What is PBG? Definition and Legal Framework

The Persetujuan Bangunan Gedung (PBG), or Building Approval, is a legally mandated regulatory instrument issued by the Indonesian government that affirms a building’s conformity with established technical standards, including but not limited to structural safety, spatial planning compliance, architectural integrity, functionality, health and hygiene, accessibility, building utility systems, and environmental sustainability.

Under the current regulatory framework, specifically Government Regulation No. 16 of 2021 on Buildings, which implements provisions of Law No. 28 of 2002 on Buildings, the PBG replaces the previously required Building Construction Permit (IMB – Izin Mendirikan Bangunan). However, the PBG is not a license in the traditional sense, but rather a comprehensive legal endorsement that a building plan or structure has fulfilled all technical and administrative requirements applicable under national and local regulations.

The implementation of PBG reflects a paradigm shift in how building supervision and urban planning governance are enforced in Indonesia. Unlike the IMB, which primarily served as pre-construction authorization, the PBG represents a multi-stage compliance model that governs the entire lifecycle of a building—from planning and construction to modification, change of use, and even demolition.

This shift from IMB to PBG is not merely a change in terminology or nomenclature, but rather a reflection of the Indonesian government’s efforts to improve transparency, standardization, and risk mitigation in the construction and real estate sectors. The PBG regime is intended to reduce regulatory ambiguity, close legal loopholes, and align national regulations with international best practices in urban development and sustainable infrastructure.

In practical terms, PBG introduces new procedural elements and documentation requirements that oblige building owners, developers, and investors to engage certified professionals—such as building planners, architects, and engineers—to prepare technical documents like the Building Technical Plan (RTB), as well as secure verification through the Online Building System (SIMBG).

The PBG regime applies not only to new constructions but also to existing buildings undergoing renovation, changes in function or use, structural modifications, or compliance corrections. It also emphasizes post-construction responsibilities, including building maintenance and functionality audits.

In essence, the PBG reinforces the legal principle that buildings must not only be authorized before development but remain compliant with evolving standards throughout their existence. This comprehensive approach is central to the Indonesian government’s goal of fostering safe, sustainable, and legally compliant urban growth.

Read More: What is SIMBG?

Key Differences Between IMB and PBG: Legal and Procedural Shifts in Indonesia’s Building Regulation

Although both IMB (Izin Mendirikan Bangunan) and PBG (Persetujuan Bangunan Gedung) serve as instruments of governmental oversight in regulating building development, they are governed by distinct legal philosophies, procedural requirements, and implementation mechanisms. The introduction of the PBG system represents a regulatory evolution aimed at strengthening accountability, technical compliance, and sustainability in the built environment. The core differences between IMB and PBG are as follows:

1. Purpose and Timing
   Under the IMB regime, the permit was essentially a pre-construction authorization, issued prior to any physical activity on-site. Its function was predominantly administrative in nature and served as a one-time license to proceed with construction.

   In contrast, the PBG framework operates as a regulatory compliance mechanism that assesses and approves technical conformity of a building throughout its entire lifecycle. The PBG may be applied before construction begins, during modifications, or after completion for legalization purposes. This shift enhances legal oversight and reflects a continuous compliance model, obliging building owners and developers to meet defined technical, spatial, and functional standards—not just once at the start, but persistently over time.

2. Legal Basis and Authority
   The IMB system was generally grounded in a variety of regional or local regulations (Peraturan Daerah), resulting in inconsistent implementation across jurisdictions. Local governments had discretionary authority to determine criteria, documentation, and processing standards, which often led to regulatory fragmentation and legal uncertainty.

   The PBG, however, is anchored in a centralized national legal framework, namely Government Regulation No. 16 of 2021 and its implementing regulations. This framework introduces standardized procedures, technical benchmarks, and digitalized submission mechanisms, thus enhancing uniformity, transparency, and legal certainty. Moreover, the PBG is processed through the SIMBG (Sistem Informasi Manajemen Bangunan Gedung) platform, which ensures all applications are centrally monitored and verified.

3. Terminology, Documentation, and Professional Involvement
   The IMB primarily required basic architectural plans and administrative data, with limited technical scrutiny. It often overlooked comprehensive safety or functionality considerations.

   Conversely, the PBG demands a robust technical submission, including:

   • Rencana Teknis Bangunan (RTB) / Building Technical Plan

   • Certificates of Functional Reliability

   • Environmental and spatial compatibility assessments

   • Declarations and validations from certified technical professionals, such as licensed architects, structural engineers, and mechanical-electrical experts

     This technical emphasis ensures that buildings are not only legally recognized but also technically sound, environmentally compatible, and functionally viable according to Indonesian National Standards (SNI).

