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Legal News Update

Contributors: Almaida Askandar, S.H., MBA, and Renata Luisa Kusuma, S.H.

Published on 28 June 2026 by IABF Law Firm, Jakarta, Indonesia.

Flight Approval and Security Clearance Framework for Indonesia’s Airspace

Indonesia has updated its aviation authorization framework through two distinct regulatory instruments, each governing a different dimension of aircraft operations within Indonesian airspace. The first is Decree of the Director General of Air Transport No. PR-DJPU 04 of 2025 on Flight Approval, which modernizes and consolidates the civil aviation approval system administered by the Ministry of Transportation. The second is Minister of Defense Regulation No. 3 of 2024 on Security Clearance, which establishes, for the first time at the ministerial level, a comprehensive framework for defense-related flight authorization.

Although both instruments relate to aircraft operations in Indonesian airspace, they address fundamentally different legal concerns. Flight Approval governs the operational and civil aviation dimensions of a flight, while Security Clearance addresses matters of national defense and airspace sovereignty. The two approvals are parallel requirements and neither substitutes for the other.

1.     Flight Approval Framework

PR-DJPU 04 of 2025 does not introduce an entirely new licensing regime. Rather, it modernizes, consolidates, and brings coherence to an existing framework that had grown unwieldy over time.

The decree was issued on the basis of four principal considerations.

1. 1. The first was regulatory fragmentation. The previous Flight Approval framework had been amended on three separate occasions over the course of seventeen years, resulting in a disjointed set of rules spread across multiple instruments. PR-DJPU 04 of 2025 consolidates these into a single, unified regulation.
   2. The second was an outdated legal basis. Several of the statutes and regulations originally cited as the legal foundation for the prior framework had since been amended or superseded. The new decree realigns the Flight Approval framework with Indonesia’s current body of aviation legislation.
   3. The third was evolving industry needs. Changes in the aviation sector, including greater scheduling complexity, increased use of aircraft substitutions, and more sophisticated overflight management requirements, necessitated updated operational rules that better reflect how the industry functions today.
   4. The fourth, and perhaps most operationally significant, was the formal expansion of delegated authority. Under the new decree, Airport Authority Offices (KOBA) are now empowered to issue certain categories of Flight Approval directly. Previously, this authority rested exclusively with the Directorate General of Air Transport at the central level. This decentralization is intended to streamline the approval process, particularly for operators based in regional airports.

Scope of Flight Approval

The categories of flights requiring Flight Approval remain largely consistent with the previous framework, including:

• • scheduled commercial flights operating outside an approved Route Implementation Permit (PPRP), including schedule revisions, additional flights, aircraft substitutions, rerouting, and frequency changes;
  • domestic and international non-scheduled commercial flights;
  • foreign non-commercial flights;
  • foreign scheduled aircraft conducting overflight outside the applicable Summer/Winter Overflight Approval; and
  • foreign non-scheduled or non-commercial aircraft transiting Indonesian airspace. 

2.     Security Clearance Framework for Indonesia’s Airspace

Prior to Permenhan No. 3 of 2024, Security Clearance was addressed only in broad terms under Government Regulation No. 4 of 2018 on the Security of Indonesian Airspace, without any dedicated ministerial implementing rules. The new regulation fills this gap by establishing comprehensive procedures governing the issuance, validity, and revocation of Security Clearances.

a.      Legal Basis and Authority

Drawing its authority from Government Regulation No. 4 of 2018, the regulation affirms that Security Clearance constitutes a flight authorization granted by the Minister of Defense. This formally distinguishes the Security Clearance regime from the Flight Approval regime: Flight Approval falls under the Ministry of Transportation and governs the operational aspects of aviation, while Security Clearance falls under the Ministry of Defense and is concerned with national defense and airspace sovereignty.

b.      Aircraft Requiring Security Clearance

A Security Clearance is required for three categories of aircraft: foreign State aircraft, including military, police, customs, and other government-registered foreign aircraft; foreign non-scheduled civil aircraft; and Indonesian civil aircraft conducting non-commercial operations within designated restricted areas.

c.      Issuance Procedure

The regulation also codifies several procedural provisions that were previously unaddressed at the ministerial level. Where an application is approved, the Chief of Staff of the Indonesian Air Force (KSAU) is the authority responsible for issuing the Security Clearance. Where an application is rejected, KSAU is required to issue a formal written rejection letter setting out the reasons for the decision, introducing a due process and transparency requirement not previously formalized in any implementing regulation. Additionally, a Security Clearance issued to Indonesian civil aircraft for non-commercial operations in restricted areas is valid only for the specific route and period of time as applied for, and does not confer any broader or open-ended authorization.

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Disclaimer

This news update is prepared for general informational purposes only. The content does not constitute legal advice, a legal opinion, or counsel from IABF Law Firm. The information contained herein may not reflect the most current developments. Any quotation, distribution, or use of this information for any purpose is solely at the user’s own risk.