Jakarta remains the primary magnet for foreign investors seeking to enter the Indonesian market. A mature business infrastructure, direct access to central government regulators, and a strong financial ecosystem make the capital city an ideal starting point for establishing a Foreign Investment Limited Liability Company (Perseroan Terbatas Penanaman Modal Asing or PT PMA).

However, amid rising physical office rental costs and tighter post 2025 regulations, many investors are beginning to consider a virtual office in Jakarta as a more efficient business domicile alternative. This raises a critical question: Is it still possible to establish a PT PMA in Jakarta by relying solely on a virtual office?

This question can no longer be answered in a simplistic manner. Changes in investment regulations, adjustments to the risk based licensing system Online Single Submission Risk Based Approach (OSS RBA), updated zoning rules in Jakarta, and stricter tax requirements mean that the use of a virtual office in Jakarta for PT PMA must be assessed comprehensively.

Without a clear understanding of the regulatory framework, a decision that appears efficient at the outset may later develop into legal and administrative risks.

Legal Basis for Virtual Office in Jakarta (2026 Update)

The use of a virtual office in Jakarta has a legal foundation that differs from other regions in Indonesia. 

Its initial recognition is based on Circular Letter of the Head of the One Stop Integrated Service Agency (Surat Edaran Kepala Badan Pelayanan Terpadu Satu Pintu or BPTSP) of DKI Jakarta Number 06 of 2016, which acknowledges virtual domicile as a valid business address.

However, this recognition is not absolute and is highly dependent on compliance with spatial planning regulations and the risk based licensing framework under OSS RBA.

Since the enactment of Governor Regulation of DKI Jakarta Number 31 of 2022 on the Detailed Spatial Plan (Rencana Detail Tata Ruang or RDTR), the OSS RBA system automatically filters applications based on zoning compliance.

A PT PMA may only use a virtual office in Jakarta if the address is located within a Designated Office Sub Zone (Sub Zona Perkantoran or KT). If the virtual office is located in a residential or non commercial zone, the OSS system may reject the application or revoke an already issued license.

In addition to zoning compliance, Spatial Utilization Conformity (Kesesuaian Kegiatan Pemanfaatan Ruang or KKPR) is a mandatory requirement. Without confirmed spatial conformity, a virtual office address cannot be used as a lawful domicile for a PT PMA even if all administrative documents appear complete.

Updated Capital Structure Requirements for PT PMA under 2025 Regulations

One of the most significant changes in the foreign investment landscape is the adjustment of PT PMA capital structure under Investment Coordinating Board Regulation (Peraturan Badan Koordinasi Penanaman Modal or BKPM) Number 5 of 2025.

This regulation clearly separates the minimum paid up capital required to establish a legal entity from the total investment commitment required for business operations.

The minimum paid up capital for a PT PMA is now set at IDR 2.5 billion per company. This provides greater flexibility for investors during the initial establishment phase.

However, it is important to note that the total minimum investment value must still exceed IDR 10 billion per five digit Indonesian Standard Industrial Classification code (Klasifikasi Baku Lapangan Usaha Indonesia or KBLI) per project location, excluding land and buildings.

In addition, a twelve month capital lock in requirement applies from the date of capital injection. Funds may not be withdrawn or transferred except for legitimate and well documented business expenses.

In the context of using a virtual office in Jakarta, operational cost claims that do not align with the company’s business model or domicile may raise red flags during audits conducted by the Investment Coordinating Board.

Business Sectors Not Permitted to Use a Virtual Office

Not all business sectors are permitted to use a virtual office in Jakarta as the domicile for a PT PMA. The government has explicitly restricted certain sectors to protect consumers, ensure transaction security, and maintain operational accountability.

Sectors that are generally required to maintain a physical office or operational facility include:

  • Construction services that require physical verification and Business Entity Certification (Sertifikat Badan Usaha or SBU)
  • Transportation and logistics services involving fleets and field operations
  • Tourism and hospitality businesses that require physical verification of service standards
  • Manufacturing industries that must operate within designated industrial zones
  • Large scale electronic commerce businesses that require a verifiable physical address for consumer dispute resolution and tax compliance

Conversely, service based sectors such as management consulting, information technology services, creative design, and professional services are the most suitable candidates for using a virtual office, provided that business activities are conducted flexibly and transparently.

Virtual Office and Taxable Entrepreneur Status in 2025

The most significant regulatory shift in 2025 from a tax perspective arises from Director General of Taxes Regulation Number PER 7 of 2025. This regulation tightens the requirements for obtaining Taxable Entrepreneur status (Pengusaha Kena Pajak or PKP) for companies using a virtual office.

