Training Procurement in Indonesian State-Owned Enterprises (BUMN): RKAP, RUPS, SKKNI, and Contracts — An Operational Guide for HC, L&D, and Procurement

Short answer: Training procurement in Indonesian state-owned enterprises (BUMN) is governed by three layers: corporate (Law No. 19/2003 on BUMN, Minister of BUMN Regulation PER-2/MBU/03/2023 on governance), procurement (Minister of BUMN Regulation PER-08/MBU/12/2019 — Best Value for Money, TKDN, ethics), and HR (the AKHLAK core values per SE-7/MBU/07/2020). The budget sits in the RKAP ratified by the RUPS, so the submission timing falls in Q3–Q4 of the prior year. Vendors are selected via each BUMN's procurement system, competencies are mapped to SKKNI, contracts follow the SPK/PKS → execution → BAST → billing → retention flow, and tax follows the BUMN's VAT-collector status (invoice code 03 if a collector, 01 if not).

Training procurement in BUMN is perceived as complex because it involves many organs — shareholders, the Board of Directors, the Board of Commissioners, the Internal Audit Unit, and BPK — and is subject to stricter rules than pure private companies. Yet the process can be mapped into an executable flow. This guide threads the regulatory layers, the budget cycle, the procurement framework, competency mapping, and the contract mechanism into a single operational map for the Human Capital / L&D / Procurement teams in BUMN and BUMN subsidiaries.

Quick navigation

1. Three regulatory layers framing BUMN training procurement
2. RKAP and RUPS cycle: when to submit training
3. The procurement framework: PER-08/MBU/12/2019
4. Mapping competencies to SKKNI and KKNI levels
5. Internalizing AKHLAK into program design
6. From TOR to SPK/PKS: anatomy of a BUMN training contract
7. Execution, BAST, and retention payment
8. BUMN VAT: invoice code 01 vs 03 and PPh 23
9. Corporate academies and multi-year programs
10. Risk, audit, and compliance trail
11. BUMN training-procurement checklist
12. FAQ
13. Next step

Three regulatory layers framing BUMN training procurement

A BUMN is neither a government agency nor a pure private company. This hybrid status creates three regulatory layers that must be kept in mind when buying training.

Corporate layer. The institutional basis is Law No. 19 of 2003 on State-Owned Enterprises, which defines two forms — Persero (for-profit, majority State-owned) and Perum (public service). On top of that, Minister of BUMN Regulation No. PER-2/MBU/03/2023 on Guidelines for Governance and Significant Corporate Activities of BUMN becomes the modern governance spine of BUMN: GCG principles, integrated risk management, health-level assessment, strategic planning (RJPP–RKAP), guidelines for significant corporate activities, and IT governance. The regulation reinforces accountability and standardizes risk practice across BUMN.

Procurement layer. Procurement of goods/services in BUMN is not governed by Presidential Regulation 16/2018 (which governs ministries/agencies/regions), but by Minister of BUMN Regulation No. PER-08/MBU/12/2019 on the General Guidelines for the Procurement of Goods and Services of BUMN, which replaced PER-05/MBU/2008. The regulation embeds the principles of Best Value for Money, Total Cost of Ownership, prioritization of domestic production/TKDN, procurement risk management, and procurement ethics. Each BUMN translates this into internal Procurement Guidelines and its own e-Procurement system (PERTAMINA SMART by GEP, Telkom e-Procurement, PLN e-Proc, etc.).

HR layer. Since Minister of BUMN Circular No. SE-7/MBU/07/2020 effective 1 July 2020, all BUMN and their subsidiaries must adopt AKHLAK — Amanah (Trustworthy), Kompeten (Competent), Harmonis (Harmonious), Loyal (Loyal), Adaptif (Adaptive), Kolaboratif (Collaborative) — as the single set of core values, without omission or addition. The implication for training: every BUMN HR development program is expected to internalize AKHLAK, and procurement decisions pay attention to vendor alignment with these values (e.g. integrity — aligned with ISO 37001:2016 anti-bribery management systems, widely adopted across BUMN as evidence of compliance).

