Indonesia has introduced a significant proceduralreform that may substantially accelerate the trademark registration process.The change arises from Minister of Law Regulation No. 5 of 2026 on TrademarkRegistration, which refines the timeframe for substantive examination oftrademark applications.

The regulation forms part of a broaderlegislative trajectory aimed at improving the efficiency of intellectualproperty administration in Indonesia. In particular, the reform builds upon theearlier amendments introduced by the Job Creation Law (Law No. 6 of 2023),which had already shortened the timeframe for substantive examination under theIndonesian trademark system.

Taken together, these developments signal a clearpolicy direction toward a faster and more streamlined trademark registrationprocess.

Substantive Examination under the 2016 Trademark Law

Under Law No. 20 of 2016 on Trademarks andGeographical Indications, the Directorate General of Intellectual Property(“DGIP”) was granted a relatively lengthy period to conduct substantiveexamination.

Article 23 paragraph (5) of the law providesthat:

“Substantive examination as referred to inparagraphs (3) and (4) shall be completed within a maximum period of 150 (onehundred and fifty) days.”

Accordingly, once a trademark application enteredthe substantive examination stage, DGIP had up to 150 days to determinewhether the mark satisfied the registrability requirements under Indonesiantrademark law.

This examination period alone could extend toapproximately five months, which in practice contributed significantlyto the overall duration of the trademark registration process.

Procedural Reform under the Job Creation Law

A significant procedural acceleration wasintroduced through Law No. 6 of 2023 concerning the Job Creation Law,which amended the substantive examination timeframe.

Article 23 paragraph (6) now provides that:

“Substantive examination shall be completedwithin a maximum period of 90 (ninety) days.”

This amendment reduced the examination period by 40percent, representing an important policy shift toward improvingadministrative efficiency within Indonesia's intellectual property system.

The reform was introduced as part of a broadereffort to streamline regulatory procedures and strengthen Indonesia'sinvestment climate.

Minister of Law Regulation No. 5 of 2026

Further procedural clarification was subsequentlyintroduced through Minister of Law Regulation No. 5 of 2026 on TrademarkRegistration.

The regulation distinguishes between applicationsthat proceed without opposition and those that are subject toopposition during the publication period.

Uncontested Applications

Article 39 paragraph (2) provides that where noopposition is filed during the publication period, the substantiveexamination must be completed within 30 days from the end of the publicationperiod.

This provision represents a substantialprocedural acceleration compared with the previous framework.

In practical terms, the Directorate General ofIntellectual Property may now complete substantive examination for uncontestedapplications within approximately one month, thereby enabling theregistration process to proceed significantly faster than under the earlierregulatory regime.

Applications Subject to Opposition

Where an opposition is filed during thepublication period, Article 40 paragraph (2) provides that substantiveexamination must be completed within 90 days following the expiry of thedeadline for submitting counter-statements.

This distinction reflects the additionalprocedural considerations involved when objections or competing trademarkrights must be evaluated during the examination process.

Nevertheless, even in contested cases, theexamination period remains aligned with the 90-day framework introduced bythe Job Creation Law.

Regulatory Trend Toward Faster Trademark Examination

These successive reforms demonstrate a clearregulatory trajectory toward accelerating trademark examination in Indonesia.

The maximum timeframe for substantive examinationhas progressively decreased from 150 days under the 2016 Trademark Law,to 90 days under the Job Creation Law, and now potentially 30 daysfor uncontested applications under Minister of Law Regulation No. 5 of2026.

This gradual reduction reflects the Indonesiangovernment's intention to modernize its intellectual property administrationand improve procedural efficiency within the trademark system.

Strategic Implications for International Trademark Filings

For international brand owners and trademarkpractitioners, the reform may have several practical implications.

First, the shortened examination timeframe mayallow applicants to secure trademark registration considerably faster thanunder the previous regulatory framework, particularly in cases where noopposition is filed.

Second, faster examination may provide greaterpredictability in trademark registration timelines, which is often acritical consideration for multinational companies managing trademarkportfolios across multiple jurisdictions.

Third, the procedural reform may enhanceIndonesia's attractiveness as a jurisdiction for trademark protection, as amore efficient examination process enables brand owners to obtain enforceablerights within a shorter period.

From a broader perspective, the reform alsoreflects Indonesia's continuing efforts to align its intellectual propertyadministration with international expectations for modern trademark systems.

Concluding Remarks

The introduction of Minister of Law RegulationNo. 5 of 2026 marks an important procedural development in Indonesia'strademark system.

By reducing the timeframe for substantiveexamination from 150 days under the 2016 Trademark Law to potentially only30 days for uncontested applications, the regulation represents asignificant step toward improving the efficiency of trademark registration.

For international trademark practitioners andbrand owners, this development signals a faster and more streamlined pathwayto securing trademark protection in Indonesia.