The IDR 10 Billion Question Nobody Answers Properly: How Is Your PT PMA Investment Plan Actually Calculated

A restaurant group with five outlets across Jakarta sits down with their lawyer to plan a PT PMA structure. They have read that the investment plan threshold for foreign investment is more than IDR 10 billion per business field. Five outlets, they reason, at IDR 10 billion each, puts the total commitment somewhere around IDR 50 billion. That number changes the entire conversation: whether the structure makes sense, whether to phase the rollout, whether foreign investment is even the right vehicle for this business.

Except that math is wrong. For a food and beverage business, the IDR 10 billion threshold is not assessed per outlet, and in many cases not even per business field in the way most investors assume. It is assessed using a different KBLI digit depth and a different geographic unit entirely, and getting this wrong in either direction has real consequences. Overestimate it, and a viable business plan looks unaffordable on paper. Underestimate it, and the company commits to a structure that fails LKPM realization checks down the line.

This is the layer of detail that sits just beneath the headline numbers most investors already know. By now, most foreign investors researching PT PMA minimum capital requirements for 2026 understand that paid-up capital was reduced to IDR 2.5 billion under BKPM Regulation No. 5 of 2025, and that this figure is distinct from the IDR 10 billion total investment plan. What is less commonly explained, and what causes the most planning errors, is how that IDR 10 billion figure is actually measured once you get into specific sectors.

The General Rule, and Why It Is Only a Starting Point

Under Article 26 of BKPM Regulation No. 5 of 2025, which took effect on 2 October 2025 and consolidated the previous BKPM Regulations No. 3, 4, and 5 of 2021, the default rule states that a foreign investment company must commit to a total investment plan exceeding IDR 10 billion, calculated per five-digit KBLI code, per project location, and excluding the value of land and buildings.

Each element of that sentence carries weight:

• Per five-digit KBLI code means the most granular level of Indonesia’s industrial classification system. A company registering two distinct five-digit KBLI codes is, under the default rule, committing to two separate IDR 10 billion investment plans, not one combined plan.
• Per project location means that the same KBLI code operated in two different cities or regencies generally constitutes two separate commitments under the default rule.
• Excluding land and buildings means that for most sectors, the value of real estate the company acquires or constructs does not count toward meeting the threshold. The IDR 10 billion has to come from machinery, equipment, working capital, inventory, and other operational investment.

If every sector followed this default rule without modification, the restaurant group in the earlier example would indeed be looking at a multiplied commitment across locations. But BKPM Regulation No. 5 of 2025 carries forward, and in some cases clarifies, a set of sector-specific exceptions that change one or more of these three elements substantially.

Sector-Specific Calculation Rules Under Article 26

Wholesale Trade: Measured at the Four-Digit Level

For wholesale trade activities, the investment threshold is not measured at the five-digit KBLI level but at the four-digit level. In practical terms, this means that if a company’s wholesale trade activities fall under multiple five-digit codes that share the same four-digit parent classification, those activities can be assessed together against a single IDR 10 billion threshold, rather than each five-digit code requiring its own separate commitment.

For a trading company planning to handle multiple related product categories under the same broader classification, this consolidation can meaningfully reduce the apparent capital burden compared to a literal five-digit reading of the general rule.

Food and Beverage Services: Measured at the Two-Digit Level, Per Location Point

This is the exception most relevant to the restaurant group scenario, and arguably the one most frequently miscalculated by investors and even by some advisors still working from the pre-2025 framework.

For food and beverage services, the IDR 10 billion investment threshold is calculated using the first two digits of the KBLI code, and the geographic unit is defined as a single location point, which Article 26(3) clarifies means one regency or city (kabupaten or kota).

What this means in practice is significant. A restaurant operator running multiple outlets, potentially under several related but distinct five-digit KBLI codes, within the same city or regency, can have those outlets assessed collectively against a single IDR 10 billion threshold for that location point, rather than each outlet or each five-digit code triggering its own separate commitment. Expansion into a different city or regency, however, constitutes a new location point and a new threshold calculation.

This single clarification can be the difference between a multi-outlet F&B concept appearing to require tens of billions of rupiah in committed investment, and the same concept requiring a single IDR 10 billion commitment per city where it operates.

Construction Services: Measured at the Four-Digit Level, Per Project

Construction services follow a pattern similar to wholesale trade, with the threshold assessed at the four-digit KBLI level. For construction companies, this is generally evaluated on a per-project basis, reflecting the reality that construction activity is inherently project-based rather than tied to a fixed location in the way a retail outlet or factory might be.

Manufacturing With Multiple Product Lines: Consolidation Within a Single Facility

For manufacturing industries producing multiple related products within a single production facility, BKPM Regulation No. 5 of 2025 allows the combined value of investment across those product lines to be assessed together, provided the combined total exceeds the IDR 10 billion threshold for that facility. This prevents a manufacturer with several product SKUs under different five-digit codes, but operating from the same factory, from facing a separate IDR 10 billion requirement for each product line individually.

