Minister of Transportation Regulation Number PM 4 of 2026 Business Licenses Officially Replaced by Standard Certificates

Introduction

On 10 June 2026, the Ministry of Transportation issued Minister of Transportation Regulation Number PM 4 of 2026 on Amendments to Minister of Transportation Regulation Number PM 8 of 2012 concerning the Operation and Commercial Activities of Multimodal Transportation (“MOT Regulation 4/2026”), which took effect on 30 June 2026. MOT Regulation 4/2026 restructures the governance, licensing, and operational standardization applicable to all business entities engaged in the transportation of goods using at least two different modes of transportation.

The Ministry of Transportation considered that Minister of Transportation Regulation Number PM 8 of 2012 on the Operation and Commercial Activities of Multimodal Transportation (“MOT Regulation 8/2012”) no longer fully accommodates regulatory developments, service requirements, and the evolving dynamics of multimodal transportation operations, making amendments necessary. Accordingly, MOT Regulation 4/2026 was issued to regulate the operation and commercial activities of multimodal transportation, namely the transportation of goods using at least two different modes of transportation under a single multimodal transport contract.

Compared to MOT Regulation 8/2012, MOT Regulation 4/2026 introduces several substantive changes, including the change in licensing nomenclature from a Business License to a Multimodal Transportation Standard Certificate, for which applications must be submitted electronically through the Online Single Submission (“OSS”) system, the reduction of the time limit for completing application requirements that do not comply with the prescribed requirements from a maximum of 90 (ninety) working days to a maximum of 7 (seven) working days, as well as updated provisions regarding human resource competency through the Recognition of Prior Learning (“RPL”) mechanism and the obligation for multimodal transportation competency training institutions to adjust their operations no later than 1 (one) year after this Regulation is enacted.

Comparison

MOT Regulation 4/2026 amends several provisions of MOT Regulation 8/2012. The comparison is presented below:

Key Provisions

Business Licenses Replaced by OSS-Based Standard Certificates

Pursuant to Article 28 paragraph (2), the operational legality of national multimodal transportation business entities has changed in nomenclature from a Business License to a Multimodal Transportation Standard Certificate. Pursuant to Article 28 paragraph (3), in order to obtain a Multimodal Transportation Standard Certificate, both administrative and technical requirements must be satisfied.

The administrative requirements are as follows:

·      possessing a deed of establishment of a company specifically established to operate multimodal transportation, which has been approved by the minister responsible for governmental affairs in the field of law;

·      possessing a Taxpayer Identification Number (Nomor Pokok Wajib Pajak – “NPWP”);

·      possessing a business domicile certificate issued by the relevant local government; and

·      possessing authorized capital equivalent to at least 80,000 (eighty thousand) Special Drawing Rights (SDR).

The technical requirements are as follows:

possessing and/or controlling a permanent office;

possessing and/or controlling transportation equipment consisting of at least 1 (one) cargo transportation vehicle, as evidenced by valid supporting documents, in the form of:

o   cargo trucks;

o   railway rolling stock (locomotives and freight wagons or railcars);

o   seagoing vessels; and/or

o   aircraft;

·      possessing and/or controlling at least 1 (one) unit of cargo handling equipment, as evidenced by valid supporting documents, in the form of:

o   forklift;

o   reach stacker;

o   mobile crane;

o   hand pallet or pallet mover;

o   container dolly tug; and/or

o   equipment appropriate for local multimodal transportation activities;

·      possessing competent human resources in the field of multimodal transportation.

In line with these amendments, Articles 34 and 36 provide that all administrative processes, from the submission of applications and supporting documents to the issuance of notices of rejection by the competent authority, shall be conducted electronically and in an integrated manner through the OSS system.

Delegation of Authority to the Director General of Transportation Integration and Multimodal Transportation

MOT Regulation 4/2026 restructures the administrative authority by transferring functions previously exercised by the Secretariat General to the Directorate General of Transportation Integration and Multimodal Transportation.

As stipulated in Articles 8, 17, 23, and 46, the registration of foreign multimodal transportation business entities, the registration of national business entities to operate within the ASEAN region, the issuance of Standard Trading Conditions (“STC”) recommendations, and guidance activities are now carried out by the Minister through the Director General of Transportation Integration and Multimodal Transportation.

Enhancement of Human Resource Qualifications and Competency Refresher Requirements

Pursuant to Articles 29 and 30, human resources engaged in the field of multimodal transportation are required to possess competency certificates obtained through competency assessments conducted by accredited institutions, including through the Recognition of Prior Learning (“RPL”) mechanism.

Although MOT Regulation 4/2026 does not expressly specify the categories of human resources required to satisfy these requirements, the scope of competency may be referred to Article 51 paragraph (4) of Minister of Transportation Regulation Number PM 8 of 2012 concerning the Operation and Commercial Activities of Multimodal Transportation, as amended by MOT Regulation 4/2026.

These provisions cover personnel performing activities relating to:

·      sorting;

·      packing;

·      handling hazardous and toxic materials (B3);

·      marking;

·      measurement;

·      weighing;

·      document administration;

·      cost calculation;

·      claims handling;

·      insurance; and

·      other logistics services in the operation of multimodal transportation.

Competency certificates remain valid for 5 (five) years, and business entities are required to conduct competency refresher programs for their human resources at least once every 2 (two) years.

Integrated Supervision and Periodic Monitoring

Article 55 reforms the supervision mechanism for multimodal transportation operations from a sectoral approach to a monitoring and evaluation system implemented by an integrated technical team.

The team is led by the Directorate General of Transportation Integration and Multimodal Transportation with the participation of other relevant technical units.

In carrying out its duties, as stipulated in Article 55 paragraph (5), the monitoring and evaluation activities include assessments of:

·      operational activity and productivity reports of multimodal transportation business entities;

·      the availability of human resources; and

·      the equipment owned and/or controlled by the business entity.

Such monitoring and evaluation activities must be conducted at least once every 6 (six) months.

Transitional Provisions

Pursuant to Article 58A, all references to, issuances of, and administrative processes that continue to use the nomenclature of Multimodal Transportation Business License under MOT Regulation 8/2012 shall remain legally valid and shall be construed as referring to the Multimodal Transportation Standard Certificate.

In addition, Article 29A grants a transition period to institutions providing education and competency training in multimodal transportation to align their programs with the new provisions within a maximum period of 1 (one) year from 10 June 2026.

Closing

With the entry into force of MOT Regulation 4/2026, multimodal transportation business entities are required to adjust their business governance, licensing mechanisms, and compliance with human resource competency standards in accordance with the new regulatory framework. These changes include the digitalization of licensing procedures through the OSS system, the change in the nomenclature of business legality to the Multimodal Transportation Standard Certificate, the transfer of administrative authority to the Directorate General of Transportation Integration and Multimodal Transportation, and the strengthening of the supervision system and competency standards.

Accordingly, businesses as well as education and competency training institutions should ensure that all operational, administrative, and competency development processes have been aligned with the provisions of MOT Regulation 4/2026 to ensure compliance with the applicable laws and regulations.