Introduction
In Part 1 of our How to Set Up a Company in Indonesia series, we outlined how to establish a foreign-owned company (PT PMA) — from capital requirements and OSS-RBA registration to obtaining your first business identification number (NIB).
Once your company is incorporated, the next step is determining what you are legally allowed to do. This means selecting the right KBLI (Indonesian Standard Business Classification) codes and obtaining the corresponding operational licences through the OSS-RBA system.
Choosing the wrong KBLI can delay your licensing, restrict foreign ownership, or even invalidate your permits.
In this guide, we unpack how KBLI codes work, how they link to Indonesia’s Positive Investment List (Presidential Regulation 10/2021), and how to secure the right licences for your sector — from consulting and real estate to hospitality and F&B.
By the end, you will understand how to align your company’s activities, ownership structure, and compliance obligations so that your PT PMA can operate legally and scale without disruption.
When you register a foreign-owned company (PT PMA) in Indonesia, your entire business structure, ownership rights, and licensing pathway depend on one critical choice — your KBLI (Klasifikasi Baku Lapangan Usaha Indonesia).
Each five-digit KBLI code defines your company’s official activity.It determines:
- Who can legally own the business (foreign vs. local).
- What licences or ministry approvals are required.
- Whether your company is considered low, medium, or high risk under Indonesia’s OSS-RBA (Risk-Based Licensing) system.
Choosing the wrong KBLI can delay your incorporation, block OSS approval, or prevent you from operating legally. This 2026 guide explains how to choose the right KBLI for your PT PMA — with examples from real estate, hospitality, F&B, and professional services, the sectors where SatuSolusi specialises.
1. Understanding the KBLI System
The KBLI is Indonesia’s national business classification system, similar to NAICS or SIC codes in other jurisdictions. It links together three key frameworks:
Framework | Purpose | Managed By |
Positive Investment List | Determines foreign ownership eligibility | BKPM (Investment Coordinating Board) |
OSS-RBA Risk Classification | Determines what licences you need | OSS / BKPM |
Supervising Ministry | Issues specific sectoral permits | e.g., Tourism, PUPR, Trade, Environment |
When you register a PT PMA, you’ll select at least one main KBLI (primary business) and may add secondary KBLIs for additional services.
2. The Positive Investment List (Presidential Regulation No. 10/2021)
Indonesia’s Positive Investment List replaced the old “Negative List” in 2021. It identifies which business activities are open to foreign investors and under what terms.
There are four key categories:
Category | Description | Impact on PT PMA Setup |
Open to Foreign Investment | 100 % ownership allowed | Full control and repatriation rights |
Partially Open | Foreign ownership capped (e.g., 49 %, 67 %) | Requires local partner |
Closed to Foreign Investment | Reserved for domestic/cooperative entities | Cannot operate under PT PMA |
Priority Sector | Eligible for incentives (tax holidays, import duty relief) | Strategic industries only |
A. Fully Open Sectors (Common PT PMA Options)
Sector | KBLI | Activity Description | Ownership | Risk Category | Key Licence |
Real Estate Development / Leasing | 68111 / 68200 | Owning, leasing, or managing real estate | 100 % | Medium–High | NIB + Environmental + TDUP (if short-term) |
Hospitality / Villas / Resorts | 55900 | Short-term accommodation (villas, hotels, resorts) | 100 % | Medium Verified | NIB + TDUP + NPWPD |
Restaurants / Cafés | 56101 | Restaurant and dining operations | 100 % | Medium Verified | NIB + TDUP + Halal + Health Certificates |
Consulting / Advisory | 70209 | Management consulting services | 100 % | Low Risk | NIB only (no sectoral licence) |
B. Partially Open Sectors (Ownership Capped)
Sector | KBLI | Description | Ownership Limit | Required Partner / Licence |
Construction Services | 41011 | General building construction | 67 % | Local partner + PUPR licence (IUJK) |
Cargo & Freight Forwarding | 52292 | Domestic freight transport support | 49 % | Local partner + Transportation Ministry permit |
Example 1:
A construction company under KBLI 41011 may be up to 67 % foreign-owned. It must obtain a Construction Business Licence (IUJK) and employ qualified personnel certified by the Ministry of Public Works and Housing (PUPR).
Example 2:
A logistics firm under KBLI 52292 can hold 49 % foreign ownership, ensuring Indonesian control in domestic cargo transport.
C. Closed Sectors (Foreign Ownership Not Allowed)
Sector | KBLI | Description | Ownership | Reason |
Traditional Retail Trade | 47111 | Retail sale in non-specialised stores (warungs, minimarts) | 0 % | Reserved for micro and cooperative enterprises |
Groundwater Extraction / Utilities | 36001 | Collection and distribution of groundwater | 0 % | Restricted for environmental sustainability |
Example 1:
Foreign investors cannot operate convenience stores or small supermarkets under KBLI 47111 — these are reserved for domestic SMEs.
Example 2:
Groundwater extraction (36001) is fully closed to foreign entities to protect natural resources and local supply.
3. OSS-RBA Risk Categories and Licence Requirements
Under the Risk-Based Licensing (OSS-RBA) framework, every KBLI is assigned a risk category that dictates what documents are required after incorporation.
Risk Category | Description | Required Licences | Example KBLI |
Low Risk | Minimal impact on safety/environment | NIB only | 70209 (Consulting) |
Medium Risk (Self-Declared) | Moderate risk; self-assessed | NIB + Standard Certificate (Self-Declared) | 68200 (Property Leasing) |
Medium Risk (Verified) | Moderate risk requiring verification | NIB + Verified Standard Certificate | 56101 (Restaurant), 55900 (Villa/Hotel) |
High Risk | Significant environmental/safety impact | NIB + Standard Certificate + Business Licence/Environmental Permit | 68111 (Property Development), 41011 (Construction) |
Examples of Common Sectoral Permits
- TDUP (Tourism Licence): Hotels, villas, resorts, restaurants.
