Client Update and Reminder: Annual Report Obligation Under MOL Regulation No. 49/2025

These are two separate requirements that serve different functions. Paid-up capital of IDR 2.5 billion is deposited at incorporation and subject to a 12-month lock-up. Investment value of more than IDR 10 billion per KBLI code is a commitment to total project expenditure, fulfilled gradually over one to three years through real business costs including salaries, office lease, equipment, and professional fees.

Paid-up capital gets your company established. Investment value is what keeps your license valid through LKPM reporting. Confusing the two is one of the most common planning errors among first-time investors establishing a PT PMA in Indonesia.

Yes, with conditions. The lock-up does not freeze the funds. The capital can be used for legitimate operational expenses including salaries, rent, equipment, and professional advisory fees, as long as every transaction is documented and traceable.

What is not permitted is returning the capital to shareholders or moving it to personal accounts without a documented operational purpose. Every expenditure will eventually feed into your LKPM investment realization record, which makes planning this in advance essential.

Not automatically. An Investor KITAS requires minimum individual share ownership of IDR 10 billion, which is governed by immigration regulations separately from the PT PMA capital requirement. The Golden Visa is determined by your investment level, shareholding structure, and OSS and LKPM compliance record.

If residency is part of your plan, the company structure needs to be designed with that threshold in mind at incorporation, not treated as a separate application after the fact.

Not all sectors are fully open. The Positive Investment List (Daftar Prioritas Investasi or DPI) under Presidential Regulation No. 49 of 2021 defines which sectors allow 100 percent foreign ownership, which carry ownership caps, and which require local partnership with cooperatives or MSMEs.

Selecting the correct KBLI code before establishing your PT PMA is critical. The wrong classification can restrict import access, increase capital requirements, or create mandatory partnership obligations that cannot be easily undone after the NIB is issued.

A PT PMA is a fully incorporated foreign investment company that can conduct commercial activities, issue invoices, generate revenue, and hire employees in Indonesia. A Representative Office, specifically a Foreign Company Representative Office (Kantor Perwakilan Perusahaan Asing or KPPA), cannot issue invoices or earn revenue from Indonesian sources. Its permitted activities are limited to market research, coordination, and preparation for eventual PT PMA establishment. If your goal is to operate commercially in Indonesia, a PT PMA is the correct structure from day one.