Legal Accountability for Construction Without Building Approval: Lessons from The Al Khoziny Islamic Boarding School Prayer Hall Collapse in Sidoarjo

The collapse of the prayer hall at Al Khoziny Islamic Boarding School in Sidoarjo on 29 September 2025 raises a legal question that is more demanding than whether a building approval document was missing: how should Indonesian law assign responsibility when administrative non-compliance, structural risk, and loss of life converge? This article examines the Building Approval (Persetujuan Bangunan Gedung, PBG) system and the potential administrative, civil, and criminal consequences associated with unsafe construction. It employs normative legal research, supplemented by a documentary case study of legislation, official disaster-management statements, government communications, and dated news reports. No interviews, structural tests, permit-register extracts, or final judicial findings were available to this study. The analysis distinguishes the legal significance of an absent PBG from the separate requirements of fault, causation, damage, and individual responsibility. It also addresses an important classification problem: a collapse during an ongoing construction project should not automatically be treated as a statutory post-handover building failure under construction-services legislation. Public reporting on Al Khoziny suggests a breakdown in the relationship between technical planning, permit control, construction supervision, and protection of occupants; it does not, by itself, establish any person’s criminal guilt. The article proposes an evidence-led accountability framework, staged construction inspections, enforceable rules on occupancy during alterations, and technical assistance that enables smaller religious schools to comply without weakening safety standards.