Rahmat Wibowo posted a detailed regulatory analysis arguing that Kampus Malaka and ASSAI cannot legally become universities quickly, highlighting that founders Ferry Irwandi, Sabda PS, and Abil Sudarman have unverified or incomplete credentials, in an accusatory tone questioning their qualifications.
| ID | ev-20260618-016 |
|---|---|
| Source | Rahmat Wibowo LinkedIn |
| Targets | Ferry Irwandi Abil Sudarman (Abigail Aryaputra Sudarman) Sabda PS |

Transcript
The Paper Wall:
why a university can't be built
ina
The Paper Wall: why
a university can't be
built in a month,
Case Study of Abil
Sudarman School of
Artificial Intelligence
and Malaka Campus
@ Rahmat Wibowo + Follow
Two founders without a completed
undergraduate degree are both, right
now, trying to build something
Indonesian law calls a "perguruan
tinggi." This is a walk through every door
they'd have to knock on, every
regulation that stands in the way, and
how long the real version of this actually
takes.
"We'll build a university." It sounds like a
sentence. It is actually a five-agency
permission chain.
In Indonesia, the word universitas is not
a brand you can put on a building. It is a
legal status, granted by the national
government, that requires a non-profit
legal entity, a notarized land certificate,
a minimum faculty roster with verified
graduate degrees, an institutional
accreditation score, and a ministerial
decree, in that order. None of those five
things can be skipped, rushed past a
checklist, or substituted with audience
size, content virality, or founder
charisma.
That matters right now because two of
Indonesia's most visible new education
ventures, Kampus Malaka (founded by
content creator Ferry Irwandi and Sabda
PS) and the Abil Sudarman School of
Artificial Intelligence, ASSAI, are both
being built and discussed in public by
founders whose own undergraduate
credentials are unverified or incomplete.
Neither problem, the bureaucracy or the
credentials, is hidden. Both are
searchable. This page lays out exactly
what stands between "we have an idea
and a following" and "we are a legally
recognized perguruan tinggi," using
these two ventures as the worked
example.
Two ventures, two unverified
credentials, one regulatory wall
ahead
Neither project has filed for, or received,
an operating license from Indonesia's
higher-education ministry as of this
writing. Both are presently legal as
media brands, communities, or training
programs, categories with essentially no
entry barrier. The wall appears the
moment either one tries to call itself a
university.
Siapa Sebenarnya Abil Sudarman?
Profil, Background, dan Kisah Viral Al
Tracking Anggaran Pemerintah
Prof, Ba
ACKING
ALT PeMERINTAM
Siapa Sebenarnya Abil Sudarman? Profil,
Background, dan Kisah Viral Al Tracking
Anggaran Pemerintah
‘ASAI: Sekolah Al yang Dibangun dari Keyakinan Sederhana
=
‘nial ttiacae
Seven regulations you cannot route around
Every requirement below traces to a
specific, currently active Indonesian
regulation. None of these are guidelines;
each is the binding instrument a ministry
cites when it rejects an application.
UU No. 16/2001 & UU No. 28/2004
Foundation Law (Yayasan)Defines how
anon-profit legal foundation is created,
who its organs are (founders,
supervisors, management board), and
what happens to its assets. A university
cannot legally exist without a Badan
Penyelenggara, foundation or
association, sitting above it as the legal
owner.
Permenkumham No. 2/2016 & No.
13/2019
Foundation Registration
ProcedureSets out exactly how a
foundation applies for legal-entity status
through Kemenkumham's AHU Online
system: name reservation, notarized
deed, supporting documents, then
ministerial ratification. This is the gate
before the education-specific gate.
UU No. 12/2012
Higher Education LawThe umbrella
statute defining what a perguruan tinggi
legally is, the academic and vocational
tracks, and the government's authority
to set minimum standards (SN-Dikti)
that every institution must meet before
and after opening.
PP No. 4/2014
Higher Education
ImplementationImplements UU 12/2012
with operational detail, including the
lecturer-to-student ratio standard, 1:20
for exact sciences, 1:30 for social
sciences, that institutions must hold to
remain compliant after launch.
Permendikbud No. 7/2020
Establishment, Change, and Closure
of PTN/PTSThe core regulation
institutions are actually licensed under
today. Specifies the Badan
Penyelenggara's legal documents, the
land certificate, the audited or self-
declared financial capacity statement,
and the signed commitment letters from
prospective permanent lecturers, all of
which must be bundled before a single
application is filed.
