Indonesia has introduced a significant regulatory update to its trademark registration framework through Permenkum No. 5 of 2026 on Trademark Registration (the 2026 regulation). This new regulation replaces the previous implementing framework under Permenkumham No. 67 of 2016 and its amendment, Permenkumham No. 12 of 2021, reflecting the government’s broader effort to modernize administrative procedures, improve efficiency, and align practice with evolving commercial realities.

The 2026 regulation introduces a number of procedural refinements, clarifications and structural improvements affecting trademark prosecution, recordals and renewals. While many of the substantive legal principles remain anchored in the parent legislation – namely, Law No. 20 of 2016 on Trademarks and Geographical Indications (as amended) – the practical impact of these regulatory changes is considerable.

Streamlining of filing formalities

One of the most immediate changes is the simplification of administrative filing requirements.

Under the previous regime, applicants were required to submit the trademark application form in two copies. This duplicative requirement has now been removed. The elimination of redundant documentation reflects a broader shift towards digitalization and administrative efficiency, particularly given that filings are predominantly conducted through the Directorate General of Intellectual Property’s electronic system.

In a similar vein, the 2026 regulation removes the prescriptive requirement to submit three physical copies of the trademark label within specified size parameters (2 × 2 cm to 9 × 9 cm).

While a representation of the mark remains required, the removal of rigid formatting requirements provides greater flexibility, especially for non-traditional marks (e.g., 3D marks, sound marks and holograms), which are now expressly accommodated under the regulation.

Introduction of mandatory applicant identity documentation

A notable and substantive procedural change is the introduction of stricter identity verification requirements.

Applicants must now submit valid identification documents corresponding to the applicant itself, such as the following:

• National Identity Card (KTP)
• Limited Stay Permit (KITAS)
• Permanent Stay Permit (KITAP)
• Passport (for foreign applicants)

For legal entities, official documentation evidencing incorporation or establishment must also be provided.

Crucially, the regulation clarifies that the identity of the appointed proxy cannot substitute for the identity of the applicant. The identification must correspond to the actual rights holder (e.g., director or authorized signatory executing the power of attorney).

This represents a tightening of formal compliance standards. Failure to meet these requirements may result in the application being deemed incomplete and not processed further, thereby increasing the importance of upfront diligence and proper documentary preparation.

Transition to electronic certificates

Another notable development under the 2026 regulation is the formalization of the issuance of electronic trademark certificates. While Indonesia had already been moving towards digitalization in practice, the new regulation firmly embeds this approach within the legal framework.

Under the updated process, once a trademark successfully passes substantive examination, the Minister will proceed to register the mark, notify the applicant and issue the certificate in electronic form.

Enhanced requirements for micro and small enterprises (MSEs)

The 2026 regulation also introduces a more structured and rigorous framework for trademark applications and renewals filed by micro and small enterprises (MSEs).

Applicants claiming MSE status are now required to submit additional documentation, including a recommendation letter issued by the relevant authority confirming their status, as well as a risk-based business licence registered through Indonesia’s Online Single Submission (OSS) system. Depending on the nature of the entity, further documentation – such as a company deed of establishment or cooperative approval documents – may also be required.

For applicants, this means that careful coordination with local regulatory frameworks, particularly the OSS system, will now be an essential part of the trademark filing strategy.

Significant improvements in renewal processing

Among the most commercially impactful reforms introduced by the 2026 regulation is the substantial acceleration of trademark renewal processing. Under the previous regime, the recordal of a renewal could take up to two months, creating a degree of administrative lag that was not always aligned with commercial timelines.

The new regulation dramatically shortens this timeframe. Once a renewal application is filed and deemed complete, the recordal may now be processed within as little as four business days. In tandem with this, the period within which the registry must notify the applicant has also been reduced to a maximum of three business days.

This change represents a meaningful improvement in efficiency and provides greater certainty for trademark owners managing large portfolios.

Clarification on recordal of name and address changes

The 2026 regulation provides helpful clarification regarding the recordal of changes to the name and/or address of trademark applicants and proprietors. Importantly, the regulation confirms that such recordals are not limited to situations involving an actual change in legal identity or location.

Instead, applicants may also file recordals to correct clerical or administrative errors made at the time of the original filing. This clarification is significant, as it resolves a degree of ambiguity under the previous framework, where it was not always clear whether purely corrective amendments – such as typographical errors – could be formally recorded.

