The company must select the code matching its actual activity. A substantive change may require corporate and licensing amendments.
The introduction of KBLI 2025 has created understandable concern among foreign investors. Many companies are asking whether their existing licences remain valid. Others are considering immediate amendments to their NIB and Articles of Association.
The short answer is reassuring. A PT PMA does not automatically need new licences merely because KBLI 2025 exists. Existing licences generally remain valid during the transition. However, companies must review whether the new classification changes their registered business substance.
This distinction matters. A simple code conversion differs from a material change in business activities. The first may only require system adjustment. The second can require shareholder approval, a notarial deed, and government approval.
Therefore, companies should avoid rushed amendments. They should first compare their actual operations, corporate documents, NIB, and sectoral licences. A careful review can prevent unnecessary costs and future compliance problems.
KBLI means Klasifikasi Baku Lapangan Usaha Indonesia. It is Indonesia’s official classification of economic activities. Government authorities use it to identify and regulate business activities.
Statistics Indonesia issued KBLI 2025 through BPS Regulation Number 7 of 2025. The regulation replaced BPS Regulation Number 2 of 2020. It became effective following its promulgation on 18 December 2025.
KBLI 2025 responds to changing industries, digitalisation, environmental concerns, and new business models. It also aligns Indonesia’s classifications with international statistical standards. The classification now contains 22 categories and 1,560 five-digit business groups.
However, KBLI is not merely a statistical instrument. Each selected code can affect risk levels, licences, operational standards, and foreign ownership rules. Consequently, selecting a code requires legal and commercial analysis.
Every PT PMA must register business activities that accurately describe its intended operations. Those activities appear in its corporate documents and OSS business profile.
The selected code also influences the company’s licensing pathway. Under risk-based licensing, business activities receive low, medium, or high-risk classifications. Each level triggers different licensing requirements.
For example, a low-risk activity may require only an effective NIB. A medium-risk activity may also require a Standard Certificate. Meanwhile, a high-risk activity usually requires a business licence before commercial operations begin.
Government Regulation Number 28 of 2025 now provides the central framework for risk-based business licensing. It replaced the earlier framework under Government Regulation Number 5 of 2021. Therefore, an incorrect classification can affect whether the company may legally conduct its operations.
No. The government has confirmed that KBLI 2025 does not automatically require companies to obtain new licences.
A Joint Circular was issued by the Investment Ministry, Ministry of Law, and Statistics Indonesia. It addresses implementation within risk-based business licensing. Existing licences issued before implementation generally remain valid.
These licences may include an NIB, Business Licence, Standard Certificate, and PB UMKU. Therefore, their continued validity does not depend solely upon immediate code conversion.
The government confirmed this position in April 2026. It stated that businesses need not reapply merely because the classification changed.
Nevertheless, “still valid” does not mean “ignore the transition.” A company must assess its data before future corporate or licensing actions. Conversion may arise when the company updates, expands, or extends its activities.
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The correct answer depends on the conversion result and the company’s actual activities. Not every company needs an immediate substantive NIB amendment.
In general, an update becomes relevant when the company applies for a new activity. It may also arise during expansion, business-data updates, or licence extensions. OSS will then apply the corresponding KBLI 2025 classification.
For existing activities, the system may offer automatic conversion. However, some former codes correspond with several new codes. In that situation, management must identify the most accurate business scope.
The official OSS conversion guide covers new applications, existing activities, and extensions. It also distinguishes automatic and manual conversion processes.
Accordingly, KBLI 2025 for PT PMA should become a compliance review exercise. It should not become an automatic document-replacement project.
A one-to-one conversion occurs when one former code corresponds with one new code. This is usually the simplest transition.
The numerical code may change while the underlying activity remains substantially identical. The OSS system may automatically present or apply the corresponding new classification.
In this situation, the company should confirm the new title and description. It should also review the applicable risk level and licensing standards.
If the business substance remains unchanged, a corporate amendment may not be required. However, the conclusion depends on Article 3 of the company’s Articles of Association.
Directors should not assess only the five-digit number. They must compare the official descriptions and operational scope. A changed number can conceal an important change in coverage.
