You searched for “negative investment list Indonesia” and landed here. That already tells us something: the term is still widely used, still referenced in investment forums, still cited in older articles scattered across the internet. Yet if you walk into a consultation today and ask an Indonesian investment adviser about the DNI, the honest answer is that it no longer exists.
Indonesia officially replaced the Negative Investment List (Daftar Negatif Investasi or DNI) in March 2021. What replaced it is structurally different, philosophically opposite, and significantly more favorable to foreign investors. Understanding both, what the DNI was and what took its place, is the clearest way to understand what is actually open to you in 2026.
What Was the Negative Investment List?
The Negative Investment List (Daftar Negatif Investasi or DNI) was the central instrument Indonesia used to regulate foreign investment for several decades. Its logic was restriction-first: the government published a list of sectors that were either fully closed or conditionally accessible to foreign capital. If your sector appeared on the list, you either could not invest at all or had to accept a capped foreign ownership percentage. If it did not appear, you could proceed.
The final version of the DNI was Presidential Regulation (Peraturan Presiden or Perpres) No. 44 of 2016. Under that regulation, at least 20 business categories were classified as fully closed to foreign investment. Dozens more carried conditional access with ownership caps that varied by sector, sometimes down to 33% or 49%, with no clear rationale tying the cap to any stated policy objective.
For foreign investors, the practical experience of the DNI was often one of uncertainty. Ownership thresholds differed across sectors without obvious logic. Updates to the list could alter eligibility without warning. And because the framework started from restriction, the burden fell on the investor to prove access rather than on the government to justify closure.
That frustration, repeated across enough investment decisions, eventually became a policy problem Indonesia could no longer ignore.
Why Indonesia Replaced the DNI
The replacement of the DNI was not an isolated policy decision. It was part of a broader structural reform effort that Indonesia pursued through the Omnibus Law (Undang-Undang Cipta Kerja or UU Cipta Kerja), Law No. 11 of 2020 on Job Creation.
The Omnibus Law was designed to address a persistent problem: Indonesia was losing investment to regional competitors because its regulatory environment was perceived as fragmented, unpredictable, and overly bureaucratic. The DNI was a visible symptom of that problem. A framework built on restriction signaled to foreign investors that entry was an exception to be negotiated rather than a right to be exercised.
Presidential Regulation No. 10 of 2021, issued in March of that year and later amended by Presidential Regulation No. 49 of 2021, was the implementing regulation that formally ended the DNI. Together, these two regulations introduced what is now known as the Positive Investment List (Daftar Prioritas Investasi or DPI).
The philosophical reversal is the key point. Under the DNI, closure was the default and openness required justification. Under the Positive Investment List, openness is the default and restriction requires justification. All business sectors in Indonesia are open to foreign investment, including up to 100% ownership, unless a regulation explicitly states otherwise.
How the Positive Investment List Works Today
Before going into which sectors are open, it helps to understand one distinction that trips up a lot of investors: the difference between ownership eligibility and licensing procedures.
As of 2026, Presidential Regulation No. 10 of 2021 as amended by Presidential Regulation No. 49 of 2021 remains the governing regulation for foreign ownership eligibility. Updates issued in 2025, including Government Regulation (Peraturan Pemerintah or PP) No. 28 of 2025 and Ministry of Investment Regulation (Peraturan Menteri Investasi atau Hilirisasi or Permenves) No. 5 of 2025, refined the licensing process and capital requirements, but did not replace or override the ownership structure established by the Positive Investment List.
When investors hear about “2025 regulatory updates,” those changes relate to how companies are licensed and how capital requirements are structured, not to which sectors are open or what foreign ownership percentages are permitted. The two are governed by separate sets of regulations entirely.
With that in mind, here is how the Positive Investment List categorizes every business activity in Indonesia.
Priority Sectors
These are business activities the Indonesian government actively wants to attract. The current list covers 245 business lines across manufacturing, infrastructure, technology, energy, and other strategic industries. Investors in priority sectors receive both fiscal and non-fiscal incentives.
Fiscal incentives include corporate income tax holidays, tax allowances, and import duty exemptions on capital goods. Non-fiscal incentives include streamlined licensing, infrastructure support, and immigration facilitation for foreign personnel. Capital-intensive businesses exceeding IDR 500 billion can receive a 100% corporate income tax reduction for up to 20 years.
