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How KBLI Choices Affect Licensing, Expansion, And Regulatory Risk in Indonesia

A company’s KBLI classifications determine which business activities it is registered to conduct in Indonesia and connect those activities to licensing, foreign-investment, and sector-specific requirements. For a foreign-owned company, adding a new product, service, or revenue stream can require regulatory changes if the activity falls under a different KBLI.

Indonesia now uses KBLI 2025, issued under BPS Regulation No. 7 of 2025, as the current classification framework for business activities.

How Does KBLI Determine Business Licensing?

Each registered business activity is identified through a KBLI classification. The activity is then connected through Indonesia’s OSS system to the licensing requirements that apply to that business.

Need to determine which KBLI applies to an Indonesian business activity? Contact MAP Resources Indonesia at info@mapresourcesindonesia.com

Indonesia’s current risk-based licensing framework is governed by Government Regulation No. 28 of 2025 on Risk-Based Business Licensing. Depending on the risk level, the required business licensing may consist of an NIB, an NIB together with a Standard Certificate, or an NIB together with the applicable business license, with additional sector-specific requirements where relevant.

Two commercially similar activities can have different licensing requirements depending on how they are classified.

Can One PT PMA Hold Multiple KBLI Codes?

A foreign-owned company can generally register multiple KBLI classifications where the activities are permitted for foreign investment and the company satisfies the requirements attached to each activity.

Each activity can carry its own risk classification, business licensing requirements, sector conditions, and foreign-investment rules. Existing licenses for one activity should not be assumed to cover another activity added to the same PT PMA.

What Happens When the Business Adds a New Activity?

A company that expands into an activity outside its existing KBLI classifications may need to add the relevant KBLI and satisfy the licensing requirements attached to it before conducting the new activity.

Adding a new business activity in Indonesia? MAP Resources Indonesia can assess the KBLI and licensing requirements. Email info@mapresourcesindonesia.com

Whether the expansion also requires an amendment to the company’s articles of association depends on whether the new activity is already covered by its stated purposes and business activities. If it is not, a corporate amendment may be required before the company’s OSS information and licensing can be updated.

Expanding an existing service within the same registered activity may not require the same changes as introducing a separate activity that falls under another KBLI.

Can a New KBLI Change Foreign Ownership Requirements?

Yes. Foreign-investment eligibility is assessed by business activity, so adding another KBLI can introduce different foreign ownership requirements.

A PT PMA whose original activity permits 100% foreign ownership cannot assume that every additional activity will permit the same ownership structure. The new activity may be subject to an ownership restriction, reserved for domestic businesses or qualifying MSMEs, or governed by separate sector rules.

Where the proposed activity is not available to the existing PT PMA, simply adding another KBLI does not remove the restriction. The investor must determine whether the activity can legally be conducted within another permitted structure or whether the proposed expansion needs to change.

When Does Expansion Require a Separate Company?

Operating several KBLI classifications does not automatically require separate companies. A single PT PMA can conduct multiple permitted activities where it satisfies the requirements applying to each one.

Unsure whether new activities can remain in your existing PT PMA? Contact MAP Resources Indonesia at info@mapresourcesindonesia.com

A separate entity may become relevant where sector-specific licensing or ownership rules make it impractical or legally impossible to conduct all proposed activities through the existing company. A separate PT PMA does not override restrictions that apply to foreign investment in the activity itself.

Does KBLI 2025 Require Existing Companies to Update Their Licenses?

Existing business licenses issued before the implementation of KBLI 2025 remain valid. Where the change only involves converting an existing KBLI 2020 code to its KBLI 2025 equivalent without changing the substance of the business, the adjustment can be processed automatically through the AHU and OSS systems without requiring an amendment to the company’s articles of association.

BPS has also published an official conversion table covering direct mappings, cases where one KBLI 2020 code is divided into several KBLI 2025 codes, and cases where multiple previous codes are combined into a new classification.

A company needs to adjust OSS or AHU where there is a substantive change to its purposes, objectives, or scope of business activities. The transition to KBLI 2025 does not by itself require every existing company to obtain new business licenses.

Align KBLI and Business Licensing with MAP Resources Indonesia

MAP Resources Indonesia advises foreign investors on matching their Indonesian business activities with the appropriate KBLI classifications and licensing requirements. Contact us today at info@mapresourcesindonesia.com.

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