- by Ai Samaytuha Maryam
- 05 May 2026
New regulations rarely arrive with enough warning. And for foreign investors operating a PT PMA in Indonesia, June 18, 2026 is a date that cannot be ignored.
On December 18, 2025, Indonesia's Central Statistics Agency (BPS) officially enacted BPS Regulation No. 7 of 2025, introducing the new national business classification framework known as KBLI 2025. This replaces KBLI 2020 in its entirety and carries direct consequences for every business entity operating in Indonesia, including all PT PMA companies.
The adjustment deadline is six months from the date of enactment. That means by June 18, 2026, the OSS-RBA and AHU Online systems will have fully migrated to KBLI 2025. PT PMA companies that have not aligned their classifications risk having their Business Identification Number (NIB) flagged, new license applications rejected, and administrative sanctions imposed.
The question is no longer *whether* this will affect your PT PMA. The question is: how significantly, and how prepared are you?
- What Is KBLI, and Why This Update Is Not Just Administrative?
- Three Conversion Patterns, and Why One of Them Is a Risk to PT PMA
- Four Direct Impacts of KBLI 2025 on PT PMA Operations
- Why PT PMA Companies in Bali Face Additional Scrutiny
- What PT PMA Companies Must Do Before June 18, 2026
- Navigate KBLI 2025 with the Right Partner
KBLI (Klasifikasi Baku Lapangan Usaha Indonesia) is Indonesia's official system for classifying business activities. Every company, whether a local PT or a foreign-owned PT PMA, must select one or more five-digit KBLI codes that define the scope of its permitted business operations.
These codes are far more than a statistical label. In practice, KBLI codes determine:
- The issuance and renewal of your NIB through the OSS system
- Your business risk classification (low, medium, or high) and corresponding permit obligations
- Minimum investment thresholds per business activity
- Quarterly investment activity reporting (LKPM)
- Access to sectoral operating licenses and investment facilitation
When KBLI changes, the entire licensing ecosystem shifts with it. KBLI 2025 is not a minor update, the total number of five-digit business codes has been reduced from 1,789 to 1,558, with many codes split into narrower categories, consolidated, or redefined in substance.
BPS has published an official conversion table mapping every KBLI 2020 code to its KBLI 2025 equivalent. There are three possible outcomes for any given code:
Pattern 1: One-to-One (Direct Mapping)
One KBLI 2020 code maps directly to one KBLI 2025 code. In most cases, the OSS system handles this automatically. No action is required from the company. This is the safest outcome.
Pattern 2: Many-to-One (Consolidation)
Multiple KBLI 2020 codes merge into a single new code under KBLI 2025. This is also typically processed automatically and does not require significant additional steps.
Pattern 3: One-to-Many (Code Split), The Highest-Risk Scenario for PT PMA
One KBLI 2020 code splits into several more narrowly defined codes in KBLI 2025. This is the scenario that generates the most complications for PT PMA companies, and it demands immediate attention.
Why is this problematic? Because under Indonesia's investment framework, minimum investment requirements are calculated per five-digit KBLI code, per project location. If your single business code now splits into two or three more specific codes, you may formally be required to demonstrate a minimum investment of IDR 10 billion per code, per location. Without early planning, this can create a structural compliance gap that is costly to resolve after the fact.
1. NIB Validity at Risk
After June 18, 2026, any NIB that has not been aligned with KBLI 2025 may be considered invalid for licensing and reporting purposes. In practice, this means new permit applications will be rejected, existing permit renewals cannot be processed, and in some cases, access to business banking services may be disrupted.
2. LKPM Submissions May Be Rejected
The LKPM investment reporting system is directly integrated with KBLI codes registered in OSS. If your quarterly reports reference a KBLI 2020 code that no longer exists in the 2025 framework, the system will automatically reject the submission, placing you in breach of your investment reporting obligations.
3. Articles of Association May Need to Be Amended
Where KBLI adjustments involve a substantive change in the scope of business activities, companies are required to formally amend their Articles of Association through a notary, followed by approval from the Ministry of Law and Human Rights. This is not a process that can be completed overnight.
4. Business Expansion Can Stall Mid-Process
Companies planning to add new KBLI codes, open additional project locations, or undergo shareholder changes, including the entry of new foreign investors, must already operate under KBLI 2025 for all such processes. Misaligned codes in OSS can halt an entire expansion plan at the point of submission.
For PT PMA companies operating in Bali, the regulatory pressure of KBLI 2025 comes with an additional layer. The Ministry of Investment (BKPM) and the Bali Provincial Government have conducted dedicated socialization sessions, with field inspections and full regulatory enforcement expected from June 2026 onward.
Two sectors are under particularly close monitoring:
KBLI 68111, Real Estate: Authorities have identified widespread misuse of this code to cover small-scale villa developments that do not meet foreign investment capital standards. PT PMA companies using this classification without adequate investment realization are exposed to administrative warnings, temporary license suspension, and potential revocation.
KBLI 70209, Management Consultancy: New PT PMA entities can no longer activate this code in Bali using a Virtual Office address. Physical operational presence is now a mandatory requirement. Existing entities remain subject to inspection, especially regarding compliance with the minimum IDR 10 billion investment realization threshold.
The regulatory direction is clear: authorities are shifting from document-based verification to substance-based compliance, evaluating whether a company's actual operations genuinely reflect its registered KBLI and declared investment value.
Time is running out. These are the three priority actions every PT PMA should take before the deadline:
Step 1. Audit Your Existing KBLI Codes
Identify all KBLI codes currently registered in your OSS profile and Articles of Association. Cross-reference them against the official BPS conversion table to determine whether your codes fall under the one-to-one, many-to-one, or one-to-many pattern.
Step 2. Align Your Registered Activities with Your Actual Operations
Many companies have expanded their operations over time without updating their KBLI registrations. With the government now enforcing substance-based compliance, this is a critical window to bring your registered classifications in line with what your business actually does, before inspectors arrive.
Step 3. Initiate Deed Amendments and OSS Updates Early
If your audit reveals that corporate deed amendments are necessary, the notarial process and ministerial approval take time. Do not wait until mid-June. Ideally, the review and adjustment process should begin now.
KBLI 2025 is a reminder that in Indonesia, the right legal structure is not a formality, it is the foundation of a safe, sustainable investment.
At Pandara Prima, we guide foreign investors and PT PMA companies across Bali through every regulatory shift with a strategic, end-to-end approach: from auditing your existing KBLI codes and analyzing the impact on your OSS licensing, to coordinating deed amendments, NIB synchronization, and full operational permit alignment.
We understand that fast-moving regulations can feel overwhelming. But with the right guidance, every transition becomes an opportunity to build a stronger compliance foundation, and a more defensible investment.
Speak with the Pandara Prima team today. The June 18 deadline is closer than it looks.
