Who Pays the 20 Percent Deduction? Vacancy in Concession Funding Arrangements in Government Regulation Number 31 of 2026

Abstract

Government Regulation No. 31 of 2026 establishes disability-related concessions across nine sectors but leaves unresolved the question of how service providers should finance the mandatory minimum tariff reduction of 20%. This study aims to identify sector-specific financing vulnerabilities, assess existing compensation mechanisms, and formulate feasible funding recommendations. A qualitative documentary research approach integrates legal analysis with a synthesis of published policy reports, subsidy practices, and budgetary frameworks. The analysis examines regulatory delegation provisions, service provider ownership structures, financing alternatives, and implementation risks. The findings identify 19 delegation clauses that lack explicit provisions requiring compensation for service providers. Private suppliers of assistive devices and land transportation operators face substantial financial exposure because existing public service obligation (PSO) and electricity subsidy schemes primarily operate through state-owned enterprises. Transitional disability eligibility documentation further complicates the verification of concession claims. Among the available financing options—ministerial budget allocations, intergovernmental fiscal transfers, and tax expenditures—ministerial budget allocations represent the most feasible initial funding mechanism within the regulatory implementation period. The study proposes a pilot reimbursement scheme for assistive devices administered by the Ministry of Social Affairs, supported by verified disability identification, reimbursement ceilings, periodic financial reconciliation, and personal data protection safeguards. The study concludes that explicit financing provisions and a coordinated provider compensation framework are essential to prevent formal administrative compliance from concealing unresolved funding gaps and to ensure equitable and sustainable access to disability-related concessions nationwide.