To qualify, a business typically needs to meet one or more criteria: it is part of a national strategic project, it is export-oriented, it employs advanced technology, it is labor-intensive, or it involves high capital investment.
Sectors Open with Conditions
Some sectors are accessible to foreign investors but carry specific conditions. These may include a cap on foreign ownership percentage, a requirement to partner with an Indonesian entity, location restrictions, or minimum capital thresholds. The exact conditions vary by business classification, which is why verifying at the KBLI level matters so much. More on that shortly.
Sectors Reserved for Cooperatives and MSMEs
Certain activities are allocated exclusively to Indonesian cooperatives and Micro, Small, and Medium Enterprises (Usaha Mikro, Kecil, dan Menengah or UMKM). Foreign investors cannot enter these sectors directly, though in some cases partnerships with qualified local entities are permitted as an indirect route.
Sectors Closed to All Investment
A small number of activities remain completely closed. These are cultivation and processing of controlled narcotics substances, gambling and casino operations, fishing of species listed under Appendix I of the Convention on International Trade in Endangered Species (CITES), collection of coral from nature for construction, aquariums, or souvenirs, chemical weapons manufacturing, industrial chemicals that destroy the ozone layer, and alcohol beverages manufacturing, which was closed by separate presidential instruction.
That is seven categories. Compared to the 20 closed categories under the old DNI, the list has shrunk considerably, which reflects just how much the overall direction of Indonesian investment policy has shifted.
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Which Sectors Are Genuinely Open to Foreign Investors?
The practical answer is: most of them. The transition from the DNI to the Positive Investment List opened significant territory that was previously restricted or ambiguous, spanning digital economy and technology, healthcare, logistics, tourism and hospitality, renewable energy, and manufacturing. For a detailed breakdown of each sector and what the current opportunities look like in practice, XPND has covered this thoroughly in its article on business opportunities in Indonesia 2026.
Why the Sector Name Is Not Enough: Understanding KBLI
This is the part that catches a lot of investors off guard. Learning that Indonesia is “open” is a useful starting point, but it does not tell you whether your specific business activity is open, or under what conditions.
The Positive Investment List operates at the level of five-digit Business Classification Codes (Klasifikasi Baku Lapangan Usaha Indonesia or KBLI), not broad industry labels. Two businesses that appear to be in the same sector can carry entirely different foreign ownership permissions depending on which KBLI code applies to their exact activity. A general hospital and a specialist outpatient clinic are both in healthcare, but their KBLI codes differ, their permitted ownership structures differ, and their licensing pathways differ.
Selecting the wrong KBLI code creates compliance problems that surface during licensing, during mandatory Investment Activity Report (Laporan Kegiatan Penanaman Modal or LKPM) submissions, or during government audits. The problems are correctable, but correction is expensive and time-consuming.
There is also a deadline that existing PT PMA entities need to act on now. The Indonesian Central Statistics Agency (Badan Pusat Statistik or BPS) released KBLI 2025 to replace the 2020 classification. All entities must update their codes no later than June 18, 2026. Non-compliance can result in suspension of OSS (Online Single Submission or OSS) access and rejection of new license applications.
What to Actually Do Next
The negative investment list is gone, but its legacy in how people talk and think about Indonesian investment has not fully faded. Many investors, advisers, and online sources still reference the DNI, which means outdated information continues to circulate. Knowing the distinction between what used to apply and what applies now is not just academic. It directly affects whether the advice you receive, and the decisions you make based on it, are grounded in the current regulatory reality.
For any foreign investor approaching Indonesia in 2026, the process starts with identifying the precise KBLI code for your intended activity under the KBLI 2025 classification. From there, you verify foreign ownership eligibility under Perpres No. 10 of 2021 as amended by Perpres No. 49 of 2021, assess whether a Special Economic Zone changes the applicable ownership terms, and structure your capital to meet the requirements under Ministry of Investment Regulation No. 5 of 2025.
At XPND, we work with foreign investors at every stage of this process, from initial KBLI analysis and sector eligibility assessment through to PT PMA incorporation, OSS licensing, and ongoing compliance. Indonesia’s investment framework since the end of the DNI is genuinely more open than what came before. But openness does not remove the need for precision. Getting the fundamentals right from the start is still what separates a smooth entry from one that runs into avoidable problems six months later.
If you are ready to assess whether your sector is open, or you want to begin the incorporation process, contact the XPND team for a free initial consultation.