Practical consequence: These three layers appear in the TOR, contract, and final report. A vendor that does not understand any one layer becomes an administrative risk for the BUMN procurement team.

RKAP and RUPS cycle: when to submit training

The RKAP is the BUMN's annual planning document containing the work plan, budget, and one-year financial projections, cascading from the five-year RJPP. Every training budget line must be tied to a strategic objective in the RJPP/RKAP — it cannot appear as a loose list of activities.

Month in year N	RKAP activity for year N+1
Q1–Q2 (Jan–Jun)	Evaluation of current RKAP execution; competency-need analysis (annual TNA)
Q3 (Jul–Sep)	RKAP draft preparation — including training budget lines per Directorate/Division
Q4 early (Oct–Nov)	Submit RKAP to Board of Commissioners; refinement; submission to shareholders
Q4 late (Dec)	RUPS ratifies RKAP for year N+1
Jan–Dec year N+1	Execute budget lines; revise RKAP via RUPS-LB if needed

For the Human Capital/L&D team, this means: next year's training needs are drafted in Q2–Q3 this year. Programs proposed in January of the running year are nearly impossible to fit into the formal budget — the route is reallocation across training line items within the ratified envelope, or an RKAP revision that goes through organ approval.

PER-2/MBU/03/2023 clarifies the category of "significant corporate activities" requiring approval from a specific organ (Board of Commissioners or RUPS) — for example material investments, structural changes, or large multi-year academy programs. Ensure the governance is discussed at design time.

Practical rule: Next year's training plan is closed in Q3 this year. A 3–5-year academy plan is closed in the RJPP cycle, earlier still.

The procurement framework: PER-08/MBU/12/2019

This regulation replaced PER-05/MBU/2008 and laid down the modern framework of BUMN procurement. Four things are relevant for training-service procurement:

1. Best Value for Money. The procurement decision is not automatic to the lowest price but to the best value for the total cost of ownership. For training, this aligns with the weighted scoring rubric — TNA fit, facilitator quality, methodology & measurement, customization, legality, post-program support — with price as one of the criteria. See How to Choose a Corporate Training Vendor for the full rubric.

2. Total Cost of Ownership. Training cost does not stop at facilitator fees. TCO includes content development, assessment, platform licensing, travel, participant opportunity cost, post-program support, and retention. A vendor that only offers a "per classroom day" price without a TCO breakdown leaves hidden costs that surface later. Cost-component detail: Building a Training Budget (RAB) & Annual Training Plan.

3. Prioritization of domestic production (TKDN). BUMN are required to prioritize domestic products at parity. For training services: domestic facilitators, Indonesian-language modules with local case studies, and domestic LMS platforms become a plus. Vendors should be ready to provide TKDN documentation when requested — many BUMN require a minimum TKDN for certain packages.

4. Procurement ethics. The regulation closes the space for conflicts of interest, gratification, and collusion. Most large BUMN are now ISO 37001:2016 (Anti-Bribery Management System) certified and require vendors to sign an Integrity Pact and a conflict-of-interest declaration. A vendor that refuses is a red flag.

Operationalization: each BUMN has its own e-Procurement system (e.g. SMART by GEP in the Pertamina Group, e-Proc Telkom, e-Proc PLN). Vendors must register and pass supplier qualification — legal verification (NPWP/PKP/SIUP/NIB), financial, and track record. Without qualification, vendors cannot join tenders or direct appointments.

Selection method	When used	Note for training
Open tender	High value, many providers	Multi-year academy, large transformation program
Direct appointment	High specialization / specific conditions	A single expert facilitator, proprietary content
Direct procurement	Low value per BUMN threshold	Single-batch workshop, short session
Umbrella contract	Repeating with curated vendors	Annual multi-batch program with preferred vendor
Internal e-Catalogue	BUMN with service catalogues	Standard training packages already listed

The exact thresholds and methods are set by each BUMN's internal Procurement Guidelines — always check the internal document before designing the sourcing strategy.

