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A Complete Legal Guide to the Business Classification Changes, the Migration Process, and the Implications for Foreign Investors in Indonesia
EXECUTIVE SUMMARY
Indonesia’s Standard Industrial Classification (Klasifikasi Baku Lapangan Usaha Indonesia / KBLI) 2025 has been fully effective in the OSS and AHU Online systems since 15 June 2026. The national adjustment deadline of 18 June 2026 has passed. All new applications and data changes must now use KBLI 2025 codes.
For foreign investors operating through a PT PMA, this change is not merely an administrative matter. The KBLI determines licensing, business risk level, compliance obligations, and even investment eligibility in certain sectors. A single wrong code can obstruct operations, block financing, or trigger sanctions.
This article provides a complete guide: what has changed from KBLI 2020, how the migration process works in OSS-RBA, the specific implications for PMA, and the common mistakes that must be avoided.
Every PT PMA in Indonesia has at least one five-digit KBLI code listed in its Articles of Association and registered in the OSS system. These five digits are not merely a statistical classification: they determine four things at once: the type of licences the company must hold, the business risk level in the eyes of the regulator, the compliance obligations that must be met, and whether the sector is open to foreign ownership.
When Statistics Indonesia (BPS) issued KBLI 2025 through BPS Regulation No. 7 of 2025, what happened was not merely an update to a list of codes. The classification structure changed: from 21 categories to 22, and from 1,789 five-digit codes to approximately 1,560. Hundreds of codes were split, merged, deleted, or had their scope redefined. And all of these changes are wired directly into the electronic licensing system that determines whether your business can operate lawfully or not.
For investors already operating, the question is simple: is your old KBLI code still valid, and what must be done if it is not? For new investors, the question is even more fundamental: how do you choose the right code from the outset so that it does not become a stumbling block later?
WHAT HAS CHANGED: KBLI 2020 VS KBLI 2025
KBLI 2025 is structured with reference to the International Standard Industrial Classification (ISIC) Revision 5, replacing KBLI 2020, which was based on ISIC Revision 4. This is not a cosmetic change. There is a fundamental restructuring that investors need to understand.
Structural Changes
The most striking change is the split of Category J. In KBLI 2020, Category J covered the entire Information and Communication sector. KBLI 2025 splits it into two: Category J for content and media, and a new Category K for telecommunications, information technology, and computing infrastructure. As a consequence, every category after J shifts by one letter: Finance moves from K to L, Real Estate from L to M, and so on.
Three Patterns of Code Changes
BPS identifies three main patterns in the Conversion Table released on 23 April 2026. Understanding these patterns is crucial, because each demands a different response from businesses:
One-to-one: one KBLI 2020 code maps directly to one KBLI 2025 code. This is the easiest pattern: migration is performed automatically by the system. Example: KBLI 70209 (Other Management Consultancy Activities) remains 70209 in KBLI 2025, although its scope has been expanded to include occupational health and safety (K3) consultancy and port security.
One-to-many: one code is split into several more specific codes. This is the riskiest pattern for businesses, because the system cannot determine the equivalent automatically, so the business must manually select the code that best matches its actual activities. If no selection is made, the NIB risks being flagged.
Many-to-one: several codes are merged into one new code. Migration is automatic by the system, but businesses need to verify that the scope of the merged code still covers the specific activities they carry out.
Important Note
BPS has not published the exact number of codes per pattern (how many are one-to-one, one-to-many, many-to-one, newly created, or deleted). The only figure available is the net reduction of approximately 230 five-digit codes. Claims of exact per-pattern figures from any source cannot be verified against official sources.
Examples of Code Changes Relevant to PMA
Several specific changes have a direct impact on foreign investors:
E-commerce and digital platforms: KBLI 63122 (Web Portals/Digital Platforms for Commercial Purposes) has been deleted. This was the code that had long served as a “safe harbour” for a wide range of digital business models. Platforms are now classified according to the sector they intermediate: marketplaces to 47901 (Retail Trade via Digital Platforms), healthtech to 86910, and so on. The implication: e-commerce players can no longer use a single generic code for every type of platform.
Real estate: the sector is now broken down more sharply between residential and non-residential, and between developers and managers. Investors engaged in property or villa management need to verify whether their code has shifted; market practice shows a move from 68111 to 68112 for property management.
