A PT PMA can add or change its KBLI after incorporation, but the process depends on whether the company is simply being converted to the corresponding KBLI 2025 code or is changing its actual business activities. An actual change in business activity may require amendments to the company’s corporate documents and OSS registration before the new activity can be conducted.
Does the KBLI 2025 Conversion Require a Company Amendment?
Indonesia implemented KBLI 2025 in the OSS and Ministry of Law’s AHU systems in 2026. Existing business licenses issued before the implementation of KBLI 2025 remain valid.
Before adding a new business activity, have MAP Resources Indonesia check the proposed KBLI and amendment requirements: info@mapresourcesindonesia.com
Where an existing activity only requires conversion to a new numerical KBLI 2025 code without changing the substance of the business activity, OSS and AHU can adjust the code automatically. If the company changes its business purposes or activities, its Articles of Association may need to be amended through notarial documentation and the Ministry of Law/AHU process before the new activity is reflected in OSS.
Will the New KBLI Require Different Business Licenses?
A company’s KBLI is connected to its Business Identification Number (NIB) and licensing information in OSS. The licenses required for a business activity depend on its classification under Indonesia’s risk-based licensing framework.
Depending on the activity, an NIB may be sufficient, or the company may need additional licenses, certificates, standards, or sector approvals.
Does Adding a KBLI Change the PT PMA’s Investment Requirement?
Under the current foreign investment rules, a PT PMA generally requires total investment of more than IDR 10 billion, excluding land and buildings, per five-digit KBLI business field per project location. Different calculation rules apply to certain activities, including wholesale trade, food and beverage services, construction, and manufacturing activities involving multiple products within one production line.
This investment requirement is separate from the company’s paid-up capital requirement. Adding a KBLI can increase the investment the company must commit to its Indonesian operations without requiring an equivalent increase in paid-up capital. The financial effect of an expansion can consequently extend beyond the cost of amending the company’s corporate and licensing records.
Can the Existing Foreign Ownership Structure Be Used?
A newly added business activity may be subject to foreign ownership restrictions that did not apply to the company’s existing activities.
MAP Resources Indonesia can check whether the proposed activity is compatible with your current foreign ownership structure. Email info@mapresourcesindonesia.com
If the activity is open to 100% foreign ownership, the existing shareholder structure may remain compatible. Where foreign ownership is restricted under Indonesia’s investment rules or sector-specific regulations, the company must determine whether its current shareholding satisfies those requirements before adding the activity.
Can the Company Start the New Activity Before the KBLI Amendment Is Complete?
A company should not conduct a new business activity requiring an updated or additional business license until the licensing requirements for that activity have been satisfied. Where additional approvals are required, this can delay the start of the new activity even after the corporate amendment or OSS update has been completed.
The required approvals depend on the activity’s risk classification and any sector-specific requirements. Updating the Articles of Association or adding the KBLI in OSS is not a substitute for obtaining a license or other approval required before the activity can begin.
What Happens to LKPM Reporting After the KBLI Changes?
A PT PMA generally reports its investment realization through the Investment Activity Report (LKPM) based on the investment activities and projects registered through OSS.
Already operating under a business scope that needs updating? Email MAP Resources Indonesia at info@mapresourcesindonesia.com
Adding a business activity can change the investment projects against which the company reports its investment realization. Its subsequent LKPM reporting should reflect the activities and investment being implemented under the updated OSS registration.
When Is a Separate PT PMA Better Than Adding the KBLI?
A separate entity may be required where the new activity has foreign ownership requirements that are incompatible with the existing shareholding or cannot otherwise be conducted through the existing PT PMA. A separate entity may also be considered where activities are subject to materially different licensing regimes.
Change or Add a KBLI with MAP Resources Indonesia
MAP Resources Indonesia can assess whether a new business activity can be added to an existing PT PMA and handle the required corporate and licensing amendments. Contact MAP Resources Indonesia at info@mapresourcesindonesia.com to review your proposed KBLI change.
