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The question of whether a virtual office can be used for OSS should actually be answered by looking at the function of the address within the business licensing system. OSS is not merely a platform for issuing NIBs. It connects business operator data, business activities, business locations, risk levels, and the licensing requirements that apply. Under the latest framework, Risk-Based Business Licensing is governed by Government Regulation No. 28 of 2025, which covers basic requirements, Business Licensing, PB UMKU, OSS services, supervision, and sanctions.
OSS Does Not Only Examine the Company's Address
An NIB is the official identification of a business operator for starting or conducting business activities in Indonesia. However, the OSS process does not stop at the business entity's identity. The system also connects business activities with their risk levels and applicable licensing obligations. Therefore, the use of Virtual Office Jakarta needs to be assessed based on the position of the address within the business structure, rather than simply whether the provider offers a corporate address.
This distinction matters because the address used in corporate administration does not automatically become a location that satisfies all business activity requirements. If a particular activity requires location, building, environmental, or spatial planning requirements, those aspects need to be assessed based on the actual activity being conducted.
A Virtual Office Address and Business Activity Location Are Not Always the Same
Within OSS, business operators need to distinguish between the business entity's address and the location where business activities are conducted. This distinction becomes increasingly important when not all business activities are carried out at the administrative office address.
For example, a company may use Virtual Office Central Jakarta as its business address while conducting its operational activities elsewhere. Such a situation cannot simply be treated as one address without considering the type of activity and the data required during the licensing process. Similarly, a company choosing Virtual Office South Jakarta should ensure that the address is appropriate for the function it intends to register within OSS administration.
KBLI Determines How Important Location Is in OSS
A common mistake is assuming that all business activities have the same location requirements. In reality, KBLI (Indonesian Standard Industrial Classification) describes the business activities being conducted and forms an important part of determining the applicable licensing framework and requirements.
For service-based businesses whose activities can be conducted administratively or digitally, the need for a physical office may differ from activities requiring a business premises, production facilities, warehouses, or other specific infrastructure. Therefore, before using a virtual office for OSS purposes, the business operator should first review the selected KBLI and the characteristics of the actual business activity.
In other words, the address should follow the business activity requirements, not the other way around. Virtual Office may be an option for certain business address needs, but it should not be used as a reason to disregard location requirements that apply to the business activity.
How Does Government Regulation No. 28 of 2025 Affect the Use of Virtual Offices?
Government Regulation No. 28 of 2025 is an important legal basis for this discussion because it governs the implementation of Risk-Based Business Licensing. The regulation covers several components, including basic requirements, Business Licensing, PB UMKU, OSS services, and supervision. It came into effect on June 5, 2025 and revoked Government Regulation No. 5 of 2021.
As a result, the use of a virtual office cannot be assessed merely by asking whether the address can be entered into the OSS system. The more important question is whether the address and location being used comply with the requirements applicable to the specific business activity.
OSS itself provides information and services relating to business locations, including information concerning RDTR, industrial areas, KEK, KPBPB, PSN, and other spatial planning matters. This demonstrates that location is a substantive part of the licensing ecosystem, rather than merely administrative data.
A Virtual Office Does Not Automatically Replace Location Requirements
For example, a company may use Virtual Office Thamrin as its business address. If its KBLI and business model can genuinely be conducted without specific physical facilities, the address may be assessed according to its relevant administrative function.
The situation is different, however, if the business activity requires a physical location, spatial planning approval, environmental approval, building requirements, or other basic requirements. OSS places these basic requirements within the Risk-Based Business Licensing framework.
Therefore, having a virtual office does not automatically remove the need for an actual business location. Nor should it be understood as a way to bypass requirements that are mandatory based on the nature of the business activity.
What If the Company Has More Than One Location?
A company also needs to be careful when the virtual office is used only as its domicile or administrative address while its business activities are conducted elsewhere. In such circumstances, the location structure needs to be mapped according to the function of each location.
For example, a company may use Virtual Office SCBD as its business address while also having another location that requires physical facilities. In that situation, the virtual office address does not automatically replace the actual business activity location. The same principle applies if a company uses Virtual Office TB Simatupang while conducting business activities across several different locations.
OSS even provides specific guidance concerning changes to business operator data and corrections to business addresses. This demonstrates that address information within the system should not be entered casually and then left unchanged when the actual business circumstances have changed.
Finally, Is a Virtual Office Valid for OSS Registration?
A virtual office can be used in the context of OSS administration as long as the function of the address is consistent with the actual business circumstances and the requirements applicable to the activity being conducted. However, it would be inaccurate to conclude that every virtual office automatically works for every type of business activity or replaces all business-location requirements.
The first considerations should be the business entity, KBLI, type of activity, risk level, business location, and any applicable basic requirements. Only after these factors have been assessed can it be determined whether a virtual office is appropriate for the address requirements within OSS.
Therefore, the more appropriate question is not simply “Can a virtual office be used for OSS?”, but “Is the virtual office address appropriate for the business address function and licensing requirements of the activity registered through OSS?”
This approach is legally safer because NIB and OSS do not operate independently. Both form part of the Risk-Based Business Licensing system, which connects the identity of the business operator with its actual business activities and business locations.
Find the Right Virtual Office Jakarta Location for Your Business Needs
A professional business address helps establish credibility from the very beginning. Every business has unique requirements, whether it's a strategic location for meeting clients or a business address that supports day-to-day operations.
Servio provides a range of Virtual Office Jakarta solutions in Jakarta's prime business districts. Our team is ready to help you find the location that best fits your business needs and arrange a site visit before you make your decision.
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