Permendikbud No. 84/2013
Appointment of Permanent
LecturersGoverns how a private
institution appoints dosen tetap,
including the requirement that they work
a fixed 37.5 hours a week for that
institution alone and hold a registered
NIDN, a national lecturer identification
number issued only after credentials are
verified by the ministry's own database.
Kepmendiknas No. 234/U/2000 (as
amended)
Guidelines for Establishing Higher
Education InstitutionsThe original
founding guideline, still cited as the
basis for lecturer-ratio standards and
minimum program-of-study counts: at
least three study programs to be
chartered as a universitas, two for a
sekolah tinggi, academy, or polytechnic.
Before anything can be filed, a founder
has to clear a minimum package, not an
ideal one, since falling short on a single
requirement gives LLDIKTI grounds to
bounce the application back unread.
The legal entity must be a ratified
Yayasan or Perkumpulan, since
Indonesian law forbids a for-profit
company or an unincorporated
community group from operating a
degree-granting institution, making the
non-profit principle structural rather
than optional.
Land ownership must be certified (SHM
or HGB) rather than leased, at 10,000 m?
for a universitas, 8,000 m? for an institut,
or 5,000 m? for an akademi, sekolah
tinggi, or politeknik, demonstrating the
institution isn't a pop-up that could
disappear after one enrollment cycle.
The institution needs at least three study
programs to open as a universitas (two
for other forms), since a single course or
bootcamp track doesn't meet the legal
definition of higher education.
Each program needs a minimum of five
permanent lecturers, at least three of
them registered dosen tetap with a
NIDN, guaranteeing a baseline of
qualified full-time academic staff exists
before a single student enrolls rather
than being hired reactively afterward.
Those lecturers must hold at least a
master's degree (S2) field-matched to
what they teach, since that credential is
what the law actually polices, applying
to staff rather than founders, given that
no institution can be chartered around
founders alone.
Financial capacity must be
demonstrated through a signed
commitment (audited if the Badan
Penyelenggara is more than three years
old) to cover both investment and
operating costs, preventing a charter
from being granted to an entity that
can't survive its first accreditation cycle.
A full set of institutional documents,
including the Statuta, RIP (master
development plan), academic master
plan, and internal quality assurance
system, must be in place, since these
are what BAN-PT and the ministry use to
judge whether the institution can self-
regulate once operating.
An LLDIKTI recommendation is also
required, covering a regional track
record review, a program saturation
check, and a viability assessment of
whether the area already has enough
capacity in that field and whether this
particular founder group has the track
record to sustain it.
Finally, of the available institutional
forms, only akademi and politeknik are
currently open to new applicants.
Six doors, in order. You cannot knock on
door three before door one answers.
This is the literal sequence of institutions
a founder has to engage, who
specifically at each one, and what they
walk away with before moving to the
next door.
What a content following actually
substitutes for, and what it cannot touch
Three ways founders try to compress the
timeline, and what actually happens
"Launch as a community or bootcamp first,
convert to a university later."
Legally sound, but it does not compress
anything. A training brand, course
platform, or "people's university"
concept can launch immediately
because it carries zero higher-education
licensing burden, which is exactly why it
isn't a university yet. Converting that
brand into a chartered PTS later still
means starting the full sequence on this
page from step one: foundation, land,
lecturers, LLDIKTI, ministry. The early
brand only buys audience and funding,
not regulatory progress.
Verdict: valid strategy, zero time saved
on the legal process itself
"Acquire or merge with an existing,
already-licensed PTS instead of starting
fresh."
This is the one real structural shortcut in
the system. Because brand-new
universitas and institut charters are
under moratorium, the realistic fast path
for anyone wanting that exact legal form
is a perubahan bentuk, taking over or
merging with an existing, already-
accredited private institution and
rebranding it, rather than filing for a new
charter that the ministry currently will
not issue. This still involves due
diligence, an existing foundation's legal
transfer, and ministry approval of the
change, typically several months, but it
is meaningfully faster than the 18 to 30
month new-charter path and is the route
most serious operators actually take.
Verdict: the legitimate fast lane, still
measured in months, not weeks
"Self-declare faculty credentials and clean
it up after approval."
This is the one move that doesn't just
slow things down, it ends the
application. NIDN registration cross-
checks against the ministry's own
academic records (Forlap/PDDikti) and
degree-granting institutions. A lecturer
dossier built on unverifiable or padded
credentials is also the single most
common reason LLDIKTI or the ministry
sends a submission back, and repeated
bad-faith submissions are explicitly
grounds, under the governing
regulations, for the ministry to simply
stop processing further applications
from that Badan Penyelenggara.
