Permenkum 27/2025 Explained: What Indonesian Venues Need to Know
In August 2025 Indonesia replaced its music royalty implementing regulation. Here is what changed, who it covers, and where it leaves questions open.
What It Is
Minister of Law Regulation No. 27 of 2025 — commonly shortened to Permenkum 27/2025 — implements Government Regulation No. 56 of 2021 on the management of song and music copyright royalties. It revoked the previous implementing regulation, MOLR 9/2022.
The stated aim was to strengthen legal protection for composers, copyright holders and neighbouring rights owners, while giving clearer guidance to businesses that play music in public spaces. The 2022 regulation had been criticised for unclear distribution mechanisms, a limited administrative role for LMKN, and insufficient transparency.
What Changed
Five substantive changes matter to venue operators:
- LMKN strengthened as central collector — royalties for commercial use are collected centrally rather than negotiated with individual LMK
- Provincial units introduced — extending collection infrastructure beyond Jakarta
- Analogue and digital use separated — with distinct treatment for each
- 23 categories of analogue commercial use defined — removing ambiguity about which premises are in scope
- Audit scope expanded — with stricter consequences, including revocation of LMK operational permits
Which Premises Are Covered
The 23 categories of analogue commercial use include:
- Accommodation facilities
- Food and beverage establishments
- Shopping centres
- Sports facilities and fitness centres
- Office buildings
- Cinemas
- Transportation services
- Entertainment and tourism venues
- Commercial events
If your premises appear on that list, music played publicly is commercial use under the regulation.
Who Carries the Obligation
This is the provision that resolved a long-running argument. Article 20(4) places the obligation to pay royalties for commercial use in public services on the event organiser or the business owner — not the performer.
The point was reinforced by the Supreme Court in the dispute between Agnez Mo and Ari Bias, and it settles the practical question for venues: the establishment is the responsible party.
It also means the obligation cannot be contracted away. A supplier’s assurance does not transfer liability from the venue.
What It Does Not Resolve
The regulation gives greater certainty than its predecessor, but questions remain open. The mechanism for detecting music use is not settled — academic and industry commentary has proposed music recognition technology or digital fingerprinting at commercial venues, but neither is mandated.
Whether payment obligations apply retrospectively or only prospectively is also unresolved.
And the regulation governs collective management. It does not, and cannot, address rights that sit outside collective repertoire — reproduction, master rights and publishing rights for commercial use remain matters for the rights owners themselves.
What This Means in Practice
For most venues the practical position is straightforward: if your premises are in one of the 23 categories and you play music publicly, you have a royalty obligation, and it sits with you rather than your supplier.
Music licensing through LMKN addresses public performance. It does not address the other three of the five commercial music rights. A venue that has paid LMKN and considers the matter closed has covered part of its exposure.
MUSICVYBE’s direct licensing covers all five rights in one subscription. Because the catalogue sits outside LMKN and LMK repertoire, our position is that no collective licence is required for the music we deliver.
Related Pages
| Music Licensing Compliance in Indonesia | LMKN, LMK and the five rights |
| Background Music Services | All verticals in Indonesia |
| Indonesia | Country hub |
Frequently Asked Questions
When did Permenkum 27/2025 take effect?+
It was issued by the Minister of Law in August 2025, replacing the previous implementing regulation MOLR 9/2022.
Does it apply to digital as well as analogue use?+
Yes. One of its changes was to distinguish explicitly between analogue and digital commercial use, with separate treatment for each.
Does the regulation set royalty rates?+
Rates are set by ministerial decree rather than within the regulation itself. The regulation governs the collection, pooling and distribution structure.
Is a restaurant in Bali treated differently from one in Jakarta?+
No. The framework is national. Permenkum 27/2025 introduced provincial units to extend collection infrastructure, but the obligations themselves apply uniformly.
Understand Your Position Under Permenkum 27/2025
Five rights, one subscription, fully managed. Talk to MUSICVYBE.