KBLI 2026 Complete Guide for Foreign Investors in Indonesia

Every business decision a foreign investor makes in Indonesia connects back to one five-digit number. The Indonesian Standard Industrial Classification (Klasifikasi Baku Lapangan Usaha Indonesia or KBLI) code assigned to a company at incorporation is not administrative housekeeping. It is the foundation on which every license, every permit, every immigration application, and every compliance obligation is built. Get it right and the rest of the regulatory framework falls into place. Get it wrong and the consequences compound quietly until they surface at the worst possible moment.

This guide is written specifically for foreign investors operating or planning to operate through a Foreign Investment Company (Perseroan Terbatas Penanaman Modal Asing or PT PMA). It covers what KBLI codes actually do, how the 2025 update changes the landscape, which sectors are open to full foreign ownership, which carry conditions, what the transition deadline means for existing companies, and how KBLI selection intersects with immigration, tax, and compliance obligations. This is not a guide about how to look up a code. It is a guide about how to think about KBLI selection as a strategic decision.

What KBLI Actually Does and Why It Matters More for PT PMA Than for Domestic Companies

For a domestic Indonesian company, an incorrect KBLI code is an administrative inconvenience. For a PT PMA, it is a compliance event with cascading consequences across multiple regulatory systems simultaneously.

The KBLI code determines four things for a PT PMA in ways that do not apply to domestic entities in the same way.

First, it determines whether a foreign investor can own the business at all. Indonesia’s Positive Investment List (Daftar Prioritas Investasi or DPI), established under Presidential Regulation (Peraturan Presiden or Perpres) No. 10 of 2021 as amended by Perpres No. 49 of 2021, assigns foreign ownership restrictions at the KBLI level. Some five-digit codes are fully open to 100% foreign ownership. Some carry ownership caps of 49%, 67%, or other thresholds. Some are reserved exclusively for domestic enterprises or micro, small, and medium enterprises (Usaha Mikro Kecil dan Menengah or UMKM). A PT PMA registered under a code that is reserved for domestic ownership is in fundamental violation of the investment framework, regardless of any other compliance it has achieved.

Second, it determines the minimum investment threshold that applies. Under Minister of Investment and Downstream Industry Regulation (Peraturan Menteri Investasi dan Hilirisasi or Permen Invest) No. 5 of 2025, the standard minimum total investment for a PT PMA is more than IDR 10 billion per five-digit KBLI code per project location. Exceptions apply to specific sectors including wholesale trade, food and beverage at the city or regency level, construction services, and certain multi-product manufacturing lines. Selecting multiple KBLI codes, which is permissible, multiplies the investment threshold accordingly.

Third, it determines the risk classification that governs regulatory oversight intensity. Under the Online Single Submission Risk-Based Approach (Sistem OSS Berbasis Risiko or OSS RBA), every KBLI code carries a risk classification of low, medium-low, medium-high, or high. The risk classification determines which business licenses are required, what level of documentation must be submitted, and how frequently the company is subject to government supervision. A PT PMA operating under a low-risk KBLI code faces less documentation burden at the time of registration but also receives less regulatory protection in enforcement proceedings. A company whose actual activities are riskier than its registered KBLI code is exposed to enforcement for operating outside its licensed scope.

Fourth, it determines the Investor KITAS eligibility pathway for foreign shareholders. The Investor Temporary Stay Permit (Kartu Izin Tinggal Terbatas or KITAS) under index E28A requires that the foreign national’s individual shareholding value meet the IDR 10 billion threshold. This threshold is assessed against the value of the company, which is in turn linked to the investment commitment made under the registered KBLI codes. A PT PMA with a single KBLI code and a total investment value of IDR 10 billion can support one Investor KITAS for a shareholder holding 100% of shares. A company with multiple codes at IDR 10 billion each has a proportionally higher investment base, which may support higher individual shareholding valuations.

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The KBLI 2025 Update: What Changed and What the June 2026 Deadline Means

Statistics Indonesia (Badan Pusat Statistik or BPS) published the updated Indonesian Standard Industrial Classification under BPS Regulation (Peraturan BPS) No. 7 of 2025, effective 18 December 2025. The transition period for existing companies runs until 18 June 2026. After that date, KBLI 2020 codes cannot be used for new license applications or OSS data amendments.

The 2025 update is not a simple renumbering exercise. The practical changes that affect foreign investors are concentrated in five areas.

Code consolidation

Several KBLI 2020 codes have been merged into single broader classifications in KBLI 2025. A company that had two separate KBLI codes under the 2020 system may find that those activities now fall under one code in 2025. Where this consolidation changes the risk classification of the merged code, the company’s compliance obligations change accordingly.

Risk reclassification

A number of codes have moved between risk categories in the 2025 update. Some activities that were previously classified as low-risk have been reclassified as medium-low. This affects the documentation requirements and oversight intensity for companies operating under those codes.

