1. Deconstruction of "Branch Technicalities" and Association Status

It is important to understand the nature of the PBPI legal subject. PBPI is aPerkumpulan(association), a private legal entity. Although its purpose concerns the public interest (sports development), its status does not automatically give it public authority like a government agency. It is often misunderstood that the parent organization has the authority to take care of state administrative matters. It needs to be emphasized, based on an analysis of the PBPI association profile,tidak ditemukan adanya kewenangan bagi PBPI untuk membantu pihak ketiga (penyelenggara turnamen) dalam melakukan proses koordinasi dengan otoritas publik, such as immigration and the police. In addition, the argument often used to justify the deep involvement of the parent organization is "branch technicalities", as mentioned in Article 103 paragraph (1) of Law 11/2022. However, this interpretation must be straightened out. The explanation of Article 52 of Law 11/2022 provides vital clarification that "branch technicalities" refers more to the uniformity of Standard Operating Procedures (SOP) that are directly related to the substance of the sport, namely "technical matters related to the characteristics and regulations of a Sports match/competition." This includes standardization of the game (rules of the game) and the rules of the game, not the administrative authority to organize events broadly. Furthermore, Article 52 of Law 11/2022 explicitly imposes the obligation to fulfill the technical requirements of the branch (including health, safety, etc.) tosports championship organizers, not to PBPI. PBPI acts as a technical validator, not an administrative coordinator.

  1. Recommendation Authority: Limited, Conditional, and Must Be Transparent

One of the control instruments that is often debated is the authority to provide recommendations. Article 54 paragraph (1) of Law 11/2022 does provide space for the Parent Organization of Sports Branches to provide recommendations. However, this authority is not absolute and is accompanied by strict prerequisites to prevent abuse. First, the authority is limited to providing recommendations, not absolute permission. The recommendation serves as a technical verification that the tournament meets applicable standards, not as an organizing license. Second, and more crucially, the exercise of this authority must be preceded by clear and permanent internal organizational regulations. The requirements for obtaining a recommendation must be regulated firmly, transparently, and accessible to the public. This is a manifestation ofthe principle of publicitywhich is fundamental in good organizational governance (good governance). The purpose of this transparency requirement is vital: