Consilio Consulting Asia

KBLI, explained: picking the business classification that fits

Every Indonesian company carries a KBLI code. It looks like an administrative detail on your NIB. It is closer to the operating system of your business. It decides what you may legally do, whether foreigners may own it, how heavy your licensing is, and how long before you can trade.

And the whole classification was replaced.

What changed

KBLI 2020 has been superseded by KBLI 2025, introduced by BPS Regulation 7/2025. This is not a cosmetic renumbering. Categories were split, merged, retired and created to reflect activities that barely existed when the 2020 list was drawn: digital services, platform businesses, the energy transition.

Practically, that means the code on an older NIB may now describe your activity imprecisely, sit under a different risk level, or no longer exist as written.

Why the code matters more than founders expect

Your KBLI drives four separate things at once:

  • What you may lawfully do. Activity outside your registered code is not a grey area.
  • Whether foreigners may own it, and how much. The Positive Investment List (Perpres 10/2021 and 49/2021) sets caps per code: some fully open, some capped, some closed.
  • Your risk level. Under PP 28/2025, OSS derives risk automatically from the code. That determines whether you need only an NIB, a self-declared Sertifikat Standar, a verified Sertifikat Standar, or a full sector licence.
  • Your investment plan. IDR 10 billion per five-digit code per location. Every extra code multiplies the commitment.

One code, four consequences. This is why we spend real time on classification rather than picking whatever sounds closest.

Where it goes wrong in practice

Villa rental. KBLI 55193 covers short-term accommodation and cannot be activated by a PT PMA. That is a hard block, not a matter of interpretation. Foreign investors in villa rental structure it as a PMA management company earning fees alongside a PMDN entity that holds 55193 and operates. Registering 55193 under a PMA is not aggressive planning; it does not work.

Property holding. KBLI 68111 covers owning and leasing real estate for permanent use, monthly and yearly, and specifically not daily accommodation. Founders who assume 68111 lets them run nightly rentals have chosen the wrong code for the business they are actually operating.

Architecture. KBLI 71101 is open to foreign ownership but capped at 67% for non-ASEAN investors and 70% for ASEAN, and it requires IUJK, SBU and certified Indonesian professionals. Open on paper, demanding in practice.

What the split looks like in practice

The clearest way to see the scale of the change is a code that used to do a lot of work on its own.

Under KBLI 2020, a single real-estate code covered owning and leasing property broadly. Under KBLI 2025 that activity is distributed across several distinct codes. Residential development sits apart from rental of residential property you own or lease, which sits apart from shopping centre management, warehouse and self-storage rental, office building management, and other non-residential real estate.

One code became a family of them. That matters for three reasons:

  • Precision is now expected. “Real estate” is no longer an answer. The system wants to know which real estate activity.
  • Risk levels differ within the family. Some of these sit at medium-low, where the Sertifikat Standar issues automatically on self-declaration. Others, real estate intermediation and appraisal among them, sit at medium-high, where the certificate must be verified by the relevant authority before you can operate.
  • Your investment plan multiplies. At IDR 10 billion per five-digit code per location, registering four codes where one activity would do is an expensive habit.

The same pattern repeats across other sectors. If your NIB carries codes chosen under the 2020 list, the mapping is worth checking properly rather than assuming the number carried across unchanged.

Regional rules sit on top of national ones

National eligibility is not the end of the analysis. Bali Province has issued restrictions affecting PMA activation of particular codes and the use of virtual office addresses. A code that is perfectly available nationally can be unavailable at your intended address.

Always check the province and regency, not only the Positive Investment List.

What to do if you already have a company

Pull up your NIB and look at the codes on it. Then ask three questions:

  1. Does each code still accurately describe what the business does today?
  2. Does each map cleanly onto the 2025 classification?
  3. Has the risk level shifted, and if so, do you now need a verified Sertifikat Standar you have not obtained?

That last one is the expensive surprise. A reclassification can move you from medium-low to medium-high, which means the certificate you relied on is no longer sufficient on its own.

Most companies need no change. The ones that do are usually the ones who never looked.


Correct at the date of publication. Code mappings are activity-specific. Verify yours in OSS, or ask us to check it.

Consilio Legal Desk

Corporate structuring, licensing and company compliance at Consilio Consulting Asia.

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