SLF, PBG, and Old IMB for Your Building

PP 16/2021 Article 1 paragraph 17 defines PBG as a permit for new construction, alteration, expansion, reduction, and/or maintenance of a building in accordance with technical standards. For new projects, PBG should ideally be obtained before construction begins.

For existing buildings, PBG becomes relevant when the building has never had a permit or has changed from its original documented state. The process is not the same as PBG for new buildings. JKK focuses on PBG for existing buildings as part of legalizing the current built condition.

PP 16/2021 Article 1 paragraph 18 defines SLF as a certificate stating the functional fitness of a building before it is occupied. The distinction is clear: PBG reviews plans and changes, while SLF assesses the fitness of a building that is already or will be in use.

In simple terms, PBG is the approval of technical building standards, whereas SLF is proof that the standing building is safe to use. For a villa or commercial building, the two are often interrelated because any building in use must have both a legal basis and a certification of functional fitness.

PP 16/2021 Article 346 paragraph (2) states that IMBs issued before this regulation remain valid until the permit expires. So having an old IMB is not automatically wrong. However, owners must verify whether the current condition of the building still matches the original documents.

Article 346 paragraph (3) is also important: buildings that are already standing and do not yet have a PBG must obtain an SLF. This is why many existing cases cannot be resolved simply by finding old documents — they require an audit of the current condition.

Start with three questions: does the building have an IMB or PBG, does the built condition match the documents, and does the building already have a valid SLF. If any answer is unclear, you need a status mapping before choosing a path.

Do not rush to conclude that you must demolish or start from scratch. Many existing buildings can be processed through technical assessment, as-built drawings, and a SIMBG application. The key is to read the data honestly and never fabricate documents.

A simple way to distinguish the three is to look at the timing and function of the documents. IMB is an old term still often used by owners to refer to past building permits. PBG is a technical approval within the new regulatory framework. SLF is proof that the building is fit for occupancy. In existing buildings, these three terms often meet because owners bring old documents, the current built condition, and today's utilization needs into a single process.

A common mistake occurs when owners assume one document automatically replaces another. Having an old IMB does not always mean the current building condition complies, especially if there is a change of function or expansion. Having a PBG is also not the same as having an SLF, because the SLF assesses suitability for use. For buildings already constructed without a PBG, PP 16/2021 provides space so that PBG and SLF can be processed through the existing path via technical proof.