From a practical perspective, this development enhances the accuracy and reliability of the trademark register. It allows applicants to rectify discrepancies without resorting to more complex procedural workarounds and ensures that the register more accurately reflects the true identity of rights holders.

Adjustments to recordal and assignment procedures

The 2026 regulation also introduces a number of refinements to the procedures governing recordals, particularly in relation to trademark assignments and changes of particulars. These changes reflect an effort to streamline administrative timelines while maintaining procedural discipline.

On the one hand, applicants are now subject to a shorter timeframe – two months, rather than three – to remedy any deficiencies identified in assignment recordal applications. This places a greater onus on applicants and their representatives to respond promptly to registry notifications and to ensure that all required documentation is prepared in a timely and accurate manner.

On the other hand, the regulation extends the period within which the registry must issue notifications relating to recordals, including both assignments and changes of name or address. The notification period has been increased from 15 working days to 30 working days, providing the registry with additional administrative flexibility.

Taken together, these changes suggest a rebalancing of responsibilities: applicants are expected to act more quickly in addressing deficiencies, while the registry is afforded a more realistic timeframe to process and communicate decisions.

Introduction of detailed framework for collective marks

A further important development is the introduction of a more detailed and structured framework governing applications for collective marks. While collective marks were recognized under the broader trademark law, the procedural requirements for their registration were previously less clearly articulated.

The 2026 regulation addresses this gap by setting out specific documentary and substantive requirements. Applicants – typically associations, cooperatives or other collective entities – must now provide, among other things, a statement of ownership, rules governing the use of the mark, and documentation evidencing the legal status of the collective body. These rules must address key aspects such as the characteristics and quality of the goods or services, mechanisms for supervision, and sanctions for misuse.

This development enhances legal certainty and aligns Indonesia’s approach more closely with international best practices. By requiring clear governance structures for collective marks, the regulation helps ensure that such marks fulfil their intended function – namely, to indicate shared characteristics and standards among multiple users – while also safeguarding consumer trust.

Formal recognition of force majeure

For the first time, the Indonesian trademark regulatory framework expressly recognizes the concept of force majeure in the context of procedural deadlines. The 2026 regulation allows applicants and trademark owners to request extensions of time where they are unable to meet deadlines due to extraordinary circumstances such as natural disasters, civil unrest or other comparable events.

To avail themselves of this relief, applicants must submit a formal request supported by documentary evidence demonstrating the occurrence and impact of the force majeure event. If approved, the authorities may grant an extension for fulfilling outstanding requirements across a range of procedures, including applications, priority claims, renewals and recordals.

The introduction of this provision represents an important step towards greater flexibility and fairness in the administration of trademark rights. It acknowledges that strict procedural timelines may not always be appropriate in exceptional circumstances and provides a structured mechanism for accommodating unforeseen disruptions.

Faster issuance of official extracts

Finally, the 2026 regulation significantly improves the efficiency of obtaining official extracts of trademark certificates. Under the previous framework, such extracts could take up to 15 business days to be issued, which could pose challenges in time-sensitive situations such as enforcement actions or commercial transactions.

The new regulation reduces this timeframe dramatically, allowing official extracts to be issued within just one business day from the date of request. This enhancement is particularly valuable for practitioners and rights holders who require prompt access to certified information from the trademark register.

By accelerating this process, the regulation supports more efficient due diligence, facilitates faster transactional workflows and strengthens the overall responsiveness of the trademark system to commercial needs.

Final word

Ultimately, the incoming Permenkum No. 5 of 2026 on Trademark Registration represents a comprehensive modernization of Indonesia’s trademark administrative framework. The key themes of digitalization, procedural efficiency and regulatory clarity are clearly evident across multiple aspects of trademark prosecution and portfolio management.

From a practitioner’s perspective, the most impactful changes include:

• Accelerated examination timelines,
• Strict identity documentation requirements,
• Rapid renewal processing, and
• Increased formalization of procedural rules (e.g., collective marks and force majeure).

While the reforms generally enhance efficiency, they also impose stricter compliance obligations, particularly at the filing stage. As such, applicants and practitioners must exercise greater care in preparing documentation to avoid delays or procedural deficiencies.