competent human resources.

Article 4 & Annex II

Obligations of Business Actors

The primary obligation for all 16 KBLI is to “submit periodic activity reports.”

Annex I

Supervisory Authorities

Supervision is conducted by the Minister, regents/mayors, the Head of the Special Economic Zone Administrator, the Head of the Free Trade Zone Authority, and/or the Head of the Nusantara Capital Authority.

Article 5(2)

Supervision Method

Supervision is carried out through “incidental field inspections,” which may be triggered by public complaints, government needs, indications of non-compliance, or emergency situations (e.g., pollution).

Article 6

Follow-up to Supervision

Follow-up depends on business scale: (a) Micro and Small Enterprises receive “assistance” to improve compliance; (b) Medium or Large Enterprises are subject to “administrative sanctions.”

Article 9

Gradual Sanction Mechanism

Administrative sanctions for medium/large enterprises are imposed progressively: first, second, and third written warnings (each valid for 30 days), followed by temporary suspension of operations, and ultimately a fine or revocation of the Business License (“BL”).

Articles 10 & 11

Annex I: List of Creative Economy Sector Business Activities

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List of 16 KBLI: While Regulation 7/2021 covered only 5 KBLI, Regulation 7/2025 encompasses 16 KBLI, including:

  1. Visual Communication Design/Graphic Design (74130)
  2. Specialized Design for Film, Video, TV Programs, Animation, and Comics (74141)
  3. Game Content Design (74142)
  4. Other Creative Content Design (74149)
  5. Photography Activities (74201)
  6. Sound Recording Activities (59201)
  7. Music and Music Book Publishing Activities (59202)
  8. Cultural Park (91025)
  9. Public Relations Activities (70203)
  10. Performing Arts Activities (90011)
  11. Supporting Activities for Performing Arts (90012)
  12. Creative Performing Artists (90021)
  13. Creative Music Artists (90022)
  14. Creative Visual Artists (90023)
  15. Other Creative and Artistic Workers (90029)
  16. Other Entertainment, Art, and Creativity Activities (90090)

Annex I stipulates the obligation to submit periodic activity reports for almost all KBLIs. However, specifically for KBLI 90090 (Other Entertainment, Art, and Creativity Activities), in the event of organizing an event, business actors are required to obtain an event permit (public gathering permit).

Annex II: Standards for Clarity of Product/Service Information

Business actors must fulfill the following main criteria for each KBLI:

  1. Design Process and Workflow (Production Pipeline): The business actor must be able to demonstrate and document the creative process and workflow.
  2. Product or Service Portfolio: The business actor must maintain and present examples of past works or services.
  3. Competent Human Resources (HR): The business actor must employ HR competent in the relevant field.

Exceptions to the “competent HR” criterion apply to the following four KBLI:

  1. Creative Performing Artists (No. 12)
  2. Creative Music Artists (No. 13)
  3. Creative Visual Artists (No. 14)
  4. Other Creative and Artistic Workers (No. 15)

Annex III: Assessment Format for Clarity of Product/Service Information

Measurable Indicators: Each criterion under Annex II is auditable and must be documented as follows:

  1. Design Process and Workflow: Must have written and documented policy and implementation records.
  2. Product/Service Portfolio: Must have a written and documented portfolio policy and evidence of implementation.
  3. Competent HR: Must demonstrate education, training, and/or at least two (2) years of relevant work experience.

Assessment Mechanism: Assessment is conducted using a binary scoring system “Compliant (1)” or “Non-Compliant (0).”

Follow-Up (Assistance): If the result is “Non-Compliant (0),” the inspector records the “Reason for Non-Compliance and Recommendations.” This forms the basis for “assistance” to Micro and Small Enterprises (as provided in Article 9), in which inspectors provide specific improvement recommendations.

 

Sanctions (Article 11)

Medium-scale enterprises that remain non-compliant within 60 working days after a temporary suspension may have their Business License revoked. On the other hand, large-scale enterprises that remain non-compliant within 14 working days after a temporary suspension are first subject to an administrative fine. If the fine is unpaid within 30 days, the Business License is revoked.

 

Conclusion

Regulation 7/2025 simplifies and clarifies business standards within the creative economy sector through three main elements:

1. Expanded Coverage

Now includes 16 low-risk creative economy KBLIs. Business actors must ensure their KBLI is listed.

2. New Standards

Each business must possess three key documents:

  • Workflow or design process;
  • Product/service portfolio;
  • Proof of HR competence (education/experience ≥ 2 years).

3. Supervision and Sanctions:

  • MSEs receive assistance to achieve compliance;
  • Medium/large enterprises face progressive sanctions up to license revocation.

Business actors are encouraged to promptly prepare documentation and periodic reports to ensure full compliance and avoid sanctions.

 

Related Regulations

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