Verdict: not a shortcut, an exit from the
process entirely
References
Compiled and verified 17 June 2026.
Regulatory citations refer to the legal
instruments as currently published;
always confirm against the live
SILEMKERMA and AHU Online portals
before filing, since procedural detail
pages are updated by the ministries
without separate public notice.
1. Disway — "Ferry Irwandi, Dari Konten
Kreatif hingga Membangun Perguruan
Tinggi Malaka"Profile covering Ferry
Irwandi's transition from content
creation to founding Perguruan Tinggi
Malaka with Sabda PS.
i
. Wikipedia Bahasa Indonesia — Ferry
IrwandiBiographical reference including
STAN and Central Queensland
University education history.
w@
. Jurnal Aceh / Pikiran Rakyat — "Ferry
Irwandi dan Malaka Project: Kisah di
Balik Impian Membangun Kampus
Rakyat" Coverage of the "people's
university" concept and curriculum
framing for Kampus Malaka.
a
Hypeabis — "Profil Ferry Irwandi, dari
PNS Kemenkeu Menjadi Kreator
Konten dan CEO Malaka
Project"Background on the founder's
prior civil service career and scholarship
program design.
al
Ruang.id — "Membongkar Paradigma
Pendidikan: Ferry Irwandi dan Misi
‘Gila’ di Balik Kampus
Malaka"Reporting on Kampus Malaka's
March 2026 instructor recruitment
window.
bad
Linkedin — Abil S., Founder of Abil
Sudarman School of Artificial
IntelligenceSelf-reported professional
profile listing University of London
education and prior KORIKA, UNESCO,
and Stimson Center roles.
“yl
Stimson Center — Abigail Aryaputra
Sudarmaninstitutional bio stating he
"previously studied Computer Science
at the University of London," without
confirming degree completion.
»
ASSAI — Official SiteASSAI's own
description of its mission, curriculum,
and current operating form as an Al
training platform.
©
. Ridwan Institute — "Syarat Mendirikan
Perguruan Tinggi Terbaru" Overview of
current legal-entity, land, and academic
planning requirements for new PTS.
10. EDC — "Syarat Pendirian Perguruan
Tinggi Swasta"’Source for current land-
area minimums by institutional form and
the active moratorium on new
universitas/institut charters.
11. EDC — "Syarat Pendirian Institut
Terbaru 2026"Definitions of Badan
Penyelenggara and Pendirian PTS under
the governing ministerial regulation.
12. Jogloabang — Permendikbud No. 7
Tahun 2020, full text summaryPrimary
source for foundation document
requirements, land certificate rules, and
lecturer commitment letter obligations.
13. LLDIKTI Wilayah VII (Kopertis 7) —
"Sistem Layanan Rekomendasi
Pembukaan Program Studi Baru dan
Pendirian PTS Baru" Official 2026
requirements notice for new study
program and new PTS recommendation
submissions.
14, Dunia Dosen — "Syarat Dosen Tetap
Yayasan yang Perlu Anda
Ketahui"Source on Permendikbud No.
84 Tahun 2013 governing appointment
of permanent (non-civil-servant)
lecturers.
15. Dunia Dosen — "Rasio Dosen dan
Mahasiswa Ideal, Berapa
Besarannya?"Source for the 1:20 and
1:30 lecturer-to-student ratio standards
under UU No. 12/2012 and PP No.
4/2014.
16. Universitas Padjadjaran — "Instrumen
Pemenuhan Syarat Akreditasi
Minimum Program Studi Baru"Official
BAN-PT-aligned instrument specifying
the minimum five-lecturer, three-
permanent-lecturer threshold per new
study program.
17. Kontrak Hukum — "Apa Saja Syarat
Mendirikan Yayasan?"Step-by-step
description of the AHU Online name
reservation and notarized deed process
under UU No. 16 Tahun 2001.
18. Valeed — "Syarat Mendirikan Yayasan
Terbaru dan Lengkap Sesuai Hukum di
Indonesia"Source for the realistic two-
to-four-week Kemenkumham foundation
ratification timeline.
19. Direktorat Jenderal Administrasi
Hukum Umum, Kementerian Hukum
dan HAM RI — FAQ YayasanOfficial
government source confirming
Permenkumham No. 2 Tahun 2016 and
No. 13 Tahun 2019 as the governing
foundation-registration regulations.
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