Indonesia’s four-month registration target: what changes for trade mark and design owners

October 14, 2026
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Articles

Indonesia’s Directorate General of Intellectual Property (DGIP) has announced that trade mark and industrial design applications received from 1 October 2026 are targeted for completion within four months. This follows a five-month target for applications received from 18August 2026.

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The change is welcome. It is, however, an administrative service target, not a new statutory registration deadline. The announcement does not amend either the Trade Marks Law or the Industrial Designs Law, and DGIP says further acceleration will require amendments to both. The existing publication, opposition and response periods remain in force.

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For portfolio owners, the consequences go beyond faster registration. A conflicting application may reach the register before a six-month priority period has expired. For designs, faster publication also brings confidentiality and product launch decisions forward.

Trade marks: four months requires faster processing

Trade mark procedure is now governed by Minister of Law Regulation No. 5 of 2026 on Trade Mark Registration. For an application with no deficiency, opposition or examiner objection:

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  1. publication must begin within 15 working days of the filing date (Art. 31);
  2. the publication and opposition period runs for two months (Arts. 31 and 32); and
  3. substantive examination follows publication and must finish within30 working days (Art. 39).

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Run to their full length, these periods total slightly more than four calendar months, before allowing for registration and certificate issue. DGIP must therefore complete some steps ahead of their legal limits to meet the target.

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Compliance with those limits does not, by itself, deliver four-month registration. Deficiencies, refusals and oppositions change the calculation:

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  1. a formalities deficiency gives the applicant two months to remedy the omission (Art. 9);
  2. a provisional refusal gives the applicant 30 working days to respond, after which the response must be examined (Art. 41); and
  3. an opposition must be sent to the applicant within 14 working days,and the applicant then has two months to respond. Examination must begin within 30 working days after the response period ends and may take up to 90 working days (Arts. 32, 33 and 40).

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An opposed application can approach 11 months to complete examination if the opposition is filed at the end of publication and each period is used in full. That is an illustration of the permitted timetable, not an estimate of average processing time. Conversely, a deficiency corrected promptly does not necessarily rule out four-month completion.

The priority problem

An applicant has six months from its first filing abroad to file in Indonesia with a priority claim (Art. 9 of the Trade Marks Law). A third party filing in Indonesia shortly afterwards could therefore obtain registration before the priority claimant’s Indonesian application is on file. The examiner cannot take account of an Indonesian application that has not yet been filed.Slower processing would give the priority application more opportunity to arrive while the conflicting application remains pending.

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That does not give the third party superior priority. Article 1(17) of the Trade Marks Law recognises the first foreign filing date as the priority date, and Article 4B of the Paris Convention protects a valid priority filing against intervening acts, including another filing. Article21(1)(a), which addresses conflicting registered marks and earlier applications, must be read with those protections. Registration first is not the same as priority first.

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The concern is procedural: how will DGIP deal with a later-filed mark that is already registered when the earlier-priority application arrives? The announcement does not explain how it will resolve that sequence in practice.

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If the registration is cited, the applicant can rely on priority in its response and, if necessary, appeal a refusal to the Trade Mark Appeal Commission. Those steps address the applicant’s own application. Removing the conflicting registration may separately require cancellation proceedings before the Commercial Court (Arts. 28 to 30 and 76 of the Law). The usual five-year cancellation period is subject to exceptions, including bad faith (Art. 77).

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An opposition puts the issue before DGIP earlier and will generally be less costly than seeking cancellation after registration.

What trade mark applicants should do differently

  1. File in Indonesia early. For key marks, file with, or shortly after, the first filing abroad. Treat the six-month priority period as a fallback, not the default filing timetable.
  2. Watch from the first filing abroad. A conflicting application’s two-month opposition period can open and close entirely within the priority period. Agree decision authority and reporting arrangements in advance, rather than waiting for an Indonesian filing instruction.
  3. Be ready to oppose. Any party may oppose on supported refusal grounds (Art. 32). Filing your own priority application promptly helps put your rights before DGIP, but is not a condition of standing to oppose. Bad faith or well-known mark protection may also provide grounds,depending on the evidence. Gather relevant use and reputation evidence early,and do not miss an opposition deadline while preparing your own filing.
  4. Get the filing right first time. Settle specifications, classification,representations and priority documentation in advance. Respond promptly to deficiencies, but do not sacrifice a filing deadline while waiting for documents that may lawfully follow.