New sector-specific codes

The digital economy, renewable energy, and creative industry sectors gained more granular five-digit classifications in KBLI 2025. For PT PMA entities in technology, digital services, or clean energy, the 2025 update introduces codes that more accurately reflect their activities than the 2020 categories did.

Supporting KBLI revenue trigger

Under Permen Invest No. 5 of 2025, a supporting KBLI code must be elevated to a primary classification and included in the Articles of Association (Anggaran Dasar or AoA) once it generates income or profit for the company. If such activities exist, the company must convene a General Meeting of Shareholders (Rapat Umum Pemegang Saham or RUPS) to amend its AoA and meet the IDR 10 billion investment requirement for the newly primary code. This applies from the date the regulation came into force, not from the date the company discovers the obligation.

Transition procedure for existing companies

A PT PMA that incorporated under KBLI 2020 codes must verify whether its codes have a direct equivalent in KBLI 2025. Where the equivalent code is available and the risk classification is unchanged, the transition can be completed through the OSS system without amending the AoA. Where the transition requires a substantive change to the registered activities or risk classification, an AoA amendment through notarization and submission to the Legal Entity Administration System (Sistem Administrasi Badan Hukum or SABH) is required. The SABH submission deadline under Minister of Law Regulation (Peraturan Menteri Hukum or Permenkum) No. 49 of 2025 applies: 30 days from the notarial deed recording RUPS approval.

How to Read the Positive Investment List for Your KBLI

The Positive Investment List (Daftar Prioritas Investasi or DPI) under Perpres No. 10 of 2021 is the primary document foreign investors should consult when evaluating KBLI selection. The DPI replaced the Negative Investment List (Daftar Negatif Investasi or DNI) and inverted the logic: instead of listing what is prohibited, it specifies what is permitted with conditions, with everything else being fully open by default.

The DPI organizes business activities into three categories.

Open to 100% foreign ownership

Activities not listed in the DPI’s restricted or conditional categories are open to 100% foreign ownership under the positive investment list framework. This includes most manufacturing sectors, technology services, wholesale trade, professional services, logistics, and a wide range of industrial and commercial activities. For a PT PMA in these sectors, KBLI selection is primarily a question of accuracy and risk classification, not foreign ownership restriction.

Open with conditions

The DPI lists specific KBLI codes that are open to foreign investment but subject to conditions including maximum foreign ownership percentages, requirements for partnership with domestic entities, location-based restrictions, or specific investment thresholds. The conditions vary by code and must be checked at the five-digit KBLI level, not at the sector or category level. Two codes within the same industry sector may carry different conditions.

Reserved for UMKM or government

Certain codes are reserved exclusively for micro, small, and medium enterprises or for government-owned entities. PT PMA entities cannot operate under these codes. The most common source of enforcement action in Bali and other major investment destinations involves PT PMA entities that were incorporated or expanded into codes that are reserved for UMKM operators, often without realizing the restriction applied.

The DPI is accessible through the BKPM website and is incorporated into the OSS system. The system will flag a KBLI code as restricted when a PT PMA attempts to activate it, but this flag does not prevent the application from being submitted in all cases. The responsibility for verifying DPI compliance before incorporation remains with the applicant.

KBLI by Industry: Ownership Status for Key Foreign Investment Sectors

The following is a sector-by-sector overview of KBLI categories commonly used by PT PMA entities and their current foreign ownership status under the DPI framework.

Technology and Digital Services

Software development, IT consulting, data centers, and AI services are generally fully open to 100% foreign ownership. The E23Y Working KITAS is available specifically for foreign nationals in digital and technology roles. Specific codes under KBLI 62 and 63 cover the full range of digital economy activities. E-commerce platforms under KBLI 47911 are also fully open, though companies with significant domestic consumer reach may face additional regulatory considerations under Ministry of Communication and Digital regulations.

Manufacturing

Most manufacturing activities are fully open to 100% foreign ownership. The principal exceptions are in small-scale manufacturing and cottage industries that are reserved for UMKM operators. Large-scale manufacturing, industrial processing, and export-oriented production are among the most consistently open sectors in the DPI.

Tourism, Hospitality, and F&B

This sector carries the most complex KBLI landscape for foreign investors. Hotels and accommodation establishments with more than 100 rooms are generally open to 100% foreign ownership. F&B operations at scale, particularly those targeting tourists, are open but subject to the IDR 10 billion per city or regency investment threshold clarified in Permen Invest No. 5 of 2025. Small-scale restaurant and cafe operations under KBLI 56100 are subject to increasing scrutiny in Bali and other tourism destinations, as discussed in our article on Bali’s proposed KBLI closures.