Mapping competencies to SKKNI and KKNI levels

SKKNI (Indonesian National Work Competency Standards) is set by the Ministry of Manpower per sector and becomes the nationally recognized competency benchmark. KKNI (Indonesian National Qualifications Framework) tiers qualifications 1–9, from operational workers to senior expert/professionals. For BUMN, these two frameworks become the objective anchor that makes training budgets defensible to auditors.

Mapping steps:

1. Identify critical roles from the internal competency dictionary and strategic workforce planning cascaded from the RJPP.
2. Match to sectoral SKKNI. Several SKKNI relevant to BUMN:
   • Electricity Sector (PLN and subsidiaries)
   • Oil & Gas Industry (Pertamina Group)
   • Telecommunications Sector (Telkom Group)
   • Banking Sector (Mandiri, BRI, BNI, BTN)
   • Construction Services Sector (Karya Group)
   • Logistics & Ports Sector (Pelindo, ASDP)
   • Tourism Sector (InJourney Group)
3. Set the KKNI level (1–9) required per position.
4. Measure the actual level through competency assessment by a BNSP-licensed LSP — most large BUMN have an LSP P-1 (internal certification).
5. The gap becomes the basis for program design and, where relevant, a BNSP certification plan through a licensed certification scheme.

Why this matters: A training budget tied to SKKNI is easier to defend to BPK and SPI because every module has a verifiable benchmark. A training budget of "loose titles" without competency benchmarks is vulnerable to questioning.

See the operational guide to competency mapping and TNA at Training Needs Analysis (TNA).

Internalizing AKHLAK into program design

AKHLAK is the mandatory core values across all BUMN since SE-7/MBU/07/2020 — effective 1 July 2020. The six values:

• Amanah — uphold trust
• Kompeten — keep learning and growing
• Harmonis — care for others and value differences
• Loyal — dedicated, prioritize the interests of the nation
• Adaptif — keep innovating, enthusiastic about change
• Kolaboratif — build synergistic cooperation

AKHLAK internalization into training happens through three practices:

Practice	Concrete implementation
Map modules → values	Each module is tied to 1–3 relevant AKHLAK values (e.g. integrity module → Amanah; cross-functional collaboration → Harmonis & Kolaboratif; growth mindset → Kompeten & Adaptif)
AKHLAK-based behavioral assessment	AKHLAK behavioral indicators become part of Kirkpatrick Level 3 evaluation — supervisors assess participant behavioral change against AKHLAK indicators 60–90 days post-training
BUMN-specific case studies & simulations	Dilemmas of state interest, public service, and BPK/SPI/KPK accountability become the practice material; avoid generic MNC cases that are weak on context

A healthy design makes AKHLAK visible in the syllabus, scoring rubric, and final report — going beyond a token mention in the introduction. A vendor that cannot explain how a program advances AKHLAK is a vendor that is not ready for a BUMN client.

From TOR to SPK/PKS: anatomy of a BUMN training contract

A TOR (Terms of Reference) or KAK (Kerangka Acuan Kerja) is the first document shared with vendors. For BUMN training, a good TOR contains at minimum:

• Background & strategic objective — tied to RJPP/RKAP, signed by the budget-line owner.
• TNA results & competency gap — measured against SKKNI/the internal competency dictionary.
• Measurable learning objectives — change in competency/behavior.
• AKHLAK objectives — the values to be reinforced.
• Participant profile — count, roles, locations, prerequisites.
• Work scope — modules, methods, duration, format (onsite/online/hybrid), language.
• Evaluation plan — Kirkpatrick L1–L3 (L4 for large programs), instruments, baseline.
• Supplier requirements — legality (NPWP/PKP/NIB), experience, facilitators by name, qualifications.
• HPS & tax position — Owner's Estimate, VAT status (incl./excl.), invoice code, PPh 23 mechanism.
• Payment terms & retention — typically 50% after delivery + BAST, 45% after final report, 5% retention after the Level 3 evaluation report (variations per BUMN).
• Bonds — Bid Bond (for tenders), Performance Bond, Maintenance Bond.
• Special clauses — Integrity Pact, participant data protection (PDP Law No. 27/2022), confidentiality, anti-bribery (ISO 37001).
• Schedule & milestones — key dates, BAST per batch, reports.