A one-to-many conversion occurs when one former code divides into several new classifications. This situation requires greater attention.
The old code may have covered several products, services, or operational methods. KBLI 2025 may now separate those activities into different codes.
The company must identify which new classification matches its current business. It must also consider planned activities within its corporate strategy.
Selecting every available code is not always prudent. Each code can create licensing obligations, investment commitments, and reporting requirements. An inactive code can also attract questions during supervision.
Moreover, choosing a new activity may alter the company’s registered purposes. If it changes the substantive scope, Article 3 may require amendment. The NIB and relevant licences would need coordinated updates.
A many-to-one conversion combines several former classifications into a broader or unified new code. This may simplify the company’s registered profile.
However, the company should examine whether the new description fully covers every existing operation. It should not assume broader wording provides automatic authority for every related activity.
The company must also check sectoral rules. A combined classification may contain separate scopes with different risk levels. Those scopes may require distinct supporting licences.
Consequently, directors should map each revenue-generating activity against the new description. Contracts, invoices, websites, and operational records can support that assessment.
This evidence-based approach is important. Regulators usually examine actual activities, not only corporate wording.
Not necessarily. A change from KBLI 2020 to KBLI 2025 does not automatically require a notarial amendment.
The decisive question concerns business substance. Does the new classification change the company’s purposes, objectives, or activities? If not, a technical conversion may be sufficient.
Article 15 of Indonesia’s Company Law requires the Articles of Association to contain corporate purposes and activities. Article 21 treats amendments to those purposes and activities as requiring ministerial approval.
The Ministry of Law’s AHU guidance follows this approach. Changes to corporate purposes and activities require a General Meeting of Shareholders. The decision must then be recorded in a notarial deed.
Therefore, KBLI 2025 for PT PMA requires coordination between OSS and AHU. Updating only one system can leave inconsistent corporate records.
An amendment should generally be unnecessary when the conversion is purely technical. This position applies when the actual business remains unchanged.
For example, the new code may replace an old code without altering its commercial substance. The business description in Article 3 may already cover the same activity.
Additionally, existing licences generally remain valid under the government’s transition policy. Therefore, the company should not amend its deed only because a numerical code changed.
However, the company should retain its legal review. The review should explain why the activity remains materially identical. This record may help during audits, transactions, or licence applications.
A written mapping table is useful. It can connect the old code, new code, corporate purpose, NIB, and operational evidence.
An amendment becomes necessary when the company changes its corporate purposes or activities. This can occur during diversification, expansion, or business restructuring.
It may also arise when a split classification forces the company to choose a narrower activity. The selected activity may differ from the existing wording in Article 3.
In that case, shareholders generally need to approve the amendment. The decision must satisfy the voting requirements under the Company Law and Articles of Association.
A notary then records the resolution through a deed of amendment. The amendment concerning purposes and activities requires approval from the Minister of Law.
After AHU approval, the company should update its OSS profile and NIB. It must then process any required Standard Certificates, licences, or PB UMKU.
The sequence should be coordinated carefully. Inconsistent wording across AHU and OSS may cause rejection or delay.
A code acceptable for an Indonesian company may not always be available to foreign investment. A PT PMA must conduct an additional foreign ownership review.
Presidential Regulation Number 10 of 2021 established Indonesia’s investment business-field framework. Presidential Regulation Number 49 of 2021 later amended that framework.
Under this framework, most commercial fields are open to investment. However, some remain reserved, closed, conditionally open, or subject to ownership limits.
Special sectoral legislation can also impose additional conditions. These may include local partnerships, special licences, technical qualifications, or minimum capital requirements.
A conversion under KBLI 2025 for PT PMA must therefore consider more than textual similarity. The company should check foreign ownership eligibility for every proposed code.
This review should occur before any shareholder resolution. Otherwise, the company may approve an activity that its ownership structure cannot lawfully conduct.
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A new code does not always change the company’s investment or capital position. However, it can affect the calculation applied to each business field.
PT PMA companies generally remain subject to foreign investment thresholds. The applicable amount depends on current investment regulations, business fields, and project locations.
