A freight forwarder that had operated under the same business classification for six years opened its OSS account in early 2026 and found something had changed underneath it without a single notification. The code was still there. What it authorized was not the same anymore. Somewhere between the old system and the new one, an entire category of activity the company had been performing legally for years had quietly shifted to a different classification entirely, one the company did not hold.
That confusion is not isolated to one operator. It is the direct result of a reclassification that landed on Indonesia’s freight forwarding industry with almost no warning, and untangling it is now the first real compliance task facing any foreign investor entering the sector.
A Reclassification Nobody in the Industry Asked For
Late in 2025, Statistics Indonesia issued BPS Regulation No. 7 of 2025 on the 2025 Indonesian Standard Industrial Classification (KBLI), and buried inside a routine-sounding classification update was a swap that upended how freight forwarding gets licensed. Jasa Pengurusan Transportasi (JPT), the freight forwarding activity long classified under KBLI 52291, moved to a new code, 52311, now categorized as Transportation Intermediation Services for Goods. In its place, KBLI 52291 was reassigned to Badan Usaha Angkutan Multimoda (BUAM), the multimodal transport operator category previously sitting under code 52295.
The practical effect blindsided thousands of operators. Under the new 52311 classification, a JPT company loses access to several activities it could previously perform under its own license, warehousing, cargo space provision, and coordination functions that now sit specifically under the BUAM classification instead. The Indonesian Logistics and Forwarders Association (ALFI), representing more than 4,000 freight forwarding companies nationally, pushed back publicly, and the pushback carried an edge beyond ordinary regulatory friction. Some operators in the sector openly questioned whether foreign interests had shaped the reclassification, given how directly it narrowed what a purely domestic-style JPT license now permits.
For a foreign investor evaluating entry into this sector right now, the immediate practical question is not whether this dispute resolves in the industry’s favor. It is what the transition actually requires in the meantime. BKPM has confirmed that licenses issued before the KBLI 2025 update remain valid as issued, and that companies only need to formally adjust their classification where the substance of their business activity has actually changed. The numeric code itself will be synchronized automatically across OSS and the Directorate General of General Legal Administration (Ditjen AHU) no later than 18 June 2026, a deadline that is closer than it looks for any company still assuming this reclassification is someone else’s problem.
Three Different Licenses, Often Confused as One
Even before this reclassification, freight forwarding in Indonesia ran on a three-license structure that first-time investors routinely collapse into one. Each license authorizes a genuinely different function, and holding one does not imply the others.
SIUJPT, the Base Freight Forwarding License
The Surat Izin Usaha Jasa Pengurusan Transportasi (SIUJPT) is the foundational license for arranging and coordinating the movement of goods across land, sea, air, or rail on a client’s behalf. It is governed by Minister of Transportation Regulation No. 12 of 2021, issued through OSS, and valid for five years before renewal. Which government body actually issues the license depends on scope. Provincial-level operators apply through the relevant Governor’s office, while PT PMA entities and companies with a national operating footprint apply through the Minister or the BKPM Head instead.
PPJK, the Separate Customs Clearance License
Pengusaha Pengurusan Jasa Kepabeanan (PPJK), customs clearance authority, is a distinct license entirely, governed by Director General of Customs and Excise Regulation No. PER-11/BC/2020. A company can hold a full SIUJPT and still have no legal authority to handle customs clearance on a client’s behalf without separately securing PPJK status. Companies that assume freight forwarding authority automatically extends to customs brokerage are operating outside their actual legal scope the moment a shipment requires clearance handling.
MTO, the License for End-to-End Contractual Responsibility
Multimodal Transport Operator (MTO) status sits on top of both of the above, and it is what a company needs when it takes on full contractual responsibility for a shipment across its entire multimodal journey, rather than simply coordinating individual legs on a client’s behalf. The KBLI code historically tied to MTO status, 52295, is itself caught up in the same 2025 reclassification confusion, which makes confirming an MTO application’s current code status a genuine prerequisite rather than a formality right now.