The contract documents used:

Document	Characteristics	Suitable for
SPK (Work Order)	Concise clauses, fast execution	Short workshop, single mid-value in-house batch
Contract/PKS	Complete clauses, strong protection	Multi-year academy, transformation programs, multi-batch
Umbrella Contract	Wide scope, fast-draw per Purchase Order	Preferred vendor for recurring programs

What determines binding strength is clause completeness. Even an SPK can be supplemented with annexes equivalent to contract clauses.

Execution, BAST, and retention payment

The BUMN execution and billing flow follows a seven-stage pattern:

1. Kick-off with the budget-line owner, target participants, and vendor — alignment on objectives, schedule, logistics.
2. TNA validation (if not already done) — vendor validates the gap, adjusts modules.
3. Execution of training sessions per schedule — attendance per session, documentation.
4. BAST per batch/milestone — handover proof, billing trigger per contract terms.
5. Term billing — invoice + tax invoice (code 01 or 03) + stamped receipt + BAST + supporting documents. PPh 23 is withheld; VAT is collected per the BUMN's collector status.
6. Final report — Kirkpatrick Level 1–2 evaluation, list of pass/fail participants, recommendations.
7. Level 3 report + final BAST — measurement of behavior change 60–90 days post-execution, as the basis for retention release.

Retention. Many BUMN apply a 5% retention of contract value as a guarantee of full obligation fulfillment — including the post-training evaluation report that can only be measured 60–90 days after execution. Vendors serious about measuring Kirkpatrick Level 3 structurally are more ready to accept this retention scheme. Agree the percentage, release documents, and schedule in the contract from the outset — not as later negotiation.

Principle: BAST is the heart of administration. Agree the BAST format and signatories in the contract; many payments are delayed by a messy BAST.

BUMN VAT: invoice code 01 vs 03 and PPh 23

The BUMN VAT mechanism differs from pure private buyers because some BUMN are designated as VAT collectors under the relevant PMK. Invoice-code implication:

BUMN status	Vendor issues	Who collects VAT	Who withholds PPh 23
BUMN designated as VAT collector	Tax invoice code 03	BUMN (collects & remits)	BUMN
BUMN not designated as collector	Tax invoice code 01	The PKP vendor	BUMN

VAT rate: nominal 12% since 1 January 2025 (HPP Law No. 7/2021), effective 11% for training services (non-luxury) via the DPP Nilai Lain mechanism. PPh Article 23: 2% gross if the vendor has an NPWP, 4% if not (technical services per SE-35/PJ/2010). Since 2025, tax invoices and PPh withholding slips are issued via Coretax DJP.

Confirm collector status with the relevant BUMN tax team before issuing the PO/SPK. A wrong invoice code causes the invoice to be rejected and payment delayed. The full mechanism is discussed in Training PO, VAT & Tax Invoice Procedure.

Corporate academies and multi-year programs

Large BUMN (Pertamina Corporate University, PLN Corporate University, Telkom Corporate University, BRI Corporate University, Mandiri University, etc.) run corporate universities as the owners of strategic HR development programs. Implications for procurement:

• Multi-year programs must be tied to the RJPP and ratified by the appropriate organ (RUPS for those qualifying as significant corporate activities).
• Umbrella Contracts are often used for fixed-curriculum vendors, with Purchase Orders per batch.
• BNSP certification schemes via internal LSP P-1 — vendors support participant preparation, while assessment is done by the LSP.
• ROI measurement uses Phillips Level 5 for flagship programs — agree the measurement scope in the contract.
• Participant data governance per PDP Law No. 27/2022 — a data-processing agreement is signed by the vendor.