Property, Accommodation, and Related Sectors: Land and Buildings Can Count

The general rule excludes land and buildings from the IDR 10 billion calculation. Article 26 introduces a specific exception to this exclusion for business activities involving property management, including construction, sales, or rental, and the provision of short-term and long-term accommodation.

For PT PMA entities operating in these sectors, the value of land and buildings can be included when calculating whether the IDR 10 billion threshold has been met. Given that land and building costs typically represent the largest component of a property or hospitality investment, this exception substantially changes the practical capital planning for these sectors compared to the default rule that applies to, for example, a manufacturing operation where the factory building itself does not count toward the threshold.

Electric Vehicle Infrastructure: A Newer Addition

BKPM Regulation No. 5 of 2025 also introduces clarified provisions for electric vehicle charging infrastructure, reflecting the government’s broader policy push in this sector. The specific treatment for EV-related KBLI codes represents one of the genuinely new additions in the 2025 regulation, rather than a carryover or clarification of a 2021-era provision, and companies planning investment in this space should confirm the current calculation basis for their specific KBLI code before finalizing a capital plan.

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What Happens When a Company Holds Multiple KBLI Codes

Beyond sector-specific exceptions, one of the most common planning questions involves companies that intend to register more than one business activity under a single PT PMA. The default position under BKPM Regulation No. 5 of 2025 is that each five-digit KBLI code registered on the company’s NIB carries its own investment commitment. A PT PMA with three unrelated five-digit codes, none of which fall under a sectoral exception that allows consolidation, is generally looking at three separate IDR 10 billion commitments, not one combined figure of IDR 10 billion across all activities.

This is a point where the 2025 regulation provided clarification rather than a substantive change. Under the prior framework, some regional licensing offices had been grouping commitments at a broader four-digit subgroup level for codes that, under a strict reading, should have been assessed individually at five digits. BKPM Regulation No. 5 of 2025 confirms the five-digit basis as the default, which means companies that registered additional KBLI codes under the looser interpretation of the previous framework may need to revisit how their cumulative investment commitment is being assessed going forward.

For a company planning a PT PMA structure with multiple business lines from the outset, this makes the sequence of decisions important. Confirming which KBLI codes the business actually needs, and whether any of those codes fall under one of the sectoral consolidation exceptions described above, should happen before the investment plan is finalized and submitted through OSS, not after.

How This Plays Out in LKPM Reporting

The investment plan figure is not simply a number submitted once during registration and then forgotten. It is the baseline against which a PT PMA’s Laporan Kegiatan Penanaman Modal (LKPM), the periodic investment realization report, is measured over time.

A company that registers an investment plan calculated incorrectly, whether overstated because a sectoral exception was missed, or understated because a consolidation rule was applied where it should not have been, sets itself up for a mismatch that surfaces during LKPM reporting cycles. PTSP (Pelayanan Terpadu Satu Pintu) offices in several regions have become more active in verifying LKPM compliance against the registered investment commitment, and a company whose actual realized investment does not track toward the figure registered at incorporation can face questions during these reviews.

This is part of why getting the sector-specific calculation right at the outset matters beyond the initial registration. The figure registered becomes the reference point for compliance monitoring for as long as that KBLI code remains active on the company’s NIB.

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Working Through This Before Registration, Not After

The sectoral exceptions described in Article 26 of BKPM Regulation No. 5 of 2025 are not exhaustive in every detail, and the practical application of terms like “location point” or “single production facility” can require interpretation specific to a company’s actual business model. A food and beverage group with outlets spanning several cities, for instance, needs each location point assessed individually even while outlets within the same city or regency are consolidated.

For investors who have already worked through the broader question of how the PT PMA setup process works under the 2026 capital framework, this sector-specific calculation is typically the next layer of detail that determines whether the business plan as designed is actually viable under the registered investment commitment, or whether the KBLI selection and location structure need adjustment before the akta pendirian is finalized.

This is also where KBLI selection intersects directly with the investment calculation. Choosing between two five-digit codes that appear similar on the surface can mean the difference between a single consolidated threshold and multiple separate ones, depending on which four-digit or two-digit parent classification each code falls under. The XPND guide to KBLI classification for foreign investors covers how these codes are structured and how to identify which classification level applies to a given business activity.

XPND’s incorporation team works through this calculation as part of the entity structuring process, mapping a company’s intended business activities against the correct KBLI codes and the applicable sectoral rules before the investment plan figure is submitted, so that the number registered at incorporation is the number the business can actually realize and report against through LKPM over the years that follow.

If your business model involves multiple locations, multiple product lines, or a sector that may fall under one of these exceptions, the calculation is worth working through in detail before the registration is filed. Speak with the XPND team about how the IDR 10 billion threshold applies to your specific KBLI codes and business structure, so the figure that goes into your incorporation documents reflects your business as it will actually operate.