HPS (Owner Estimate) for a Website or App: Perpres 46/2025

HPS (Harga Perkiraan Sendiri) is the buyer's own price estimate, calculated by expert judgement from data you can defend. Under Article 26 of Presidential Regulation (Perpres) 46/2025 (30 April 2025) the HPS total is public and its breakdown is confidential. The 28-working-day limit for fixing it is no longer in that article, but it is still printed in the implementing rule. For a website or app, the procurement agency LKPP's own guidance uses "website development consulting" as its example of a market-based method. The 2026 INKINDO personnel rates already contain overhead and profit, so adding a percentage on top counts the same cost twice.

This article is for heads of procurement and budget holders at banks, insurers, multifinance companies and listed companies, with finance and compliance as second readers. The nearest international term is an owner's estimate. We read every figure and article number below from the official text on 2 October 2026. The pages Google's AI Overview cited for the Indonesian query "hps adalah", and that we read, rely on Perpres 12/2021 or 16/2018 rather than 46/2025. Some still describe a rule that has changed.

What Article 26 says after Perpres 46/2025

Perpres 46/2025 is the second amendment to Perpres 16/2018 on government procurement. It was enacted and promulgated on 30 April 2025 (State Gazette 2025 No. 67). Item 14 of its amendments changes paragraphs (5) and (7), deletes paragraph (8), and restates Article 26 in full. What matters to a buyer of digital services:

• Paragraphs (1)-(3): the HPS is calculated by expert judgement using data that can be accounted for. The HPS value is not confidential; the HPS breakdown is.
• Paragraph (5): the HPS is used to judge whether bid prices and unit prices are reasonable, to set the ceiling on a valid bid (for goods, construction and other services), to size the bid, performance and appeal guarantees, and to select the guarantee issuer.
• Paragraph (6): the HPS is not the basis for calculating state loss.
• Paragraph (7): preparing an HPS is waived for budget ceilings of up to Rp10,000,000, for e-purchasing up to Rp100,000,000, and for integrated-work tenders.
• Paragraph (8): deleted. The restated Article 26 contains no rule fixing the HPS 28 working days before the bid deadline.

One contradiction remains unresolved. LKPP Regulation 12/2021 (31 May 2021), Annex I item 2.2.3, still prints the 28-working-day rule, and its e-purchasing carve-out has no value limit. We found no LKPP regulation amending that item. The only amendment to 12/2021, LKPP Regulation 4/2024, touches Annexes III and VI. Our reading: a presidential regulation outranks an LKPP regulation, so the new paragraph (7) governs. That is a reading, not a quotation. Anyone building an audit checklist from Annex I alone will test a deadline that no longer exists.

Who is bound: a Perpres is not a private bank's rulebook

Article 2 of Perpres 16/2018, as amended, limits its scope to spending by ministries, agencies, regional bodies, other institutions and village governments funded wholly or partly from the national, regional or village budget (APBN, APBD, APB Desa). Private banks, insurers, multifinance companies and listed issuers are not bound directly. Using it as a reference is legitimate if the paper trail exists.

Buyer	Binding rule	What we found about "HPS"
Agencies funded by APBN/APBD	Perpres 16/2018 as amended by 46/2025; LKPP Regulation 12/2021	Article 26 regulates HPS in full, with its exemptions
State-owned enterprises (BUMN)	PER-2/MBU/03/2023 (3 March 2023), shown as in force in the BPK database	Zero occurrences of "HPS" or "harga perkiraan" in the whole text. Article 160 leaves the procurement SOP to the board of directors; Article 147(1)(a) allows a total-cost-of-ownership approach for strategic, high-value procurement
Commercial banks	OJK Board Regulation (PADK) 1/2026 (23 January 2026, in force 1 March 2026)	Zero occurrences of "HPS", "owner estimate" or "harga perkiraan" in the whole text. What it does contain: itemised service costs in the proposal, a cost-benefit analysis including reasonableness of cost, and the arm's-length principle
Other private buyers, including listed issuers	Internal procurement policy	No binding HPS definition; the Perpres and LKPP act as references

The two zeros come from our own text searches on 2 October 2026, not from another page. An owner estimate at a bank or state-owned enterprise therefore lives in internal SOPs, and an auditor will test it against that SOP and cost reasonableness, not an HPS article.

