Clarification for Online Single Submission System

AmCham meets with Bambang Adi Winarso of the Coordinating Ministry for Economic Affairs to discus the operation of the new OSS scheme

By Ellisa Kosadi
Monday, September 24, 2018

AmCham Indonesia’s Trade and Investment Committee met with Coordinating Ministry of Economic Affairs Deputy for Trade and Industry Bambang Adi Winarso and his team in early September, to gain clarification and share member experiences so far with the Online Single Submission (OSS) system.

Participating in the meeting were AmCham Indonesia Managing Director A Lin Neumann, committee chair Douglas Ramage, and representatives from member companies including Cargill, Chevron, HM Sampoerna and Asia Group Advisors.

The meeting provided clarity on pressing operational issues of concern to AmCham members since the implementation of the OSS system, particularly matters related to the scope of the regulation. For instance, Government Regulation no. 24 year 2018 (GR 24/2018) on details about the OSS mentions the exclusion of the extractive and financial sectors from the regulation.

Bambang said the exclusion is in terms of applying for permits and licenses through the OSS, as registration for documentation in these two sectors is not yet integrated into the system and thus is still dependent on their respective regulating ministries. However, regardless of the sector, all businesses, old and new, are still required to register for a Business Identification Number (NIB) through the OSS.

Other concerns regarding the system include the validity of licenses and permits applied for and obtained pre-OSS from the Indonesia Investment Coordinating Board (BKPM) and other government agencies. Bambang said the OSS was built in anticipation of such a grandparent clause, and only applications for permits and licenses applied for after the OSS was launched in July need to be resubmitted.

It is also unclear whether businesses with NIBs but pending licenses and permits are allowed to start operating, although some government agencies do accept license/permit-under-process declaration letters. And it is also not clear if NIBs, permits and licenses issued through the OSS are valid at all levels of government.

Bambang also spoke of the future management of the OSS system. Under GR 24/2018, the coordinating ministry will manage the system for six months before returning operational responsibilities to BKPM, which has full access to the system’s data backed up by the Indonesia National Single Window (INSW). However, there are still concerns regarding the readiness of the system as well as the future transition between the two managing bodies.

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