4. Compliance Enforcement and Lifecycle Monitoring
   IMB approvals were largely static and lacked active post-issuance supervision. Once obtained, there was minimal legal obligation to reassess compliance unless major violations occurred.

The PBG system introduces structured oversight and enforcement mechanisms, requiring compliance at various stages of construction and use. In certain cases, building owners must also obtain SLF (Sertifikat Laik Fungsi)—a certificate confirming that the completed structure is safe and operable based on its approved plans.

Read More: Tanda Daftar Gudang

PBG Application Procedure: Legal and Technical Stages for Compliance

Obtaining a Persetujuan Bangunan Gedung (PBG) in Indonesia is a structured and highly regulated process designed to ensure that all building activities align with national technical, environmental, and spatial planning standards. The procedure is not merely administrative, but involves technical, legal, and professional assessments coordinated across multiple stakeholders, both private and governmental.

1. Preparation of Technical Documents
   The first and most critical stage in the PBG application process is the preparation of the Building Technical Plan (Rencana Teknis Bangunan – RTB). This document must be drafted by certified professionals, including licensed architects, structural engineers, and mechanical-electrical experts, and must strictly adhere to the provisions set forth in:

   • Government Regulation No. 16 of 2021 on Buildings

   • Relevant Indonesian National Standards (SNI)

   • Local zoning regulations and building codes

     The RTB includes detailed architectural drawings, structural calculations, utility system plans, and assessments on building safety, fire resistance, accessibility, and environmental impact.

2. Submission through SIMBG
   All technical documents and supporting materials are to be uploaded to the Sistem Informasi Manajemen Bangunan Gedung (SIMBG), an integrated online platform established and administered by the Ministry of Public Works and Housing (PUPR). This platform enables end-to-end submission, status tracking, inter-agency coordination, and issuance of digital certificates.

   Applicants must register, complete the required forms, and upload the RTB and any supplementary documentation. The system routes the application to the appropriate regional or sectoral authorities for assessment.

3. Assessment and Verification
   The SIMBG system forwards the application to the local government authorities or technical evaluation team responsible for reviewing compliance with:

   • Spatial and land use regulations (RTRW/RDTR)

   • Functional classification of buildings

   • Technical design integrity and safety standards

     In some cases, onsite inspections or clarification meetings may be required. The authorities may also coordinate with relevant ministries or professional associations to validate technical submissions.

4. Issuance of PBG
   Upon successful verification, the PBG certificate is issued electronically via SIMBG, granting the applicant formal legal acknowledgment that their building plans comply with all applicable laws and standards. Only after obtaining the PBG may the applicant lawfully commence construction or renovation activities. For projects already in progress, PBG is mandatory for continued legal compliance and the issuance of downstream permits such as SLF (Sertifikat Laik Fungsi).

Read More: What is K3L

Legal Consequences for Non-Compliance with PBG Regulations

Failure to comply with PBG requirements constitutes a violation of Indonesian building law and may result in multi-tiered legal consequences, as stipulated under Article 346 of Government Regulation No. 16 of 2021. Sanctions are designed to enforce public safety, regulatory discipline, and environmental accountability.

Administrative Sanctions May Include:

1. Written Warnings
   Issued to building owners or developers found to be in breach of PBG obligations or technical requirements.
   
2. Temporary Suspension of Construction Activities
   Authorities may halt construction until compliance is restored or documentation is corrected.
   
3. Forced Demolition or Dismantling Orders
   Applied to structures built without PBG or in violation of approved plans, particularly when safety is compromised.
   
4. Seizure or Confiscation of Equipment or Materials
   In certain severe cases where public safety is at immediate risk.
   

Civil and Criminal Liabilities:

1. Developers or property owners may be held civilly liable for damages caused by unsafe or illegal structures, including property damage or injury to third parties.
   
2. In extreme cases involving gross negligence or deliberate evasion, criminal sanctions including fines or imprisonment may be pursued under applicable criminal statutes.

Conclusion

Compliance with the PBG framework is not optional—it is a mandatory legal requirement for all forms of building development in Indonesia. The procedure, while technically detailed, is designed to safeguard public welfare, environmental sustainability, and urban order. Failure to adhere not only jeopardizes a project’s legal standing but also exposes developers to substantial risk, both financially and reputationally.

At ET Consultant, we provide full-scope legal and technical advisory services for PBG acquisition, including document preparation, SIMBG submission, coordination with government agencies, and post-issuance support. Our multidisciplinary team ensures that your development project meets all regulatory benchmarks—efficiently and lawfully.

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ET Consultant is a Business Consultant and Legal Consultant Expert that provides support for local and multinational clients to start and manage their business operations in Indonesia. ET Consultant specializes in Business Incorporation, Licensing & Legal, Accounting & Taxes, Immigration, and Advisory Services.

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