For vendors: this is a long-term relationship. Commitment to AKHLAK, integrity (ISO 37001), and the ability to execute multi-batch across locations becomes a key differentiator.

Risk, audit, and compliance trail

BUMN are supervised in layers: the Internal Audit Unit (SPI), Board of Commissioners, Public Accounting Firm, and BPK for state-financial audits. In addition, the KPK has the authority to examine transactions indicating corruption in BUMN. The main risks and mitigations:

Risk	Common cause	Mitigation
Audit finding of "not economical"	Above-market price without justification	Market-research-based HPS, documented scoring rubric
Audit finding of "not effective"	No evidence of impact	Kirkpatrick L3–L4 evaluation with baseline
Audit finding of "not accountable"	Incomplete procurement documents	Integrity Pact, BAST, reports, withholding slips
Conflict-of-interest indication	Vendor affiliated with a BUMN officer	Conflict-of-interest declaration, due diligence
Gratification indication	Off-contract giving	ISO 37001 governance, anti-bribery training for the PIC
PDP Law breach	Participant data leak	Data-processing agreement, limited data retention

Compliance-trail discipline — TOR, HPS, proposal evaluation, contract, BAST, invoice, withholding slip, final report, evaluation documents — is not paperwork. It is what protects the procurement PIC, the Board of Directors, and the vendor when the audit arrives.

BUMN training-procurement checklist

Before signing, ensure all are ticked:

• Need tied to RJPP/RKAP objectives and ratified by the budget-line owner.
• TNA done; gap mapped to SKKNI/internal competency dictionary.
• Modules mapped to AKHLAK values; AKHLAK behavioral indicators in L3 evaluation.
• Vendor passes supplier qualification in the BUMN e-Procurement system.
• Integrity Pact and conflict-of-interest declaration signed.
• TOR/KAK complete; HPS documented with calculation basis.
• BUMN VAT status (collector or not) confirmed; invoice code agreed (01 or 03).
• Vendor has NPWP/PKP; sample tax invoice and Coretax readiness confirmed.
• Contract/SPK/PKS complete: scope, terms, retention, bonds, AKHLAK, PDP Law, anti-bribery clauses.
• BAST scheme per batch agreed; format and signatories clear.
• Retention scheme (typically 5%) and release conditions clear — including the L3 evaluation report.
• For multi-year programs: significant-corporate-activity governance reviewed.
• BNSP certification (if relevant) prepared via internal LSP P-1.
• Participant data-processing agreement per PDP Law No. 27/2022 signed.
• TKDN documented where the package requires it.

FAQ

What is the main regulatory framework for training procurement in BUMN?

Three layers. Corporate: Law No. 19/2003 on BUMN, plus Minister of BUMN Regulation PER-2/MBU/03/2023 on Governance & Significant Corporate Activities (GCG principles, risk management, strategic planning). Procurement: PER-08/MBU/12/2019 (Best Value for Money, TCO, TKDN, ethics), replacing PER-05/MBU/2008. HR: SE-7/MBU/07/2020 establishing AKHLAK as mandatory core values.

What is the RKAP and why does its cycle determine training timing?

RKAP is the BUMN's annual planning document containing the work plan, budget, and one-year financial projections, ratified by the RUPS. It cascades from the 5-year RJPP and is drafted in Q3–Q4 for implementation the following year. Implication: training needs must be submitted long before the execution year — typically by August–November of the prior year.

What is the role of the RUPS in approving training budgets?

