BKPM Regulation 5/2025 sets two separate capital tests for a PT PMA: issued and paid-up capital of at least IDR 2.5 billion per company, and a total investment above IDR 10 billion for each five-digit KBLI business line at each project location. The first is cash the company holds. The second is the spending commitment you report through LKPM. Mixing them up is the most common planning error, including in earlier versions of this article. This guide is about planning: how multiple business codes change the numbers, how supporting activities and existing permits are treated, and what to check before you commit capital. For the headline rule summary see our PT PMA minimum capital guide.
What This Guide Covers
The official name is Investment and Downstreaming Minister/BKPM Head Regulation 5 of 2025 on guidelines and procedures for risk-based business licensing and investment facilities through the OSS system. It took effect on its promulgation date, 2 October 2025, and revoked BKPM Regulations 3, 4 and 5 of 2021 (Articles 398 and 400). The regulation also runs the licensing system, which our licensing guide covers. The headline capital rule is summarised in the minimum capital guide above. This article does not repeat them. It covers capital planning only.
The Two Capital Tests in Brief
| Paid-up capital (modal disetor) | Investment value | |
| Minimum | IDR 2.5 billion | More than IDR 10 billion |
| Counted | Per limited liability company | Per five-digit KBLI line, per project location |
| Land and buildings | Not applicable | Excluded for most sectors |
| Nature | Cash the shareholders subscribe and pay in | Total project spending you commit to and report |
| Source | Article 26(10) | Article 26(2) |
A PT PMA is treated as a large business and must follow the minimum investment value (Article 26(1)). A PT PMA must also meet the minimum capital rule (Article 26(9) and (10)), “unless otherwise provided by other laws and regulations”. The IDR 2.5 billion is a reduction. Under BKPM Regulation 4/2021, Article 12(7), the minimum issued and paid-up capital for a PMA was IDR 10 billion, unless other laws said otherwise. Regulation 5/2025 replaced that rule.
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How Multiple KBLI Codes Affect the Numbers
The IDR 2.5 billion does not multiply. A company with three KBLI codes still needs IDR 2.5 billion in paid-up capital, not IDR 7.5 billion.
The investment test is the one that scales with the number of codes. Each five-digit KBLI line at each project location needs total investment above IDR 10 billion. A company with two separate lines at one location therefore plans for more than IDR 20 billion of investment across the two. A supporting business line also counts if it earns income. A supporting activity must use a different KBLI from the main one, and it is exempt from the capital and investment validation. If it generates revenue or profit, however, its KBLI must be listed in the deed and it must meet the minimum investment value and capital rules (Article 35(6) and (7)). The cash in the bank account and the investment value are different numbers, and the second can be met over time through realisation reported in LKPM. See our guide to investment cash flow and capital commitment.
Worked Examples
These examples apply Article 26 as written. They are illustrations, not advice on your facts.
- One business line, one location. A software company with one five-digit KBLI line in Jakarta needs IDR 2.5 billion in paid-up capital and a total investment above IDR 10 billion for that line.
- Two business lines, one location. A company with two separate five-digit lines in Jakarta needs IDR 2.5 billion in paid-up capital in total and more than IDR 10 billion of investment for each line, so a plan above IDR 20 billion across both.
- Food and beverage in two cities. F&B is counted per first two KBLI digits per location, and a location is a regency or city (Article 26(3)(b) and (4)). Outlets in one city share one IDR 10 billion test. Outlets in a second city need their own.
- Wholesale trade with several product codes. Wholesale trade is counted per the first four KBLI digits (Article 26(3)(a)), so several five-digit wholesale codes that share the first four digits fall under one test.
- An existing company adds a line. A new KBLI line is a new line, so it needs its own investment test. The transition rules in Articles 394 and 395 protect the capital terms of existing licences, not new lines.
Where the IDR 10 Billion Test Is Counted Differently
Article 26(3) changes the counting unit for some activities:
- Wholesale trade: per the first four KBLI digits.
- Food and beverage services: per the first two KBLI digits per location, where a location means a regency or city (Article 26(4)).
- Construction services: per the first four KBLI digits.
