Indonesia's Business Competition Supervisory Commission (KPPU) has periodically adjusted the asset and turnover thresholds that trigger mandatory merger notification under Government Regulation No. 57 of 2010. For deal teams accustomed to checking thresholds once at the term sheet stage, the periodic adjustments are a recurring trap: a transaction structured against last year's thresholds may cross this year's line.
The mechanics remain a post-closing notification regime — unlike many jurisdictions, Indonesia does not require pre-closing clearance, but does require notification to KPPU within 30 business days of closing where the combined assets or turnover of the merging parties exceed the prescribed thresholds. Missing the notification window carries an administrative fine, calculated per day of delay, that has in practice been enforced against both large and mid-market transactions.
We increasingly advise clients to build a KPPU threshold check into the earliest stage of transaction planning — alongside, not after, tax structuring — since the combined-group calculation can pull in revenue from affiliates that a deal team might not initially think to include.
For any transaction involving an Indonesian target or an Indonesian-incorporated acquirer, we recommend confirming current thresholds and the notification timeline before signing, rather than treating it as a closing-mechanics item.
