Most of what changed for PT PMA over the last two years was not the company setup. It was what happens after the company exists, and specifically, whether you are allowed to trade.
If you are working from a guide written before late 2025, three things in it are now wrong.
1. The capital number moved
BKPM Regulation 5/2025 cut minimum paid-up capital from IDR 10 billion to IDR 2.5 billion. The minimum investment plan you declare in OSS, IDR 10 billion per five-digit KBLI per location, excluding land and buildings, did not change.
Two different numbers doing two different jobs. Paid-up capital is what you actually put in and cannot withdraw for twelve months. The investment plan is a projection you commit to in the system. Confusing them is the single most common error we correct on inherited files.
One knock-on: capital and immigration thresholds have now separated. Investor KITAS still requires IDR 10 billion in share value. A properly capitalised company at 2.5 billion no longer qualifies its shareholders automatically.
2. Licensing is risk-based, and your KBLI decides the risk
This is the part people underestimate. Under PP 28/2025, in force since 5 October 2025, OSS assigns every activity a risk level automatically from your KBLI code and business scale. Four levels: low, medium-low, medium-high, high.
You do not choose your risk level. Your KBLI chooses it for you. Which means the classification decision made in week one determines the licensing burden you carry from then on.
3. The Sertifikat Standar is not automatic, and this is where timelines break
Here is the distinction that costs people months.
- Low risk. NIB is enough. You can operate.
- Medium-low. NIB plus a Sertifikat Standar. You self-declare that you meet the standard and the certificate issues automatically.
- Medium-high. NIB plus a Sertifikat Standar that must be verified by the relevant ministry or regional authority before it is active. The certificate appears in OSS almost immediately with the status not yet verified. That status is not a formality. Until an official verifies it, you are not cleared to operate commercially.
- High risk. A sector licence, and in some cases a verified Sertifikat Standar as well.
The legal basis is Article 131(2) of PP 28/2025: verification for medium-high risk activities is carried out by central government, regional government, or the relevant KEK or KPBPB authority, based on checking that the operator genuinely meets the standard.
We see the same failure repeatedly. A founder incorporates, sees a Sertifikat Standar in their OSS dashboard, assumes licensing is finished, signs a lease and starts hiring. The certificate was never verified. Legally, nothing had been cleared.
The one piece of good news
PP 28/2025 introduced fiktif positif: if the authority misses its service-level deadline without issuing a decision, approval is deemed granted. It is a real protection against agencies sitting on files. It is not a plan, you still need the documentation to be right, but it changes the negotiating position when something stalls.
What actually didn’t change
The sequence is the same as it always was: deed, Kemenkumham approval, NIB, then licensing appropriate to your risk level, then immigration. Foreign ownership is still governed by the Positive Investment List. LKPM reporting is still quarterly and still mandatory for PMA.
What changed is the cost of getting the KBLI wrong. Under a risk-based system, classification is not administrative tidying. It sets your licensing path, your verification burden, and how long before you can legally take money.
Correct at the date of publication. Indonesian licensing practice varies by sector and region; check before you commit, or ask us.