LMKN Circular Letter SE.06.LMKN.VIII-2025 and Ministry of Law Regulation 27/2025 stripped Indonesian CMOs of their royalty-collection authority. LMKN is now the sole collector. What does this mean for songwriters, commercial users, and foreign rights holders?
On 27 August 2025, Indonesia's LMKN issued Circular Letter SE.06.LMKN.VIII-2025 revoking the long-standing collection delegation to licensed Indonesian CMOs. Weeks later, the Minister of Law issued Regulation 27/2025 as the implementing rule under PP 56/2021. The result: LMKN is now the sole entity authorised to collect music royalties from commercial users in Indonesia.
What the rules say
- Delegation revoked. Indonesian CMOs (WAMI, KCI, RAI, ARDI, SELMI, SMI) previously held the right to collect royalties on behalf of their members. Since the August 27 Circular, that delegation is withdrawn.
- Centralised at LMKN. Collection from commercial users (cafés, hotels, broadcasters, streaming, concerts) is now the exclusive function of LMKN.
- System INSPIRATION. LMKN launched a centralised platform for usage monitoring, user billing, and distribution management.
- Post-rule role of CMOs. Licensed CMOs continue to exist as a member-representation and post-LMKN distribution layer — they no longer collect directly.
Why the change
The government's stated rationale: the previous decentralised model produced double-billing of users (one venue invoiced by multiple CMOs), administrative leakage, and opaque distribution. Centralising at LMKN with the INSPIRATION system is intended to provide commercial users with a single window and produce a unified audit trail.
The counter-argument: six CMOs (KCI, SELMI, PKU BBC, LKB, CNS, TRI) and three music professional organisations (AKSI, Garputala, ABHC) have written to the Minister of Law citing significant member income drops, layoffs at CMOs, and Q1 2026 distributions still unprocessed.
Practical consequences
For songwriters & neighbouring-rights holders
- You still need CMO membership as the distribution channel from LMKN to you.
- Key questions to ask your CMO: "What is the realistic distribution timeline post-circular? Has Q1 2026 been allocated?"
- Correction claims now flow through LMKN, not directly to your CMO.
For commercial users
- Pay royalties only to LMKN as the single window. Direct invoices from individual CMOs are no longer valid post-circular.
- Audit and clarification requests go to LMKN.
For foreign rights holders
- The reciprocal route via your home CMO ↔ Indonesian CMO is now slower because the Indonesian-side end now waits on LMKN.
- Direct registration in SILM, paired with a notarial-equivalent power of attorney to a local administrator, is more important than ever.
- Your global income from YouTube Content ID, Spotify Publishing Hub, MLC, SoundExchange, etc. is unaffected by the Indonesian SE — those flows remain independent.
How we operate post-SE
- Notarial Power of Attorney from rights holders to Perkumpulan Lintas Media Kreasi Nusantara: (a) catalogue administration, (b) CMO membership maintenance, (c) LMKN distribution claim & correction, (d) direct international platform collection.
- Unified registration: DJKI → CMO of choice → SILM → CISAC/global CMO partners.
- Direct international collection: YouTube Content ID, Spotify Publishing Hub, Apple Music for Artists, MLC (US), SoundExchange (US), PRS for Music (UK), GEMA (DE), JASRAC (JP), KOMCA (KR), and 70+ partner CMOs.
- Automated payouts: Xendit (Indonesia), Stripe Connect & PayPal Mass Payouts (international).
- Transparent reporting: quarterly distribution dashboard and independent annual audit.
Brief FAQ
Do I still need to be a WAMI/KCI member?
Yes — as the distribution channel from LMKN to you. Only the collection layer changed; distribution still flows LMKN → CMO → member.
Can foreign rights holders still claim Indonesian royalties?
Yes. The clearest post-SE path: a notarial-equivalent power of attorney to a local administrator who registers with SILM, maintains the LMKN distribution claim, and runs international platform collection in parallel.
Can the rule be reversed?
Indonesian CMOs and music organisations have formally requested its withdrawal. The situation is fluid; we will update this page as the framework evolves.
Are my Spotify/YouTube payouts affected?
No. Royalties from global platforms are collected in those platforms' jurisdictions and flow through their own networks — not through LMKN. They are independent of the August 27 SE.
Evolving framework. Implementation of SE.06.LMKN.VIII-2025 and Permenkum 27/2025 remains the subject of public debate and industry pushback. Operational details — distribution timelines, allocation formulas, and CMO positioning — may change with subsequent policy decisions. This page will be updated as the official position evolves.