Primary vs secondary KBLI code Indonesia rules decide how your PT PMA’s activities are licensed, which of them must appear in the deed, and which of them trigger a minimum investment test. In the Indonesian rules the word is not “secondary” but “supporting” (kegiatan usaha pendukung), and a supporting code is not a code that is barred from earning money. This guide explains the test, the conditions that apply to a supporting code, and the point at which it must be treated like a primary one. For the basics of the code system, start with our complete guide to KBLI codes.
Primary and Supporting Activities Are Defined by Rule
When you register a business activity in the OSS system, you classify each five-digit KBLI code as either a primary activity (kegiatan usaha utama) or a supporting activity (kegiatan usaha pendukung). The rules are in Article 35 of Investment Minister Regulation (BKPM) 5/2025, which follows Article 210 of Government Regulation (PP) 28/2025.
| Point | Primary activity | Supporting activity |
| What it is | The activity that is your source of income or profit | An activity that supports the primary activity |
| Listed in the deed | Yes, the primary activity is the one stated in the deed of establishment or amendment, as approved | Not required while it does not earn revenue |
| Can earn revenue | Yes | Yes (Article 35(6)(b)) |
| Same KBLI as the primary | n/a | Not allowed; the code must differ (Article 35(6)(d)) |
| Timing | Applied for first | The licence application can be filed after the one for the primary activity |
| Can start early | After it gets operational or commercial legality | Can obtain operational legality and operate before the primary activity gets its operational or commercial legality (Article 35(6)(e)) |
| Licensing requirements | Per its risk level | Still applies, including risk identification (Article 35(6)(f)) |
| Minimum investment and capital check | Applies | Exempt, until it becomes a source of revenue (Article 35(6)(g) and (7)) |
If the supporting activity shares a location with the primary one, you can use the primary activity’s spatial approval (KKPR) and, where the environmental document already covers it, its environmental approval. A building needed for the supporting activity still needs its own building approval and functionality certificate (Article 44).
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A Supporting Code Can Earn Revenue, With Conditions
A common misreading is that a supporting code cannot generate independent commercial revenue. The regulation says the opposite: a supporting activity “can be a source of income or generate profit” (Article 35(6)(b)). What changes is the paperwork once it does. Under Article 35(7), if a supporting activity is a source of income, the business must:
- list the supporting KBLI code in the deed together with its approval; and
- meet the minimum investment and capital requirements in Articles 25 and 26.
So the real question is not whether a supporting code is allowed to earn, but when you cross the point at which it must be treated like a primary line. Plan for that point at the start. For example, a software company that adds a consulting code as a supporting activity can invoice consulting work, but once consulting becomes a regular revenue line, the deed and the investment calculation need to reflect it.
When a Supporting Code Must Go Into the Deed
For a PT, the primary activities are the ones stated in the deed. A supporting code is outside the deed only while it does not earn revenue. When it starts to, the deed’s purpose and objectives clause must include its KBLI code. That is a deed amendment: the shareholders approve it in a general meeting, the notary prepares it, and the change is filed with the legal entity system. Our guides to calling an extraordinary general meeting, RUPS for a PT PMA and the documents required for PT PMA incorporation cover the steps.
If a code was filed wrongly, see our guide on the consequences of a wrong KBLI code and how to fix it.
Single Purpose and Other Special Business Fields
Some fields are classified as special business fields: single purpose, limited purpose and single majority (Article 10(1)(f) of BKPM Regulation 5/2025). Which rules apply to them follow the law or government regulation of that sector (Article 10(3)). In practice, a company that falls in one of these fields may be required to be set up for that field only, so adding unrelated codes can be blocked. Check the sector law before you add any other activity to the same company. OSS also treats these companies differently when a licence is withdrawn (Article 351(5)).
KBLI 2025 and What It Changes
The code list itself has changed. BPS Regulation 7/2025, signed on 17 December 2025, sets KBLI 2025 and revokes BPS Regulation 2/2020 (the KBLI 2020 list). Users of KBLI must align with it within six months of the regulation’s promulgation (Article 5). It does not set the primary and supporting rules; those come from PP 28/2025 and BKPM Regulation 5/2025, which replaced the earlier BKPM Regulation 4/2021. Your codes may need to be mapped to their KBLI 2025 equivalents. Our KBLI 2026 guide for foreign investors explains how the update affects an existing company.
How This Affects Capital Planning
For a PT PMA, the minimum investment is more than IDR 10 billion, excluding land and buildings, per five-digit KBLI code per project location (Article 26(2) of BKPM Regulation 5/2025). The rule has exceptions for wholesale trade and construction (counted per the first four digits), food and beverage services (the first two digits per location) and industry (per production line) (Article 26(3)). On top of that, a PT PMA needs paid-up capital of at least IDR 2.5 billion per company (Article 26(10)), and the paid-up capital cannot be moved out of the company’s account for at least 12 months, except for buying assets, constructing buildings or operating the business (Article 27).
Each primary activity brings its own investment line. A supporting code is exempt from this check only while it does not earn revenue, which is why a supporting code that later becomes a real revenue stream can create a gap between your planned and required investment. See our guides to PT PMA minimum capital and the PT PMA establishment cost breakdown.
A Practical Sequence for Structuring Your Codes
- List every activity you expect to earn money from in the next two to three years, not only the first one.
- Mark the ones that will be a real revenue source as primary, and give each its own five-digit KBLI code.
- Use supporting codes only for activities that support the primary line, with a KBLI different from the primary one.
- Check each code against the sector rules for foreign investment and the special business fields.
- Work out the investment per five-digit KBLI per location before you file.
- Review the position each time a supporting activity starts to bring in revenue, and amend the deed if needed.
If you are not sure how your codes should be split, our regulatory compliance team can review your structure, or you can contact XPND.