PKP registration through a virtual office is now permitted only if the company’s primary business activity falls within the services sector. Wholesale trading or distribution companies are generally denied PKP registration if they rely solely on a virtual office address without evidence of a warehouse or physical operational office.

Additional requirements include the following:

  • The virtual office provider must itself be registered as a Taxable Entrepreneur.
  • A minimum one year lease agreement must be demonstrable.
  • The virtual office must provide a physical space that can be verified through on site inspections by tax officials.

PT PMA entities that already hold PKP status but fail to meet these new criteria are given a transition period until the end of 2025 to adjust their domicile. Failure to comply may result in administrative revocation of PKP status.

Mandatory Transition to KBLI 2025 for PT PMA

Statistics Indonesia (Badan Pusat Statistik or BPS) has officially released KBLI 2025 to replace the 2020 classification. All PT PMA entities, whether newly established or already operating, must update their KBLI codes no later than 18 June 2026.

Non compliance may lead to serious consequences, including suspension of OSS access, rejection of new license applications, inconsistencies in Investment Activity Reports (Laporan Kegiatan Penanaman Modal or LKPM), and denial of Limited Stay Permit (Kartu Izin Tinggal Terbatas or KITAS) applications for foreign personnel.

In the context of a virtual office in Jakarta, KBLI adjustments must be handled carefully. If a revised business classification falls into a sector that requires a physical office, the PT PMA must transition away from a virtual office to maintain legal compliance.

BKPM Supervision, LKPM Reporting, and Audit Risks

The establishment of a PT PMA does not end with the issuance of a Business Identification Number (Nomor Induk Berusaha or NIB). Post licensing supervision has become a primary focus of the Investment Coordinating Board through mandatory quarterly LKPM submissions.

Companies using a virtual office in Jakarta often fall into the pattern of repeated zero activity reports due to minimal physical operations. Under current regulations, repeated zero reporting increases the company’s risk profile and may trigger on site audits.

If it is determined that a PT PMA functions merely as a passive entity or shell company, the most severe sanction is permanent revocation of its NIB.

Accordingly, even when operating from a virtual office, PT PMA entities are advised to consistently report investment realization, including office lease expenses, employee salaries, marketing costs, and other operational expenditures.

Virtual Office, Banking, and Immigration Considerations

A PT PMA’s registered address plays a critical role in both banking and immigration processes.

Banks apply strict Know Your Customer (KYC) procedures and frequently conduct physical verification visits. A virtual office in Jakarta that lacks an active receptionist or adequate meeting facilities may result in rejection during corporate bank account opening.

From an immigration perspective, a PT PMA acts as the sponsor for Investor KITAS or Work KITAS holders. If authorities suspect that a company uses a virtual office solely to obtain residency without genuine business activity, visa applications may be collectively rejected.

The Role of XPND in Supporting Virtual Office Establishment for PT PMA in Jakarta

Amid tighter foreign investment regulations and increased scrutiny of business domiciles, the use of a virtual office in Jakarta for PT PMA can no longer be treated as a purely administrative shortcut. It must be aligned with business structure, KBLI compliance, and readiness for audits by BKPM, tax authorities, and banks.

In this context, XPND acts as a strategic partner that assists investors in positioning a virtual office accurately, legally, and sustainably from establishment through early operations.

XPND’s role includes the following:

  • Assessing the eligibility of using a virtual office based on the PT PMA’s business sector and KBLI, with a focus on service sectors that are still permitted to operate using virtual domiciles in Jakarta
  • Verifying virtual office zoning compliance under RDTR and Governor Regulation Number 31 of 2022 to ensure the address is located within an approved office sub zone and accepted by the OSS RBA system
  • Supporting PT PMA establishment by ensuring the virtual office address is lawfully recorded in the deed of establishment, NIB, Tax Identification Number (Nomor Pokok Wajib Pajak or NPWP), and related administrative systems connected to OSS and the Directorate General of Taxes
  • Aligning capital structure, investment realization, and LKPM reporting to prevent the use of a virtual office from being flagged as a passive or non operational entity
  • Designing a realistic transition strategy that positions the virtual office as an initial entry solution before moving to a physical office when business scale, KBLI changes, or PKP requirements demand it

Through this structured approach, XPND not only facilitates the formal establishment of PT PMA but also ensures that the use of a virtual office in Jakarta remains compliant with the regulatory direction for 2025 to 2026.

With proper guidance, a virtual office in Jakarta can serve as a legal and efficient solution for PT PMA during the early stages of business, provided it remains aligned with KBLI, tax obligations, and prevailing investment policies.