The PFII implementing regulation has not arrived

On 21 July 2026 Indonesia passed the law creating the Pusat Finansial Internasional Indonesia at Kura Kura Bali. We wrote at the time that the framework had arrived but the playbook had not, and that the detail deciding whether any of it was useful would sit in the implementing regulation expected in mid-August.

That regulation has not appeared, so far as we can see.

Based on publicly reported statements and our own checks as at the date of this note.

What was promised, and by when

The Coordinating Minister for Economic Affairs said the implementing regulation was being prepared in parallel with the law, and expressed the hope that everything would be ready before the president’s budget address on 16 August. That date has passed.

In the same week the law was passed, the Finance Minister described a rather different horizon: a number of derivative rules were still being drafted, and he hoped all implementing regulations could be completed within six months. Six months from late July runs to January 2027.

Two ministers, one week apart, describing a gap of roughly five months. That distance is itself the most useful piece of information available about the timetable.

What is still undecided

Everything that determines whether the zone is usable by any particular business remains in draft:

• Which categories of business activity qualify for the incentives
• Which types of tax facility will actually be granted
• The size of each facility
• The eligibility requirements a recipient must meet
• The mechanism for applying and being granted a facility
• The duration of each incentive

In other words, the questions a client would ask before committing capital are, without exception, the ones that have not been answered.

The fifty-year headline is softer than it was reported

The figure that travelled furthest was a corporate income tax exemption of up to fifty years. It is worth reading what the authorities have actually said about it.

The tax authority has been clear that the arrangement will not apply identically to every business, that the detail will come through ministerial regulation, and that the incentives must still comply with international commitments including the global minimum tax. The Finance Minister has said the size and the duration are still under study and are not final.

None of that means the incentive will not be generous. It means nobody can currently tell you what it will be for their business, because that has not been decided.

What this means if you were thinking about it

Our advice has not changed, and the last five weeks have made the case for it rather than against it. Map the options. Understand which of your activities might plausibly qualify. Work out what a move would cost and what it would require in substance. Then wait for the text.

Anyone who restructured in July on the strength of the fifty-year headline is now holding a position built on a rule that does not yet exist, and which the government has said will be tightened by global minimum tax obligations.

The opportunity may well be real. It is not yet a thing you can plan around with any precision, and the difference between those two states is where expensive mistakes live.

One caveat on this note

Absence of publicity is not proof of absence. An implementing regulation can be signed and gazetted before it is widely reported, particularly in the weeks around a budget cycle. We have not seen publication as at the date above, and we would check the primary source before anyone acts on it either way.

We will update this when the text appears.