Trade: Category G has been simplified. KBLI 2020 contained code 45 (trade in and repair of vehicles), 46 (wholesale trade), and 47 (retail trade). In KBLI 2025, vehicle repair has been moved to the services category, leaving only 46 and 47.
New technologies: new codes have been introduced for AI development, blockchain (62193), crypto-asset exchanges and brokers, podcasts, streaming, content creators, and carbon unit trading. This provides classification clarity for sectors that were previously “forced” into ill-fitting codes.
DEADLINE AND THE MIGRATION PROCESS: WHAT HAPPENS AFTER 18 JUNE 2026
Article 5 of BPS Regulation 7/2025 requires all KBLI users to adjust no later than six months after the regulation was promulgated, that is, by 18 June 2026. Technically, the OSS and AHU Online systems have been operating fully on KBLI 2025 since 15 June 2026, following system maintenance on 13–14 June. This means that all new applications, data changes, licence renewals, and reporting must now use KBLI 2025 codes.
How the Migration Process Works in OSS
The government issued Joint Circular Letter (Surat Edaran Bersama) No. 4.S/Tahun 2026 on 25 March 2026, signed by the Minister of Investment, the Minister of Law, and the Head of BPS, confirming three transition scenarios:
Companies already using KBLI 2025 codes require no conversion. Companies still using KBLI 2020 codes undergo conversion when they apply for a new licence or a data change: automatic for the one-to-one and many-to-one patterns, while for the one-to-many pattern the business must select manually. Applications that had already passed risk validation before 15 June 2026 continue to be processed under KBLI 2020.
WARNING: KBLI VERSIONS 2009 AND 2017
Companies still using KBLI version 2009 or 2017 face a more serious problem. The OSS and AHU systems do NOT support automatic conversion from these versions. Since 15 June 2026, deeds containing KBLI 2009/2017 codes trigger automatic rejection in OSS.
The step that must be taken: update the Articles of Association through a General Meeting of Shareholders (RUPS) and a notary using KBLI 2025 codes. Filings that still carry old KBLI codes can be flagged or blocked.
New licence applications, data changes, licence renewals, and LKPM reporting can be rejected by the system. Synchronisation with the company’s NPWP and tax business classification (KLU) may also be disrupted. In tender processes and third-party legality verification, banks and investors will question code mismatches.
SPECIFIC IMPLICATIONS FOR PT PMA
Investment Threshold and KBLI
The minimum PMA investment requirement remains in force: more than Rp10 billion per five-digit KBLI business field per business location, excluding the value of land and buildings. This requirement is set out in Government Regulation No. 28 of 2025 and maintained in Regulation of the Minister of Investment/Head of BKPM No. 5 of 2025.
What has changed: the minimum issued and paid-up capital for a PMA has been reduced from Rp10 billion to Rp2.5 billion per limited liability company under PerBKPM 5/2025, with a 12-month capital lock-in.
The direct implication for KBLI: because the Rp10 billion threshold attaches to the five-digit KBLI code, if one KBLI 2020 code is split into several KBLI 2025 codes, the investment calculation can change drastically. Two separate KBLI codes potentially require two times Rp10 billion, not one.
Interaction with the Investment Business Fields List (Perpres 49/2021)
The KBLI 2025 code changes do not automatically change the status of business fields under Presidential Regulation 49/2021 on the Investment Business Fields List. Business fields that are closed remain closed, and existing foreign-ownership restrictions continue to apply, regardless of code changes.
However, when a KBLI code is split or moved to a different category, the way a business field is “read” in the context of those restrictions can shift. This is particularly relevant when an investor applies for a new licence, adds KBLI codes or business locations, or when a company’s status changes from PMDN to PMA as a result of a foreign shareholder coming on board.
KBLI SELECTION GUIDE FOR FOREIGN INVESTORS
Selecting the right KBLI is not merely an administrative step; it is a strategic decision that affects regulatory compliance, operational flexibility, and the company’s ability to grow. Here are the five steps we recommend:
Step 1: Define the Core Economic Activity
Focus on the core source of revenue, namely the activities that directly create value and generate income. Do not base the identification on the company’s name or branding. A company named “ABC Digital” does not automatically fall under a technology code; what matters is what the company actually does to generate money.
Step 2: Map Supporting Activities
Identify additional services, production activities, self-managed distribution, or other business models that are run consistently. These activities can affect KBLI selection, and in a PMA context, every additional KBLI potentially requires fulfilment of its own Rp10 billion investment threshold.