Admissible inputs for an HPS

Annex I of LKPP Regulation 12/2021 (the guideline for other goods/services and non-construction consulting), item 2.2.2, lists ten kinds of data, letters a to j, that may be used "among others". The list is open. The ones that matter for digital work:

Letter	Data source	Note for a website or app
c	Official unit costs or prices published by a professional association	INKINDO 2026 qualifies
f	Comparison with similar contracts completed or under way	Contracts you ran yourself can be used if documented
g	Cost estimate calculated by a planning consultant (engineer's estimate)	Record the name and qualification of whoever calculated it
h	Price information from online shops	Suits devices and licences, not bespoke builds
d	Vendor price lists after rebates and discounts	Not the shop-window price
j	Other information that can be accounted for	The accountability test still applies

The same item says an HPS may not include contingency costs, miscellaneous costs or income tax (PPh), and that the HPS value may be at most equal to the budget ceiling (pagu). Item 2.2.3 adds that an HPS is valid only once signed by the commitment-making official (PPK), who must document the historical data and supporting information behind it. Note the source: those prohibitions and the signature rule sit in Annex I, not in the restated Article 26. Our BPK copy of the annex is an initialled draft, not the signed text, so check the final version before an audit file quotes it.

Three methods, and the example LKPP chose itself

For non-construction consulting services, item 2.2.2 names three methods. Cost-based adds direct personnel cost and direct non-personnel cost. Market-based compares the cost of producing the output with the rates or prices that apply in the market. The examples printed in the annex are "website development consulting" and open-source application development. Value-based applies to services with a reputation or exclusive rights, such as a patented information system.

So a person-month list is not the only recognised route for a website. A market-based HPS with documented comparables is equally valid. Our opinion: if you'll be examined, use both. Build it from cost, then test it against two or three dated comparables. One method with no cross-check is easy to knock down.

We found no official software-costing method. Ministerial Regulation (Permenkomdigi) 6/2025 (25 March 2025), Article 27(3) and (5), requires the planning stage of an application project to include a cost estimate. But we searched the whole text and found no mention of function points, COCOMO, HPS, price estimate or person-months. It binds only government SPBE applications.

A worked HPS for a corporate website, on 2026 INKINDO rates

INKINDO board decision No. 03/SK.DPN/I/2026 (Minimum Standard Guidelines 2026, Jakarta, 30 January 2026) states on page 2, item 7, that its rates may serve as a reference for consulting funded by APBN, APBD, BUMN, BUMD and private parties. The rates below are DKI Jakarta monthly rates (index 1.000); other provinces multiply by the Table 6-26 index. The title says "minimum standard", so read these as a floor, not a ceiling.

The example is ours, built for illustration: a mid-size corporate site over three months. It is not a WEBARQ project price and not a quotation. Headcounts and months are assumptions; in a real procurement they come from the terms of reference (KAK).

Role (INKINDO table)	People	Months	Person-months	Rate per month (Rp)	Subtotal (Rp)
S1 expert without SKK, 5 years (Table 3-26)	1	3	3	32,300,000	96,900,000
Software programmer (Table 4-26)	2	3	6	17,600,000	105,600,000
Graphic designer (Table 4-26)	1	2	2	17,600,000	35,200,000
Web administrator (Table 4-26)	1	1	1	16,900,000	16,900,000
Direct personnel cost					254,600,000
Non-personnel at cost (domain, hosting, certificates; assumption)					20,000,000
Subtotal before VAT					274,600,000

Non-personnel cost here is 7.3% of the subtotal. The guideline says direct non-personnel cost should "in principle" not exceed 40% of total cost, except for special assignments. VAT (PPN) goes on last at the rate in force when the HPS is set, and PPh is left out. LKPP Regulation 2/2026, Article 1 point 25, defines HPS as an estimate that already includes indirect costs, profit and VAT.

How to read the rates: item 2.2.2 converts the monthly rate (SBOB) to a daily rate with SBOH = SBOB/22 × 1.1, and to an hourly rate with SBOJ = SBOH/8 × 1.3. For the programmer, 17,600,000 / 22 × 1.1 = Rp880,000 per person-day, or Rp143,000 per hour. The 5-year expert comes to Rp1,615,000 per day and the web administrator to Rp845,000 per day. Use this conversion when a vendor quotes day rates.

