Client Alert · Foreign Direct Investment · Licensing · Prasetyo Law Office · Updated 14 August 2026
KBLI determines how a business activity is classified in OSS, but a change in the KBLI version does not by itself cause an existing NIB or business licence to lapse. The main risk is misalignment between the actual activity, the deed/AHU record, OSS data and the code used for a new application or data amendment.
1. How KBLI 2025 conversion works
The official OSS guidance distinguishes conversion by mapping pattern. Certain one-to-one or many-to-one mappings may be converted automatically. For a one-to-many mapping, the business may be required to select the appropriate KBLI 2025 code manually based on the activity actually conducted. Businesses should review the notifications and conversion results in their OSS accounts.
If the entity data still uses KBLI 2009 or 2017, the OSS guidance directs alignment through a notary and AHU Online, followed by a review through the Business Entity Amendment menu. A deed amendment is required only where the purposes, objectives or activities in the deed are no longer aligned with the code to be used.
2. What should not be assumed
Existing NIBs and business licences do not automatically lapse, become flagged, blocked or rejected solely because the KBLI version has changed. New applications and data amendments must follow the official OSS conversion process and the requirements applicable to the relevant activity. System outcomes depend on the data, application type, risk level and competent authority.
This article also does not assert a Bali-wide suspension of KBLI 70209 or any other code without an official written announcement from the competent authority. Any regional or sectoral condition should be supported by a legal basis applicable to the relevant activity and location.
3. Implications for a PT PMA structure
- Check whether the converted codes change the activities that must be reflected in the deed.
- Reassess business-field openness, risk level, basic requirements, Standard Certificates, Licences and PB UMKU.
- Calculate investment value under Article 26 of Minister of Investment/BKPM Regulation No. 5 of 2025 and its exceptions. A split of one old code into several new codes should not automatically be treated as multiplying the investment threshold without reviewing the activity, location and applicable calculation method.
- Align AHU, OSS/NIB, beneficial-ownership and LKPM records only to the extent each record is actually affected.
4. Issued and paid-up capital
Article 27 of Minister of Investment/BKPM Regulation No. 5 of 2025 is not an absolute 12-month prohibition on using the capital. The capital generally may not be moved from the company’s account for at least 12 months, except when used to purchase assets, construct buildings and/or fund the company’s operations as permitted by that article.
Practical steps
- Map every KBLI code in the deed, AHU, NIB, licences and LKPM.
- Match each code to the actual activity and the relevant KBLI 2025 mapping.
- Document the basis for a manual one-to-many selection.
- Amend the deed/AHU only where required, then align OSS and affected licences.
- Do not rely on claims of automatic system rejection or blocking without an official written basis.
Conclusion
KBLI migration is a data and licensing-alignment exercise, not a basis for assuming that all existing licences automatically become invalid. Each decision should follow the code mapping, actual activity, investment structure, location and sectoral requirements.
Primary sources: Official OSS KBLI 2025 conversion guidance; KBLI 2025; Minister of Investment/BKPM Regulation No. 5 of 2025, particularly Articles 26–27.
Disclaimer: This article provides general legal information and is not a legal opinion for a specific activity or licence.
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