Indonesia: Healthcare Licensing & Facility Registers
Demonstrating how differences between corporate records, OSS-RBA licensing data, and facility-specific healthcare authorisations identify specific matters requiring verification before the target's authorised operating scope is confirmed.
Do the target's current facility-level business licences and healthcare-sector approvals fully substantiate the specialized clinical services contributing to projected expansion revenues?
- • House of Representatives — Law No. 17 of 2023 on Health (UU Kesehatan — Facility Licensing Provisions)[cite: 3] ↗
- • Government of Indonesia — Government Regulation No. 28 of 2025 (Risk-Based Business Licensing Implementation via OSS)[cite: 3] ↗
- • Ministry of Health — Regulation No. 11 of 2025 on Business Activity and Product/Service Standards for Risk-Based Business Licensing in the Health Subsector ↗
- • Statistics Indonesia (BPS) — Regulation No. 7 of 2025 on KBLI 2025 (Business Activity Classification; applicability to target's registered activities to be verified) ↗
Facility-level healthcare authorisations incomplete
Illustrative evidence profile: The scenario assumes an acquisition of a private hospital and clinical operator in West Java, but specific operational facility approvals have not been verified in the transaction records:
- • Current facility-level business licences and healthcare-sector approvals applicable to the hospital, clinic and relevant specialized services, including any required approvals for the expanded clinical activities: MISSING
- • Reconciliation of the target's registered business activities under the applicable KBLI classification with the actual clinical services provided at each relevant facility: MISSING
- • Environmental, building, and operational safety authorisations applicable to the relevant site and specialized inpatient units: MISSING
Analyst note: Differences between corporate registry entries (NIB/KBLI) and specialized healthcare facility authorisations require verification before confirming operating scope. The absence of a branch-specific permit in the data room does not establish statutory non-compliance or operating illegality, but prevents confirming that the facility's full scope of services is documented.
Revenue assumptions tied to unevidenced services remain conditional
The target's investment model projects annual specialized outpatient and surgical clinic revenue of IDR 14.5 billion / year attributable to newly expanded operating units.
The projected IDR 14.5 billion annual revenue assumption remains unverified to the extent it depends on the outstanding authorisation evidence. It is neither accepted as fully substantiated nor automatically reduced to zero. The baseline financial valuation of compliant core healthcare activities is retained, and only the unverified expansion assumption remains unresolved pending documentary review.
- • No automatic valuation haircut or balance-sheet write-down is imposed.
- • No arbitrary revenue deduction is introduced for compliant core hospital operations.
- • The documented financial baseline of general healthcare operations is maintained.
- • The underwriting condition is strictly confined to the IDR 14.5 billion revenue line dependent on the specific unevidenced clinical authorisations.
Targeted request for information (RFI)
- • Request the current NIB and relevant OSS-RBA records, current facility-level business licences, and applicable healthcare-sector approvals.
- • Obtain the documentary reconciliation between registered KBLI activities and the actual clinical services provided at each facility.
- • Review inspection reports, building approvals, or correspondence issued by the competent health authority regarding branch expansion approvals.
- • Reassess the IDR 14.5 billion revenue assumption against the verified authorisations and service-to-revenue mapping. Determine whether any corrective filing, licence amendment or other transaction protection is necessary only if the evidence establishes a material gap.
Transaction response: Any proposed condition precedent (CP), operating covenant, or indemnity protection should follow the verified evidence, materiality, and the required timeline for administrative regularisation.
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