Real Estate and Property Development

Large-scale residential and commercial real estate development is open to PT PMA with conditions including minimum land area thresholds and partnership requirements for affordable housing components. Small-scale villa development and residential rental operations under KBLI 68111 are under active scrutiny in Bali. Management of property on behalf of others carries different KBLI codes than ownership and development, and the distinction matters for compliance purposes.

Healthcare and Education

Healthcare facilities carry minimum investment thresholds set by the Ministry of Health that supersede the standard PT PMA capital requirements. Foreign ownership of hospitals and clinics is permitted with conditions. Private schools and educational institutions follow a separate framework under the Ministry of Education. Both sectors require sector-specific licenses in addition to the standard PT PMA Business Identification Number (Nomor Induk Berusaha or NIB).

Financial Services

Banking, insurance, securities, and fintech activities are governed by the Financial Services Authority (Otoritas Jasa Keuangan or OJK) framework, which sets its own capital adequacy and ownership requirements. The IDR 2.5 billion paid-up capital minimum for PT PMA is irrelevant in financial services because sectoral minimums are orders of magnitude higher. KBLI selection in this sector must be validated against both the DPI and the applicable OJK regulation.

Professional Services

Management consulting, legal advisory, accounting, and HR services are generally open to foreign ownership with conditions. The mandatory use of Indonesian professionals in certain licensed professions applies at the individual license level, not the corporate level. A PT PMA in professional services can hold foreign ownership but may need to engage Indonesian licensed professionals for regulated activities. Management consulting under KBLI 70209 has been closed to new PT PMA activation in Bali as of early 2026, though the closure is Bali-specific and not a national restriction.

KBLI and Your Immigration Obligations

KBLI selection directly affects two aspects of the immigration position of foreign nationals associated with the company.

Work permit eligibility for foreign employees

The Foreign Worker Utilization Plan (Rencana Penggunaan Tenaga Kerja Asing or RPTKA) that authorizes foreign workers to be employed under the E23 Working KITAS must be consistent with the company’s registered KBLI codes. A foreign worker in a role that does not correspond to the company’s registered business activities cannot be sponsored for an RPTKA. Companies that expand into new activities without updating their KBLI codes find themselves unable to sponsor work permits for the foreign specialists those activities require.

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Investor KITAS validity

The E28A Investor KITAS requires individual shareholding of IDR 10 billion. If a capital reduction or shareholder restructuring reduces the foreign investor’s individual share value below this threshold, the Investor KITAS becomes ineligible for renewal regardless of whether the company’s KBLI codes remain accurate. The connection between KBLI-driven investment valuation and immigration eligibility is not automatic, but the two are linked through the OSS system’s real-time shareholding validation that now applies to E28A renewal applications.

For companies managing multiple foreign nationals across different roles and permit types, a KBLI audit that identifies mismatches between registered activities and actual operations should include an assessment of whether the identified gaps affect the company’s ability to sponsor or renew the immigration permits of existing foreign staff.

The Bali Dimension: Geographic KBLI Restrictions

Bali is currently the clearest example of how KBLI selection in Indonesia now requires a geographic layer of analysis in addition to the national DPI framework. What is permitted for a PT PMA at the national level may not be activatable in a specific province, and Bali is where this dynamic is most advanced. This is a precedent that other provinces with high concentrations of foreign investment may follow. 

Since February 2026, KBLI selection for PT PMAs planning to operate in Bali carries an additional layer of complexity that does not exist in other provinces. The Bali DPMPTSP has submitted a proposal to the Ministry of Investment to close seven KBLI categories to foreign-owned companies. Of these, KBLI 70209 (management consulting) has been formally approved and closed. The remaining six categories are under national ministerial review. 

For investors targeting Bali, the KBLI selection process must include a check against the current Bali closure status in addition to the standard DPI ownership analysis and OSS risk classification. A code that is nationally open to foreign investment may not be activatable for a PT PMA in Bali depending on the outcome of the ministerial review.

The categories under review include real estate development (KBLI 68111), travel agency services (KBLI 79110), motorcycle and scooter rental (KBLI 77100), food and beverage operations (KBLI 56100 series), recreational activities including surfing schools and yoga studios (KBLI 93290), and fitness and wellness facilities (KBLI 93130). These categories should be treated as requiring direct verification with the Bali DPMPTSP or a licensed incorporation consultant before proceeding, as the status of each can change with ministerial approval at any point.

Alongside the KBLI closures, the Ministry of Investment has proposed a ban on PT PMA entities using virtual offices as official business addresses in Bali. For KBLI 70209 this restriction is already in effect. For new incorporations in Bali across all sectors, establishing a genuine operational address reduces exposure to the intensifying enforcement activity the DPMPTSP has signaled through 2026.

KBLI and Your Tax and Compliance Obligations

The relationship between KBLI codes and tax compliance operates through two mechanisms that are often overlooked at incorporation.