Madrid designations

The announcement does not expressly address international registrations designating Indonesia or specify when any four-month period would start for them. Indonesian publication, opposition and examination procedures still apply (Arts. 10 to 12 of Government Regulation No. 22 of 2018),so the priority and watching considerations remain relevant. Applicants choosing between national and Madrid routes should not assume the administrative target covers Madrid designations.

Industrial designs: can four months fit the statute?

The Industrial Designs Law, No. 31 of 2000, provides that:

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  1. an application meeting the relevant requirements must be published within three months of filing (Art. 25);
  2. any party may object within three months from the start of publication (Art. 26);
  3. if no objection is filed, the certificate must issue within 30 days after the objection period closes (Art. 29); and
  4. substantive examination is expressly required where an objection is filed (Art. 26(5)).

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Four months can fit those provisions, but only with prompt handling. The fixed three-month objection period leaves roughly one month in total for the work before publication and after it closes. DGIP cannot use the full three months allowed to begin publication and still meet the target.

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A formalities deficiency gives the applicant three months to respond, extendable by one month (Art. 19). Using that period will ordinarily put four-month completion out of reach. An immediately corrected deficiency need not do so.

What happens to substantive examination?

DGIP’s January 2026 guidance describes six months of substantive examination even where no objection is filed. The September announcement also refers to substantive examination taking around six months.That description needs to be distinguished from the statutory procedure: Article26(5) requires substantive examination where an objection is filed, while Article 29 requires a certificate within 30 days of an unopposed publication period ending.

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A six-month examination conducted after publication cannot fit a four-month total. DGIP could overlap work, remove administrative waiting time or bring its treatment of unopposed applications more closely into line with Article 29. The announcement does not explain the operational changes. It does not establish that examination will become lighter; DGIP expressly says it intends to maintain examination quality.

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DGIP qualifies the design target by the absence of complications such as objections. Where an objection is filed, the applicant has three months from notification to respond, and DGIP must decide within six months after publication ends (Art. 26). The six-month decision period runs from the end of publication, not the end of the response period. If publication and the decision both occur at their statutory limits, the process can take around year to reach a decision.

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Design applicants also have a six-month priority period (Art. 16). The same sequencing risk can therefore arise: a later-filed application may register before the earlier-priority application is filed. Priority protection remains, but any challenge must address the applicable design-law grounds, including novelty, rather than simply importing the trade mark analysis.

What design applicants should do differently

  1. Decide on deferred publication at filing. Meeting the target requires publication within roughly the first month, potentially before product launch.A written request made at filing can defer publication for up to 12 months from the filing or priority date (Art. 25). Deferral preserves confidentiality but postpones registration. Applicants cannot plan on both prolonged deferral and four-month registration.
  2. Watch design publications. The three-month objection window is the opportunity to put substantive objections before DGIP before registration. Keep dated evidence of relevant earlier disclosures. A contested novelty challenge after registration requires a cancellation action before the Commercial Court (Art. 38). This matters whether or not examination practice changes.
  3. File early under priority. For commercially important designs, do not wait until the end of the six-month period merely because it is available. Earlier filing puts the application before DGIP sooner; deferred publication can address a separate need to preserve confidentiality.
  4. Prepare representations and formalities carefully. Resolve inconsistencies in the drawings, photographs and description, and settle ownership and entitlement documents before filing. A prompt response to any deficiency gives the application its best chance of staying close to the target.

Planning around the target

Four months is a best-case target for a straightforward application, not a deadline that produces registration by default. For transactions, product launches and enforcement, allow for the applicable statutory procedures and realistic processing time rather than assuming a certificate will arrive within four months.

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As at mid-October 2026, it is too early to assess how consistently DGIP will achieve the objective, particularly for designs. The first applications received under the new target will not reach the four-month mark until February 2027. In the meantime, the practical response is to file early, watch publication and make opposition and confidentiality decisions before the timetable makes them urgent.

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