- Manufacturing: per single production line that makes a range of products.
Other rules apply as follows. For property, short-term and long-term accommodation, farming, plantations, livestock and aquaculture, land and buildings count toward the IDR 10 billion (Article 26(5)). Public EV charging is assessed per province (Article 26(7)). In special economic zones the investment rules follow the presidential regulation on investment fields (Article 26(8)).
The 12-Month Retention Rule
Paid-up capital cannot be moved out of the company’s bank account for at least 12 months from the date it is paid in. The exceptions are buying assets, constructing buildings and operating the business (Article 27(1)). The commitment is made as a self-declaration in OSS when you apply for the business licence, and breaking it brings administrative sanctions (Article 27(2) to (4)).
The declaration is stored in OSS with your business licence (Appendix I of the regulation). On our reading, the capital can pay for running costs, equipment and construction, but it should not be returned to shareholders, lent back to them or moved to related parties within the first year. Keep the bank evidence and invoices. Our guide to proof of capital injection explains how to document it.
What Did Not Change: The Investor KITAS Threshold
The investor KITAS has its own test, set by immigration rules rather than by BKPM Regulation 5/2025. The foreign investor must show shares of at least IDR 10 billion in the investment ministry’s data (Ministry of Law Regulation 22 of 2023 as amended, Article 38). A founder holding a company with IDR 2.5 billion in paid-up capital does not meet that test on the capital alone.
If your shareholding is lower, the usual alternative is a work permit with an approved foreign worker plan (RPTKA) under Government Regulation 34 of 2021, Article 6, together with the foreign worker compensation fund payable for each foreign worker (Article 23(1)). Article 19(1) exempts a director or commissioner with a certain shareholding from the RPTKA approval, but it does not say the fund is waived, so confirm that point with the manpower office. See our investor KITAS guide.
Existing PT PMAs and the Transition Rules
Permits that were valid, verified and approved before 2 October 2025 stay valid (Article 389), and the new licensing rules do not apply to them unless the new rules are more favourable (Article 394).
On capital, Article 395 says that when an existing PMA changes its project location or extends a licence issued before the regulation, it follows the capital and minimum-investment rules of the licence it already has. When it expands an activity for which it already holds a business licence, the capital rules of that existing licence apply. We found no provision in the text that forces an existing company to restructure. Check your own licence conditions before adding a new KBLI line, because a new line is not covered by that transition rule.
KBLI 2025 and Your Business Codes
Statistics Agency Regulation 7 of 2025 replaced KBLI 2020. It was issued on 17 December 2025 and took effect on promulgation, which was 18 December 2025. Users of KBLI had six months from promulgation to adjust (Article 5), so the window closed in June 2026. Regulation 5/2025 says that when KBLI changes, the OSS system updates the licensing data to follow the new classification automatically (Article 393).
Check your company’s codes in OSS. A code that was split or renamed can change the risk level, the permits required and the investment value test. Our KBLI codes guide explains how to pick codes.
LKPM Reporting and Your Capital
A PT PMA is a large business, so it reports quarterly. The deadlines are the 15th of April, July, October and January (Article 286(5)). The report covers investment realisation, workforce and production (Article 285(3)). Realisation of the IDR 10 billion investment is shown here, so keep bank records and invoices that match what you report. Missing reports lead to graduated administrative sanctions. See our LKPM reporting guide.
A Practical Checklist
- List every five-digit KBLI line and project location, and calculate the investment value for each.
- Confirm paid-up capital of at least IDR 2.5 billion for the company, and check whether your sector’s own rules require more.
- Wire the capital from the shareholder’s account into the company account and keep the bank evidence.
- Make the 12-month retention declaration in OSS and track the exceptions you use.
- Align your KBLI codes with KBLI 2025.
- Put the quarterly LKPM dates in the finance calendar.
- If founders want an investor KITAS, check the separate IDR 10 billion share test.
How XPND Helps With PT PMA Capital Planning
XPND models the paid-up capital and the investment value for each KBLI line before you incorporate, prepares the OSS declarations and supports the LKPM reports afterwards. To set up the company, see our PT PMA formation service or get a free consultation.