The double-counting trap

Item 2.2.2 defines direct personnel cost as already including basic salary, social charges, overhead and profit. INKINDO's 2026 book says the same of its billing rate (page 1, item 2): basic salary, social charges, general overhead and profit (REM = GD + BBS + BBU + K). An overhead or profit mark-up on top of an INKINDO rate therefore counts the same elements twice.

The size is easy to measure. Put a 15% mark-up on the personnel line only: Rp254,600,000 × 15% = Rp38,190,000. The HPS above rises from Rp274,600,000 to Rp312,790,000, which is 13.9% more. Put the same 15% on the whole subtotal instead and the addition is Rp41,190,000, giving Rp315,790,000, up 15%. Either way, the addition buys something the rate already contained.

The 15% figure does exist in LKPP Regulation 12/2021, but in Annex II, for construction work: profit and indirect costs of at most 15%. In Annex I, the non-construction consulting part, we found no comparable cap. The only 15% there concerns advance payments. Don't justify a 15% mark-up on a website HPS with a construction clause.

E-purchasing: Rp100 million is not a free pass

Article 26(7) waives the HPS for e-purchasing up to Rp100,000,000. LKPP Regulation 2/2026 on the Electronic Catalogue (the text we read is dated 27 August 2026; the promulgation date is blank) revokes LKPP Regulation 9/2021 and confirms the point in Article 13. An HPS is required for e-purchasing above Rp100,000,000. Up to Rp100,000,000 the PPK prepares a Price Reference, a comparator used to judge whether unit prices are reasonable (Article 1 point 26). A Rp99.9 million package therefore does not escape price documentation; only the form of the HPS disappears. One exception sits in paragraph (3): direct purchase of fixed-price products needs neither.

What makes an HPS fail an audit

The KPK 2025 e-Procurement Governance Study classes procurement as a high-risk process, especially for information technology, multi-year projects and consortium packages. Its e-KTP chronology records an HPS "prepared unreasonably" and raised repeatedly, plus rigged BoQ, HPS and price references, citing verdict 130/Pid.Sus/TPK/2017/PN.Jkt.Pst. The prices manipulated there were for hardware, chips and servers, so it shows HPS manipulation, not anything about software estimation. We also found no BPK audit finding on a website or app HPS, and we do not claim one exists.

From the text above, four things make an HPS hard to defend:

1. Unsourced rates. Every line should point to a table, a comparable contract or a dated price quotation.
2. Double counting. Overhead and profit stacked on a billing rate, as calculated above.
3. Prohibited items. Contingency, miscellaneous costs and PPh inside the breakdown.
4. No trail. An HPS with no historical data and no comparison worksheet cannot be reconstructed at examination.

The price of the running years

Person-months to build a system are only part of the cost. Our public case study for PT Freeport Indonesia records web work since 2012 with ongoing maintenance and server-hosting management. It is the only multi-year maintenance relationship in our project catalogue. We take no figure from it, only the lesson that the operating years are a separate line. For the security-testing line items, see the three-year cost of vulnerability assessment and penetration testing.

What this means for the buying committee

• Head of procurement: fix the method first (cost-based, market-based or both), then keep one worksheet per line. Person-months come from the scope in the KAK. Without a written scope, an HPS is a guess formatted as a table.
• Finance: the HPS value may be public; the breakdown stays closed. Keep the breakdown confidential from prospective providers, because paragraph (5) makes it the yardstick for judging bid reasonableness.
• Compliance and internal audit: Perpres 46/2025 does not bind private institutions, but an examiner will ask what your reference was. Record that it was Article 26 as amended by 46/2025, not the 28-day item in Annex I.

If you're planning a corporate website build and want to map it to rows like the table above, start from scope and integrations, because those two drive the person-months.

This article was prepared with AI assistance from primary texts retrieved on 2 October 2026: Perpres 46/2025, LKPP Regulations 12/2021 and 2/2026, INKINDO SK 03/SK.DPN/I/2026, Permenkomdigi 6/2025, PER-2/MBU/03/2023, OJK PADK 1/2026 and the 2025 KPK study. We did not verify the VAT rate in force and make no claim that WEBARQ has prepared an HPS for any client.