Rahmat Wibowo shared an analytical article casting doubt on Kampus Malaka and the Abil Sudarman School of Artificial Intelligence, pointedly noting both founders' unverified or incomplete undergraduate credentials and arguing neither venture can legally become a university under Indonesia's regulatory requirements.
| ID | ev-20260728-016 |
|---|---|
| Source | Infraloka Blog |
| Targets | Ferry Irwandi Sabda PS Abil Sudarman (Abigail Aryaputra Sudarman) |

Transcript
The Paper Wall: why a
university can't be
built ina month, Case
Study of Abil
Sudarman School of
Artificial Intelligence
and Kampus Malaka
By Ferry Irwandi
RahmatWibowo - June1,2026
‘The Paper Wall:
iversity can't be built
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 howlong the real
version of this actually takes.
"We'll build a university." It
sounds like a sentence. Itis
actually a five-agency permission
chain.
In Indonesia, the word universitasis not a
brand you can put ona building. Itis a
legal status, granted by the national
government, that requires anon-profit
legal entity, a notarized land certificate, a
minimum faculty roster with verified
graduate degrees, an institutional
accreditation score, anda ministerial
decree, in that order. None of those five
things canbe skipped, rushed pasta
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 orincomplete.
Neither problem, the bureaucracy or the
credentials, is hidden. Both are
searchable. This page lays out exactly
what stands between “we have anidea
anda 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, ortraining
programs, categories with essentially no
entry barrier, The wall appears the
momenteitherone tries to callitselfa
university.
Siapa Sebenarnya Abil Sudarman?
Profil, Background, dan Kisah Viral Al
Tracking Anggaran Pemerintah
SIAPA SEBENARNYA
prof, Background, dan
ACHING
A Gan PEMERITAH
‘Siapa Sebenarnya Abil Sudarman? Profil,
Background, dan Kisah Viral Al Tracking
‘Anggaran Pemerintah
Sevenregulations you cannot
route around
Every requirement belowtraces toa
specific, currently active Indonesian
regulation, None of these are guidelines;
eachis the binding instrument a ministry
cites whenit rejects an application
UU No. 16/2001 & UU No. 28/2004
**Foundation Law (Yayasan)**Defines
howa non-profit legal foundations
created, whoits organs are (founders,
supervisors, management board), and
what happens toits assets. Auniversity
cannot legally exist without a Badan
Penyelenggara, foundation or
association, sitting aboveit as the legal
owner.
Permenkumham No. 2/2016 & No.
13/2019
Foundation Registration ProcedureSets
out exactly howa 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.
UUNo. 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
forexact sciences, 1:30 for social
sciences, that institutions must hold to
remain compliant afterlaunch.
Permendikbud No. 7/2020
Establishment, Change, and Closure of
PTN/PTSThe core regulation institutions
are actually licensed under today.
Specifes 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 beforea single applicationis
filed
Permendikbud No. 84/2013
Appointment of Permanent
LecturersGoverns howa 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, anational lectureridentification
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
forlecturer-ratio standards and minimum
program-of-study counts: at least three
study programs to be chartered asa
universitas, two fora 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 ona 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 m2
fora 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 openas auniversitas (two
for other forms), since a single course or
bootcamp track doesn't meet the legal
definition of higher education.
Each programneeds 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 recommendationis also
required, coveringa regional track record
review, a program saturation check, anda
viability assessment of whether the area
already has enough capacity in that field
and whether this particular founder group
has the track record to sustainit.
Finally, of the available institutional forms,
only akademi and politeknik are currently
open tonew applicants.
Six doors, inorder. You cannot
knock on door three before door
one answers.
Thisis 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.
Whata content following actually
substitutes for, and what it
cannot touch
Three ways founders try to
compress the timeline, and what
actually happens
“Launchas acommunity or
bootcamp first, convert toa
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, whichis 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 processitself
“Acquire or merge with an
existing, already-licensed PTS
instead of starting fresh."
This is the one real structural shortcutin
the system. Because brand-new
universitas and institut charters are under
moratorium, the realistic fast path for
anyone wanting that exact legal formis a
perubahan bentuk, taking over or
merging with an existing, already-
accredited private institution and
rebranding jit, rather than filing fora 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 itis meaningfully
faster than the 18 to 30 month new-
charter path andis 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. Alecturer dossier built on
unverifiable or padded credentials is also
the single most common reason LLDIKTI
orthe 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 fing, since procedural detail
pages are updated by the ministries
without separate public notice.
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.
Wikipedia Bahasa Indonesia — Ferry
\rwandiBiographical reference
including STAN and Central
Queensland University education
history.
Jurnal Aceh / Pikiran Rakyat — "Ferry
Inwandi dan Malaka Project: Kisah di
Balik Impian Membangun Kampus
Rakyat’ Coverage of the "people's
university" concept and curriculum
framing for Kampus Malaka.
PNS Kemenkeu Menjadi Kreator
Konten dan CEO Malaka
Project"Background on the founder's
prior civil service careerand
scholarship program design.
Ruang.id — "Membongkar Paradigma
Pendidikan: Ferry Inwandi dan Misi
Gila’ di Balik Kampus
Malaka" Reporting on Kampus
Malaka’s March 2026 instructor
recruitment window.
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
Centerroles
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 formas an Al
training platform.
Ridwan Institute — "Syarat Mendirikan
Perguruan Tinggi Terbaru" Overview of
current legal-entity, land, and
academic planning requirements for
new PTS.
EDC — "Syarat Pendirian Perguruan
Tinggi Swasta"Source for current
land-area minimums by institutional
form and the active moratorium on
new universitas/institut charters.
EDC — "Syarat Pendirian Institut
Terbaru 2026"Definitions of Badan
Penyelenggara and Pendirian PTS
under the governing ministerial
regulation
Jogloabang —Permendikbud No.7
Tahun 2020, full text summaryPrimary
source for foundation document
requirements, land certificate rules,
and lecturer commitment letter
obligations.
"Sistem Layanan Rekomendasi
Pembukaan Program Studi Baru dan
Pendirian PTS Baru"Official 2026
requirements notice for new study
programandnewPTS
recommendation submissions.
Dunia Dosen — "Syarat Dosen Tetap
Yayasan yang PerluAnda
Ketahui' Source on Permendikbud No.
84 Tahun 2013 governing appointment
of permanent (non-civil-servant)
lecturers.
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.
Universitas Padjadjaran — "Instrumen
Pemenuhan Syarat Akreditasi
Minimum Program Studi Baru"Official
BAN-PT-aligned instrument
specifying the minimum fve-lecturer,
three-permanent-lecturer threshold
pernew study program.
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.
Valeed — *Syarat Mendirikan Yayasan
Terbaru dan Lengkap Sesuai Hukum di
Indonesia’ Source for the realistic
two-to-four-week Kemenkumham
foundation ratification timeline.
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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