Step 3: Evaluate the Description, Not Just the Code Title
Seemingly small differences in scope within KBLI descriptions often have significant consequences. Example: the differences among 70201 (Tourism Management Consultancy), 70202 (Industry), 70203 (Trade), and 70209 (Others) may look minor, but the licensing implications and risk level of each can be very different.
Step 4: Check PMA Restrictions
Before finalising your selection, verify it against Perpres 49/2021: is the code fully open to PMA, subject to ownership restrictions, or closed? Do not overlook regional restrictions, and note that even a single foreign shareholder, whether an individual, an entity, or a PMA, is enough to trigger PMA status with all of its obligations.
Step 5: Simulate in OSS-RBA
As a final validation step, run a simulation in the OSS system. Review the licensing, risk level, and compliance obligations generated by each KBLI alternative. This helps ensure that your KBLI selection is not only accurate for current conditions but also aligned with the business’s long-term needs.
COMMON MISTAKES AND HOW TO AVOID THEM
From our practice handling PMA clients, these are the mistakes that occur most frequently:
Choosing a “Catch-All” Code That No Longer Exists
KBLI 63122 used to be the default choice for almost every digital business. That code has been deleted. E-commerce players still registered under it must promptly select a replacement code based on the sector they actually intermediate.
Ignoring Description Changes Where the Number Stays the Same
Many businesses assume that if the code number has not changed, nothing needs to be done. This is mistaken. KBLI 2025 changes the scope and description of many codes without changing their numbers. A change in scope can change licensing obligations, even though the code number looks the same.
Splitting KBLI Codes to Avoid the Threshold
Some investors attempt to register several KBLI codes with the investment split among them in order to avoid the Rp10 billion threshold per code. This is risky: regulators are familiar with the practice, and Article 364 of Minister of Investment Regulation 5/2025 provides a sanction basis for companies that do not carry out genuine business preparation within one year of the NIB being issued.
Triggering Reclassification Unintentionally
Every amendment to the deed, change of directors or address, or addition of a KBLI code triggers a code review in the OSS system. This can be fatal: a change that appears routine can trigger an OSS block, even for low-risk codes. Resolve KBLI migration questions with legal advice first, before making any changes in OSS.
IMMEDIATE STEPS TO TAKE
Whether you are an investor already in operation or planning a new investment, here are the actions we recommend:
☐ Audit all KBLI codes in your NIB and Articles of Association, and match them against the BPS Conversion Table (released 23 April 2026)
☐ Identify the change pattern for each code (one-to-one / one-to-many / many-to-one / deleted)
☐ For one-to-many codes: select the KBLI 2025 code that best matches your actual business activities
☐ For codes from the 2009/2017 versions: update the Articles of Association through a RUPS and a notary using KBLI 2025 codes
☐ Check your quarterly LKPM status: make sure reports have been filed before the substance-based inspection window
☐ For PMA companies in Bali: avoid any deed or OSS data changes before consulting an advocate
☐ Verify your investment threshold: if a code has been split, recalculate compliance with the Rp10 billion requirement for each new code
If your company’s situation requires tailored analysis for KBLI selection, migration to KBLI 2025, resolving OSS obstacles, or restructuring PMA licensing, Prasetyo Law Office provides professional consultation.
Prasetyo Law Office is a law firm based in Jakarta, Indonesia, providing integrated legal services to clients across a wide range of areas, from commercial transactions to cross-sector litigation. With years of experience, we not only master the regulatory aspects but also understand the industry dynamics and business character of our clients. We provide comprehensive legal advice and strategic solutions to help clients minimise legal risk in every business challenge.
Should you require further information regarding this issue, please contact us:
Prasetyo Law Office
Infiniti Office, Indonesia Stock Exchange Building, Tower 1 Level 3 Suite 304, Sudirman Central Business District (SCBD), Jl. Jenderal Sudirman Kav. 52-53, Jakarta Selatan, DKI Jakarta, 12190
Phone : +6221 5890 5002 (ext. 105)
E-mail : info@prasetyolawoffice.com
Disclaimer: This article has been prepared by Prasetyo Law Office for educational and marketing purposes. None of its content is intended to constitute formal legal advice. Accordingly, Prasetyo Law Office is not responsible for any actions taken by any party who uses this article beyond its intended purpose.