- SPPL / UKL-UPL (Environmental Approval): Required for property development and construction.
- Halal Certification: Mandatory for F&B products from 2024–2026.
- IUJK (Construction Licence): Required for contracting and engineering work.
- NPWPD (Local Tax ID): Required for all entities with physical operations (for PBJT/PHR filing).
4. How the Positive List and OSS Risk Category Interact
The Positive List governs who can invest, while OSS-RBA governs how you operate.
Example | Ownership Status | Risk Level | Required Licences |
Villa Operator (55900 + 68200) | 100 % foreign | Medium Verified | NIB + TDUP + NPWPD |
Real Estate Developer (68111) | 100 % foreign | High | NIB + Environmental + Building Licence (SLF) |
Construction Contractor (41011) | 67 % foreign (joint venture) | High | NIB + IUJK + SBU (PUPR) |
Retail Minimart (47111) | 0 % (closed) | — | Not eligible for PT PMA |
Pro Tip:
Always review both frameworks together before finalising your KBLI — ownership eligibility doesn’t guarantee operational clearance.
5. Common KBLI Bundles for Foreign Investors
Foreign investors often combine multiple KBLI codes within one PT PMA to cover ownership, operations, and management.
Business Model | Common KBLI Bundle | Ownership | Key Licences |
Villa Operator (Own & Manage Property) | 68111 (Real Estate) + 68200 (Management) + 55900 (Accommodation) | 100 % | TDUP, NPWPD, SPPL/UKL-UPL |
Hospitality Group (F&B + Accommodation) | 55900 (Villas) + 56101 (Restaurants) | 100 % | TDUP + Halal Certificates |
Real Estate Developer | 68111 (Property) + 41011 (Construction) | 67 % | PUPR, Environmental Permits |
Consulting & Advisory Firm | 70209 | 100 % | NIB only |
Mixed-Use Project (Property + Café + Events) | 68111 + 56101 + 82302 (Event Organisation) | 100 % | TDUP + Local Government Registration |
|Pro Tip:
If your business spans multiple KBLI categories, structure your group with one PT PMA for holding and separate entities for operations. This reduces licence conflict and improves clarity during BKPM audits.
6. Common Mistakes in KBLI Selection
- Registering a KBLI that doesn’t match your real operations.
- Selecting partially open KBLI without a local partner
- Forgetting to align KBLI codes between Notarial Deed and OSS form.
- Underestimating the licensing requirements for medium/high-risk KBLIs.
- Using a virtual office in an unapproved zoning area (OSS rejection).
Pro Tip:
Always run a KBLI Feasibility Review before incorporation to confirm your codes, ownership, and risk classification.
7. How to Choose the Right KBLI (Decision Framework)
Follow this simple three-step method before you finalise your KBLI:
Step | Question | Why It Matters | Example |
1. Define your core income stream | What are you billing for? | Determines main KBLI | Management fees → 68200 |
2. Identify operational activities | Will you manage physical assets or only lease them? | Changes risk level | Owning land (68111) = high risk |
3. Check secondary services | Are you offering accommodation or F&B? | May add sectoral licences | Villas + café → add 56101 |
Pro Tip:
Split capital-intensive and service-based activities between two entities.
For example, a holding PT PMA under 68111 + 68200, and an operations PT PMA under 55900 + 56101.
8. KBLI Compliance Checklist
Before you submit your company incorporation through OSS-RBA, make sure you’ve:
- Defined your core and secondary business activities.
- Verified foreign ownership eligibility under the Positive Investment List.
- Checked OSS-RBA risk category and licensing requirements.
- Prepared an investment plan ≥ IDR 10 billion per KBLI per location.
- Matched KBLI codes in the Notarial Deed and OSS submission.
- Confirmed your business address meets zoning (domicile certificate).
- Registered NPWPD at the local Bapenda office if operating physically.
Once ready, schedule a KBLI Feasibility Review Call with SatuSolusi to finalise your codes and documentation.
9. Regulatory References
- Presidential Regulation No. 10/2021 – Positive Investment List
- Government Regulation No. 5/2021 – Risk-Based Licensing (OSS-RBA)
- BKPM Regulation No. 4/2021 – Licensing Implementation
- BPS KBLI 2020 Revision – Latest KBLI classification standard
10. Speak with a SatuSolusi Advisor
Your KBLI codes define the scope, ownership, and compliance life cycle of your business in Indonesia.
At SatuSolusi Consultancy, we help you structure your PT PMA correctly from day one — ensuring full alignment between ownership, KBLI classification, and risk-based licensing.
Our services include:
- KBLI and Positive List analysis
- OSS-RBA registration and NIB issuance
- TDUP and sectoral permit processing
- NPWPD, BPJS, and local compliance setup
Conclusion
Selecting the right KBLI codes and securing the correct licences ensures your PT PMA operates within Indonesia’s legal framework from day one. It aligns your business activities, ownership structure, and compliance obligations so your company can grow without disruption.
If you haven’t yet read Part 1 – How to Open a Foreign-Owned Company (PT PMA) in Indonesia – 2026 Guide, start there to understand the incorporation and OSS-RBA registration process.
In Part 3 – Indonesia HR Compliance Guide – Employment Contracts, Payroll & BPJS (2026 Edition), we move from business licensing to day-to-day operations — explaining how to build a compliant HR foundation covering employment contracts, payroll tax, and BPJS registration.
Together, these three parts form a complete roadmap for establishing, licensing, and operating your business successfully in Indonesia.
Need help figuring out which KBLI code to use? Contact us today for a free discovery call.