KBLI 2025 and OSS Updates: What Foreign Investors in Indonesia Need to Know

Indonesia’s business licensing system continues to evolve. One of the most important recent developments is the implementation of KBLI 2025 within the Online Single Submission Risk-Based Approach system, commonly known as OSS RBA.

For foreign investors planning to establish a PT PMA, these changes are important because the selected KBLI code determines the company’s permitted business activities, risk classification, licensing requirements and, in certain sectors, eligibility for foreign ownership.

This article explains the most relevant developments involving KBLI 2025, OSS RBA, NIB, AHU and Coretax—and what foreign investors should consider before starting or modifying a business in Indonesia.

Important: Obtaining an NIB does not always mean that a company has fulfilled every licensing requirement. Additional certificates, approvals or sector-specific licences may still be required.

1. KBLI 2025 Is Being Implemented in the OSS System

KBLI, or the Indonesian Standard Industrial Classification, is the official system used to classify business activities in Indonesia.

The selected KBLI code is used by government systems to determine:

• The company’s permitted business activities
• Whether foreign investment is allowed
• The applicable business risk level
• The required business licences
• Whether a Standard Certificate is required
• Applicable sector-specific requirements
• Environmental and spatial-planning obligations
• The government authority responsible for supervision

The OSS system now provides an official process for converting KBLI 2020 codes into KBLI 2025 codes.

However, the conversion is not always a simple replacement. Depending on the business activity, a KBLI code may:

• Remain unchanged
• Receive a revised title or description
• Be replaced by another code
• Be divided into multiple new codes
• Be merged with another business classification

For example, according to the official OSS conversion table, KBLI codes 01118 and 01119 under KBLI 2020 are merged into KBLI 01118 under KBLI 2025.

Foreign investors and existing PT PMA companies should therefore avoid assuming that an old KBLI code remains suitable without checking the official conversion.

Official reference: KBLI 2020 to KBLI 2025 Conversion Table

2. How KBLI 2025 Affects a PT PMA

For a PT PMA, selecting the correct KBLI code is especially important.

A KBLI code affects more than the wording included in the company’s deed of establishment. It can influence:

Area	Possible impact
Foreign ownership	Some activities may be restricted, conditional or reserved
Investment requirements	The planned investment must correspond to the company’s activities
Business scale	Certain activities may require a particular business scale
Risk classification	Determines whether an NIB alone is sufficient
Standard Certificate	May require a verified or unverified certificate
Sectoral licence	Additional approval may be required from a technical ministry
Business location	Spatial and zoning requirements may apply
Environmental approval	Environmental documents may be required
Operational readiness	Commercial activities may only begin after specific requirements are fulfilled

Investors should select a KBLI code based on the company’s actual commercial activities—not merely because the code appears convenient or broadly worded.

Using an unsuitable KBLI may create problems when the company:

• Opens a corporate bank account
• Applies for an operational licence
• Imports or distributes products
• Employs foreign workers
• Signs commercial contracts
• Participates in tenders
• Applies for sector-specific approvals
• Updates its OSS business data

3. Existing Companies May Need to Review Their KBLI Codes

Existing companies should determine whether their current KBLI 2020 codes remain appropriate under KBLI 2025.

This does not necessarily mean that every company must immediately change its deed or NIB. The required action depends on the official conversion result, the company’s actual activities and how the relevant code is implemented in OSS.

A practical review should include:

1. Checking every KBLI code listed in the deed of establishment or latest amendment.
2. Comparing those codes with the company’s OSS and NIB records.
3. Reviewing the official KBLI 2020–2025 conversion.
4. Identifying codes that were merged, divided or substantially revised.
5. Confirming the foreign-ownership position for each activity.
6. Checking whether the risk level or licensing requirements have changed.
7. Determining whether an amendment to the deed is required.
8. Updating OSS data only after the legal documents and business plan have been reviewed.

Companies planning to add a new business activity should use KBLI 2025 rather than simply copying a code from an older corporate document.

4. OSS Provides a Transition Process for Certain Existing Projects

Indonesia’s OSS platform also provides a transition mechanism related to the implementation of Government Regulation No. 28 of 2025 on Risk-Based Business Licensing.

The transition process may apply to business projects created before the implementation date of 5 October 2025, particularly where spatial-planning requirements had already been issued but the business-licensing process had not been completed.

This is important because an unfinished legacy project may need to be continued through the transition process instead of being submitted as an entirely new application.