Investment Ministry Regulation Number 5 of 2025 governs OSS procedures and investment facilities. It replaced several earlier BKPM regulations from 2021.
A company adding several business classifications should review its investment plan carefully. OSS may assess investment values by activity and location.
Companies should also distinguish authorised capital, issued capital, paid-up capital, and planned investment. These concepts have different corporate and regulatory functions.
A proper review should begin with the company’s actual business model. The legal team should understand how the company earns revenue.
First, collect the latest deed, ministerial approval, NIB, business licences, and supporting licences. Also collect LKPM reports, tax registrations, and sectoral approvals.
Second, list every operational activity. Review contracts, invoices, product catalogues, websites, facilities, and employee functions.
Third, compare each KBLI 2020 code with the official conversion table. Identify whether the mapping is one-to-one, one-to-many, or many-to-one.
Finally, review foreign ownership, risk levels, capital commitments, and sectoral requirements. Only then should management decide whether amendments are needed.
A practical review should cover the following actions:
This checklist turns KBLI 2025 for PT PMA into a manageable governance process. It also creates a clear compliance record.
An inaccurate code can affect the validity of business operations. The seriousness depends on the company’s sector and risk level.
First, the company may lack the correct licence. An NIB alone may be insufficient for medium-risk or high-risk activities.
Second, the company may breach foreign ownership restrictions. This can attract regulatory intervention and complicate future corporate transactions.
Third, inconsistent documents may delay banking, financing, and due diligence. Banks often compare corporate purposes with actual transactions.
Fourth, the mismatch can affect tenders and commercial contracts. Customers may require evidence that the company holds suitable licences.
Fifth, inaccurate information can create problems during OSS supervision. Consequences may include warnings, suspension, licence revocation, or other administrative measures.
Finally, the mismatch can weaken transaction readiness. Buyers and investors usually treat licensing defects as legal and valuation risks.
One common mistake is selecting codes based only on similar titles. Two titles may appear similar but cover different operational scopes.
Another mistake is adding many codes for future flexibility. Each additional code may create investment, reporting, and licensing obligations.
Some companies update OSS before reviewing their Articles of Association. This approach can create inconsistent government records.
Others amend their deed unnecessarily. A purely technical conversion may not justify shareholder meetings and notarial costs.
A further mistake involves ignoring PB UMKU. Updating the principal business field does not automatically update every supporting licence.
Finally, some companies overlook foreign ownership limits. A new code can fall under different investment conditions.
Careful planning prevents these mistakes. The company should complete its legal mapping before selecting any OSS conversion option.
In our view, companies should not approach this transition with panic. They should also avoid automatic conversion without legal review.
The correct approach begins with substance. What does the company actually sell, produce, manage, or provide? Does Article 3 accurately cover those activities?
After answering these questions, the company can assess the technical conversion. This sequence prevents the OSS system from driving the business strategy.
For a PT PMA, the review should include foreign ownership and investment requirements. Sectoral regulations must also receive careful attention.
We recommend preparing a written compliance matrix. It should compare the deed, AHU records, NIB, licences, actual operations, and proposed classification.
This matrix can support management decisions and future due diligence. It also demonstrates that directors acted carefully and responsibly.
Most importantly, amend documents only when the legal substance requires it. Do not rely solely on numerical changes.
KBLI 2025 does not automatically cancel an existing NIB or business licence. It also does not automatically require every PT PMA to amend its Articles of Association.
However, companies must review the substance behind each conversion. A technical conversion may require only an OSS adjustment. A material business change can require broader corporate and licensing actions.
The review should cover actual operations, Article 3, foreign ownership, risk classifications, and sectoral licences. It should also consider investment commitments and reporting obligations.
Ultimately, KBLI 2025 for PT PMA is not merely an administrative issue. It affects corporate authority, licensing validity, and investment compliance.
Early review can prevent delays, rejected applications, and costly restructuring. It can also strengthen the company’s position before financing or investment transactions.
Need help reviewing your PT PMA under KBLI 2025? Kusuma & Partners Law Firm can assess your corporate documents, NIB, OSS data, and licensing requirements.
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