The Minister of Transportation (“MoT”) of Indonesia has issued an amendment to MoT Regulation 35 of 2021, i.e. MoT Regulation No. 2 of 2025 (“MoT Reg 2/2025”), introducing significant regulatory changes affecting air transport operations. These amendments impose new obligations on scheduled commercial air transport business entity (“Air Carriers“) and enhance regulatory oversight by the Directorate General of Civil Aviation (“DGCA”).
This update outlines the key provisions of MoT Reg 2/2025, highlighting its implications for Air Carriers and the compliance measures they must now undertake.
Obligation to Obtain a Flight Route Implementation Determination
Under MoT Reg 2/2025, Air Carriers must submit an application for the Flight Route Implementation Determination (Penetapan Pelaksanaan Rute Penerbangan/”PPRP“) for domestic flights to the DGCA no later than 30 (thirty) working days before the intended flight.[1]
Once the PPRP is granted, Air Carriers are required to operate flights strictly in accordance with the approved schedule set forth in the PPRP.[2]
Periodic Monitoring and Reporting Obligations
The Head of the Airport Authority Office is tasked with monitoring Air Carriers’ compliance with the PPRP every 14 (fourteen) calendar days. The results of such monitoring must be submitted to the DGCA within 7 (seven) working days, after which the DGCA will evaluate the reports and determine any necessary actions.[3]
Consequences of Non-Compliance
If, based on the DCGA’s evaluation, an Air Carrier is found to have canceled or operated flights inconsistently with its approved PPRP by 20% (twenty percent) or more, DGCA shall impose the following sanctions:
(a) Reduction of flight frequency; or
(b) Revocation of the affected flight routes.[4]
Following the reduction of flight frequency or revocation of flight routes, the slot time manager will revoke the slot times associated with the affected flight routes.[5]
Passenger Rights and Compensation Obligations
In cases where flight frequency reductions or route revocations impact passengers (“Users“), Air Carriers are required to fulfill Users’ rights to compensation as per applicable regulations.[6]
MoT Reg 2/2025 imposes stricter regulatory compliance measures on Air Carriers, ensuring that flight schedules are adhered to and that consumer rights are protected. Air Carriers must now take proactive steps to submit their PPRP applications in a timely manner and minimize flight cancellations to avoid regulatory sanctions.
Closing Remarks
The introduction of MoT Reg 2/2025 marks a significant regulatory shift in Indonesia’s air transport industry, emphasizing stricter compliance obligations for Air Carriers. The mandatory submission of PPRP, along with the stringent monitoring and reporting requirements, reinforces the government’s commitment to ensuring operational reliability and consumer protection. The severe consequences of non-compliance, including route revocations and passenger compensation obligations, highlight the importance of meticulous adherence to the new regulatory framework.
To navigate these regulatory changes effectively, Air Carriers should establish robust compliance mechanisms, including early submission of PPRP applications, close coordination with regulatory authorities, and strategic scheduling to minimize disruptions. Implementing an internal compliance monitoring system can further help mitigate risks associated with non-compliance and ensure operational continuity.
*The authors would like to acknowledge the contribution of our Junior Associate, Alma Dwi Ramadiani in preparing this legal alert.
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[1] Article 30 of the MoT Reg 2/2025
[2] Article 33 paragraph (1) of the MoT Reg 2/2025
[3] Article 34B of the MoT Reg 2/2025
[4] Article 34C paragraph (1) of the MoT Reg 2/2025
[5] Article 34C paragraph (2) of the MoT Reg 2/2025
[6] Article 34E of the MoT Reg 2/2025