The first is the Business Field Classification (Klasifikasi Lapangan Usaha or KLU) used by the Directorate General of Taxes (Direktorat Jenderal Pajak or DJP) in the Coretax system. The KLU is derived from the KBLI code and is the reference point for corporate tax sector benchmarks. A mismatch between the KBLI registered in the OSS system and the KLU used in tax filings is a Coretax flag. Since January 2025, Coretax cross-references business licensing data, payroll records, VAT invoices, and tax filings in real time. A company whose OSS registration reflects a technology services KBLI but whose tax profile shows management consulting income will generate a data inconsistency that the system identifies without requiring a manual audit trigger.

The second mechanism is Value Added Tax (Pajak Pertambahan Nilai or PPN) treatment. PPN applicability and rate vary by business activity. The KBLI code is the reference point for determining which PPN treatment applies to a company’s transactions. Some KBLI sectors are PPN-exempt as specified under Article 4A of VAT Law No. 42 of 2009 (Undang-Undang Nomor 42 Tahun 2009 tentang Pajak Pertambahan Nilai), which covers certain healthcare services, educational services, and financial services among others. Selecting the wrong code can result in incorrect VAT reporting from the first invoice, which creates a gap between declared obligations and actual obligations that compounds over time. 

Additionally, the DJP uses KBLI codes as one input in its Compliance Risk Management (CRM) scoring within Coretax. Companies classified under higher-risk KBLI codes receive more intensive compliance monitoring. A company whose Coretax-reported revenue patterns are inconsistent with the economic profile expected for its KBLI classification may be flagged for closer scrutiny.

The Investment Activity Report (Laporan Kegiatan Penanaman Modal or LKPM) submitted quarterly to the Ministry of Investment must reflect investment realization consistent with the registered KBLI codes. Under BKPM Regulation No. 5 of 2025, the LKPM deadline is now the 15th of April, July, October, and January, updated from the previous 10th of those months. Reporting investment in activities outside the registered codes creates a discrepancy between LKPM declarations and OSS records.

For companies that have been operating under mismatched KBLI codes for an extended period, the retroactive compliance exposure from LKPM, tax, and OSS record inconsistencies is often the most significant practical consequence of a KBLI audit. Addressing these gaps proactively rather than reactively is almost always the lower-cost path.

The KBLI Selection Process for a New PT PMA

For investors at the pre-incorporation stage, the KBLI selection process should be structured around four sequential questions.

Is the intended activity permitted for foreign ownership? Check the DPI at the five-digit KBLI level before any other step. If the code is reserved for UMKM or carries ownership conditions that conflict with the intended structure, the business model needs to be reconsidered before incorporation begins.

What is the risk classification of the intended code? Verify the OSS RBA risk classification. This determines the documentation burden at registration and the oversight intensity post-incorporation. If the intended activity carries a high or medium-high risk classification, factor the additional documentation and licensing requirements into the incorporation timeline.

What is the investment threshold for the intended code? Confirm whether the standard IDR 10 billion per KBLI per location applies, or whether a sectoral exception modifies it. Plan the capital structure accordingly, taking into account the IDR 2.5 billion minimum paid-up capital under Permen Invest No. 5 of 2025 and the 12-month lock-up restriction on that capital.

Does the KBLI selection support the immigration structure? If any foreign shareholder will apply for an E28A Investor KITAS, confirm that the planned total investment value and individual shareholding structure meets the IDR 10 billion individual threshold. If foreign employees will be engaged under E23 Working KITAS permits, confirm that the intended roles fall within the scope of the registered KBLI codes.

For a complete walkthrough of the PT PMA incorporation process under the current regulatory framework, the PT PMA service page covers each stage of the process including KBLI selection, capital structure, and the compliance handover that ensures the company is operationally ready from day one.

How XPND Supports KBLI Selection and Compliance

XPND approaches KBLI selection as a strategic analysis, not an administrative task. For new PT PMA incorporations, XPND’s process begins with mapping the client’s intended business activities against the five-digit KBLI level, checking DPI compliance, confirming the risk classification, and assessing the investment and immigration implications before any OSS filing is made.

For existing PT PMA entities, XPND conducts KBLI compliance audits that identify mismatches between registered codes and actual revenue-generating activities, assess the transition requirements under KBLI 2025 before the 18 June 2026 deadline, and identify any supporting KBLI activities that have generated revenue and therefore require AoA amendment under Permen Invest No. 5 of 2025.

XPND’s services that directly intersect with KBLI compliance include PT PMA incorporation, business licensing, tax compliance, payroll management, corporate secretary, and regulatory compliance advisory.

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For investors who want to assess their current KBLI position or plan their KBLI selection for a new incorporation before the 18 June 2026 transition deadline, our team is available for a free initial consultation.