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The Capital Number That Surprises Most First-Time Investors
Standard PT PMA incorporation in Indonesia carries a minimum paid-up capital requirement of IDR 2.5 billion, a figure most foreign investors research early and budget around without much friction. Freight forwarding does not follow that baseline. A JPT license carries its own minimum capital requirement of IDR 25 billion, a full order of magnitude higher than the general PT PMA floor. XPND’s broader comparison of PT PMA and PT PMDN capital structures covers how that general baseline works, and freight forwarding is exactly the kind of sector where relying on the general figure leads to underfunding a license application that was never going to clear at the standard threshold in the first place.
Which Logistics Activities Are Actually Open to Full Foreign Ownership
Foreign ownership permissions across logistics are not uniform, and treating the sector as a single ownership category is the second most common structuring mistake after underestimating capital. Courier services, classified under KBLI 53202, and warehousing, under KBLI 52101, are both open to 100 percent foreign ownership under the current Positive Investment List. Freight forwarding and multimodal transport carry their own separate ownership conditions tied to their specific KBLI codes, conditions that are now further complicated by the 52291 and 52311 reclassification described above.
Given how much movement this sector’s classification system has seen in a short window, verifying the current foreign ownership status for the exact code and activity in question, rather than assuming a sector-wide percentage, is essential due diligence rather than caution for its own sake. The general mechanics of how the Positive Investment List assigns ownership permissions at the KBLI level are explained in full in XPND’s explainer on what replaced the Negative Investment List, and the broader classification selection process is covered in the site’s KBLI 2026 guide for foreign investors.
Cabotage Still Blocks Foreign Vessels From Domestic Sea Cargo
One restriction the recent reclassification did not touch, and that foreign logistics investors sometimes overlook entirely, is Indonesia’s cabotage principle. Under Law No. 17 of 2008 on Shipping, together with Government Regulation No. 31 of 2021, domestic sea cargo transport between Indonesian ports is reserved for Indonesian-flagged vessels operated by Indonesian shipping companies. A foreign-owned freight forwarder can coordinate and arrange domestic shipments, but it cannot own or operate the vessels physically carrying cargo between Indonesian ports without structuring around this restriction separately. This distinction matters most for investors evaluating vertical integration into shipping capacity itself, rather than remaining purely a coordination and documentation intermediary.
Where the Ports and Corridors Actually Sit
Licensing aside, freight forwarding is ultimately a geography business, and Indonesia’s two most active foreign investment corridors for logistics happen to sit around two very different port profiles. East Java’s Tanjung Perak has become the anchor for Surabaya’s positioning as, in XPND’s own description, the country’s eastern logistics nerve center, a role explored further in the site’s overview of operating a logistics or manufacturing business in Surabaya and East Java. Batam offers a different profile entirely, with cargo handling split across Batu Ampar for general containers, Kabil’s dedicated in-estate cargo port, and Hang Nadim for air freight, a breakdown covered in detail in the site’s guide to Batam’s industrial parks. Matching a target trade lane to the right corridor before signing a lease is worth doing before the licensing sequence even starts, not after.
A Practical Checklist Before the June 2026 Sync Deadline
Bringing the classification confusion, the license structure, and the capital requirement together, a foreign investor entering this sector right now benefits from working through a specific sequence rather than a general one.
- Confirm whether an existing or planned freight forwarding entity’s KBLI classification reflects the pre or post 2025 code, and whether any activity performed actually requires the BUAM classification alongside SIUJPT
- Determine separately whether PPJK customs clearance authority is needed, since SIUJPT alone does not grant it
- Assess whether the business model requires MTO status, given the added contractual liability and the code confusion currently surrounding it
- Budget against the IDR 25 billion JPT capital threshold specifically, not the standard PT PMA minimum
- Verify current foreign ownership permissions against the exact KBLI code in question rather than a general sector assumption
- Evaluate cabotage exposure if the business model includes any ambition toward owning or operating vessel capacity
None of these steps are difficult individually, but skipping the sequence in a sector whose own classification system is mid-transition is exactly how a company ends up holding a license that no longer authorizes what it assumed it did.
XPND’s logistics sector team is tracking the KBLI 52291 and 52311 transition as it develops, confirming for clients whether an existing license needs formal reclassification ahead of the June 2026 synchronization deadline and whether any operational activity now falls outside what a current license actually covers. A freight forwarder that assumed its classification was settled has, for the first time in years, genuine reason to check again before the ground shifts any further underneath it.