The RUPS is the highest organ of a BUMN, ratifying the RKAP, annual financial statements, and significant corporate decisions. For a Persero, the shareholder is the Minister of BUMN plus others if applicable; for a Perum, the Minister of BUMN acts as the RUPS. Training budgets are bound by the figure ratified at the RUPS — the Board cannot spend beyond the envelope without approval.

How does PER-08/MBU/12/2019 affect vendor selection for training?

Four embedded principles: Best Value for Money (not automatic to lowest price), Total Cost of Ownership (beyond facilitator fees), prioritization of domestic production/TKDN, and procurement ethics (aligned with ISO 37001:2016). Vendors must register in the BUMN's e-Procurement system and pass supplier qualification.

How do I map training needs in a BUMN to SKKNI?

Steps: (1) identify critical roles from the competency dictionary and RJPP; (2) match to sectoral SKKNI; (3) set the required KKNI level 1–9; (4) measure actual level via BNSP-licensed LSP assessment; (5) the gap becomes the basis for program design and BNSP certification plan.

What is the difference between an SPK, contract, and PKS in BUMN procurement?

SPK is typical for mid-value, simple, short work — concise clauses. A contract/PKS is used for high-value, multi-session, multi-year, or higher-risk work — complete clauses for scope, terms, bonds, retention, etc. For multi-year academies, PKS is default; SPK suffices for short in-house batches.

What is the function of BAST and when is the retention payment released?

BAST is the billing trigger: proof of work delivered and accepted. For training, it records date, attending participants, content, and accompanying documents. Many BUMN apply 5% retention as a guarantee of remaining obligation fulfillment (e.g. Level 3 evaluation report). Retention is released after the final BAST stating all obligations met.

Which tax-invoice code does a BUMN use?

Depends on collector status. BUMN designated as VAT collector — vendor issues code 03 and BUMN collects/remits. BUMN not designated as collector — code 01 (PKP vendor collects). PPh 23 on training is still withheld 2% (with NPWP) or 4% (without). Since 2025 tax invoices and slips via Coretax DJP.

How are BUMN AKHLAK values internalized into training program design?

Three practices: (1) map each module to relevant AKHLAK values; (2) embed AKHLAK-based behavioral assessment in Kirkpatrick Level 3; (3) align case studies and simulations to BUMN-specific dilemmas. A healthy design makes AKHLAK visible in the syllabus itself, beyond a token mention in the introduction.

What if I need an urgent training that is not in the RKAP?

Pathways: (1) reallocate within the current RKAP envelope; (2) revise RKAP via internal approval for material changes; (3) use crisis/contingency funds if available; (4) bundle with already-budgeted programs. Better solution: plan for the next RKAP cycle while executing small non-training interventions as a bridge.

Next step

Training procurement in BUMN is not a regulatory test — it is the same work discipline as procuring other services, only with a clearer governance layer. What distinguishes vendors ready to serve BUMN is understanding of the three layers (corporate/procurement/HR), document readiness, and the ability to internalize AKHLAK into program design — all testable long before contract.

Neksus works with a parallel framework: every program starts from a training needs analysis tied to SKKNI/internal competency dictionary, designed with AKHLAK as the behavioral spine, tax-ready (invoice code 01/03 per status, Coretax-ready), and BUMN-procurement-ready (Integrity Pact, PDP Law agreement, e-Procurement readiness). Discuss your BUMN team's needs and request an initial TNA via the Neksus contact page — no obligation, as the right starting point.

Also explore related guides:

• How to Choose a Corporate Training Vendor
• Building a Training Budget (RAB) & Annual Training Plan
• Training PO, VAT & Tax Invoice Procedure
• Training Needs Analysis (TNA)
• Corporate Generative AI Training
• Organizational Change Management

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Last updated: 18 May 2026. BUMN regulations and PMK on tax/procurement are referenced from the official current sources; VAT-collector status and procurement thresholds are confirmed per BUMN and per contract. Validate with your BUMN's tax, legal, and procurement teams. Neksus does not publish client names or success statistics; any claim about a vendor should always be verified with evidence.