Before processing an old or incomplete OSS project, the company should review:

• The date on which the project was created
• The status of its spatial-planning approval
• The status of its Standard Certificate or business licence
• Whether the project is still visible in the OSS account
• Whether the system provides a legacy-data or transition option
• Whether the KBLI must first be converted to KBLI 2025

Official reference: OSS Transition Guide for Government Regulation No. 28 of 2025

5. An NIB May Not Be the Final Business Licence

An NIB, or Business Identification Number, is the official identity of a business operating in Indonesia.

However, the NIB is only one component of Indonesia’s risk-based licensing framework.

The company’s obligations depend on its risk classification:

Risk level	General licensing outcome
Low risk	NIB
Medium-low risk	NIB and Standard Certificate
Medium-high risk	NIB and verified Standard Certificate
High risk	NIB and business licence or government approval

Additional sector-specific requirements may also apply.

Consequently, a company should not begin commercial operations solely because an NIB has been issued. The company must first confirm that all licences, certificates and operational requirements connected to its business activity have been fulfilled.

Official reference: OSS Risk-Based Business Licensing System

6. AHU, Beneficial Ownership and Corporate Data

The establishment and amendment of an Indonesian limited liability company are processed through the Ministry of Law’s Legal Entity Administration System, known as AHU or SABH.

For a limited liability company, the relevant process may include:

• Company-name reservation
• Deed of establishment
• Approval as a legal entity
• Amendment of the articles of association
• Changes to directors and commissioners
• Changes to shareholders
• Changes to authorised, issued or paid-up capital
• Beneficial ownership information

The AHU service requirements include the submission of beneficial ownership information. For certain corporate amendments, the notary must also verify the validity of the company’s tax identification information.

Official reference: AHU Limited Liability Company Services

Foreign investors should ensure that the information recorded in the deed, AHU, OSS and tax system is consistent.

Common inconsistencies include:

• Different company addresses
• Incorrect passport or identity information
• Different shareholder compositions
• Outdated directors or commissioners
• Inconsistent capital information
• Business activities appearing in the deed but not in OSS
• Differences between AHU records and the NIB

These inconsistencies can delay future amendments, licence applications, tax administration and banking procedures.

7. Coretax Registration Should Be Treated as a Separate Completion Step

After the company has been established, its tax administration must also be properly completed.

The issuance of a corporate tax identification number does not always mean that the company’s Coretax account is fully activated and ready for use.

A proper tax-account handover should confirm:

• The company’s registered email address
• The registered mobile number
• The identity of the responsible person
• Access to the Coretax account
• Successful password management
• Correct company and management information
• Availability of the relevant electronic tax services

The registered email address and telephone number should remain under the company’s control. Investors should avoid allowing these credentials to remain permanently controlled by an unrelated third party.

8. Recommended Actions for Foreign Investors

Foreign investors establishing or managing a company in Indonesia should consider the following steps:

For a new PT PMA

• Define the actual business model and revenue activities.
• Select the appropriate KBLI 2025 codes.
• Verify whether each activity is open to foreign investment.
• Check the required investment scale and capital structure.
• Review the proposed business location.
• Identify the applicable risk classification.
• Determine whether additional sectoral licences are required.
• Align the deed, AHU registration, OSS data and tax registration.

For an existing PT PMA

• Review all current KBLI codes.
• Use the official OSS conversion table.
• Identify codes that were merged, divided or changed.
• Check unfinished OSS projects and transition eligibility.
• Reconcile the company’s AHU, OSS and Coretax information.
• Review whether the company holds all required Standard Certificates and operational licences.
• Amend corporate documents where legally necessary.

Conclusion

The implementation of KBLI 2025 is more than an administrative change. It can affect a company’s foreign-ownership eligibility, risk classification, licensing obligations and ability to operate legally in Indonesia.

Foreign investors should avoid selecting KBLI codes solely from a list or copying them from another company. Every code should be reviewed against the company’s actual activities, investment structure, location and sector-specific requirements.

A properly structured PT PMA should maintain consistent information across its deed, AHU records, OSS account, NIB and Coretax registration.

If you are planning to establish a PT PMA in Bali or elsewhere in Indonesia—or need to review an existing company’s KBLI and licensing status—professional assistance can help prevent incorrect classifications and unnecessary licensing delays.

Need Assistance Establishing or Updating a PT PMA?

PMA in Bali assists foreign investors with:

• PT PMA establishment
• KBLI 2025 consultation
• Deed and AHU registration
• OSS and NIB processing
• Standard Certificate applications
• Corporate amendments
• Business-licensing reviews
• Corporate tax and Coretax account assistance

Contact our team through WhatsApp to discuss your planned business activities and licensing requirements.

Legal notice: This article provides general information only and does not constitute legal, tax or investment advice. Requirements may vary depending on the company’s activities, ownership structure, location and responsible government authority.