100% Foreign-Owned Companies in Indonesia: Check Eligibility for Your KBLI Activity

Define the whole business before checking ownership

Start with the commercial activities, rather than a preferred code. Write what the Indonesian company will supply, to whom, through which channel, and whether it manufactures, trades, provides services or handles regulated functions. Separate work done by the company from work bought from an independent supplier. A supplier’s permission does not describe your company’s scope.

For this review, “100% foreign-owned” concerns the total foreign shareholding. Foreign investment under Law 25/2007 can involve wholly foreign capital or a combination with domestic capital. A proposed local shareholder therefore changes the ownership structure; it does not convert an otherwise restricted activity into unrestricted foreign ownership.

Use one row for each distinct activity and include planned additions that will be launched under the same company. Note the product, customer, location, delivery method and any size or technical feature that could affect the restriction. Avoid broad descriptions such as “technology business” when the company actually supplies several different services.

Check the complete operating scope , not just the main revenue code. Have the commercial owner confirm that the list matches intended contracts and invoices. If a draft contract includes an extra activity, resolve that discrepancy before the share table is approved. This is an editorial control for the review, not a government form.

Once the scope is settled, Indonesia company formation requirements provide the separate entity-planning context. An ownership conclusion alone does not complete incorporation or authorise the activities.

Match each activity to the current KBLI description

Use KBLI 2025 and its current descriptions. Statistics Indonesia’s classification was adopted through Regulation 7/2025; BPS Regulation 6/2026 amended the annex and took effect on September 10, 2026. This updates the classification reference. It is not, by itself, a rule opening or closing an activity to foreign equity.

Read the five-digit description, inclusions and exclusions against the commercial scope. Record why the activity fits and why any plausible neighbouring code does not. Keep the description used on the review date, rather than saving only a search result or a code number. A familiar number can conceal a different activity boundary after a revision.

For existing records, preserve both the old and current codes. The official OSS conversion guide distinguishes manual one-to-many selection from automatic conversion paths. It illustrates 10510 becoming 10501; the current BPS annex describes 10501 as fresh milk and cream manufacturing. That example establishes a classification relationship, not a foreign-ownership conclusion for that activity.

A mapping is not an ownership approval. If a predecessor splits into several current activities, select the branch matching the actual work and trace the applicable restriction to that scope. Where the link is uncertain, leave the ownership conclusion unresolved and identify the evidence needed to settle it. Do not interpret the new code’s absence from a 2021 annex as automatic eligibility.

Read the restriction and every qualifier

Read the investment rule by activity description and qualifying language, not by number alone. Under the amended Article 6 , conditional fields include domestic-investment requirements, foreign-equity limits and special permissions. Where a code covers several fields, the listed requirement applies to the field specified in the activity column. The words beside the number determine the boundary.

The amended Annex III demonstrates why qualifiers matter: geographically indicated coffee processing is specified with domestic-only capital, while scheduled commercial air transport combines a 49% foreign cap with an additional national-ownership condition. These are examples from the annex’s own code references, not a current-code eligibility directory or a clearance for a particular project.

Also identify the current rules of the relevant sector regulator. Article 11 of Regulation 10/2021 preserves sector-specific licensing standards and treats finance and banking under their respective legislation. For the review, separate a sector ownership condition from an operational condition. A missing operating approval can prevent launch even where the proposed equity is permitted.

The same review needs to connect classification, the exact investment condition and the remaining evidence. The result for each activity then feeds the decision for the whole proposed scope.

Build a company-wide eligibility sign-off

Use the following worksheet as an internal approval record. Repeat it for every activity; it is an editorial review tool, not an OSS certificate or legal opinion. Attach the underlying evidence so a second reviewer can follow the decision without recreating the research.

Give each row a review date, evidence location and named reviewer. “Not found” is a research observation; “not applicable” is a reasoned conclusion. Record why a restriction does not apply, especially where a broader code or predecessor appears in the rule. A blank cell should remain visibly unresolved rather than silently becoming a pass.

A code-selection memo helps with recording the reasons behind your chosen codes before the ownership reviewer signs off. Keep that classification reasoning with the legal conclusion; neither document should depend on a screenshot of an unexplained green system status.

Ownership eligibility and operating readiness need separate conclusions. The current risk-based licensing framework is Government Regulation 28/2025 . Track the Business Identification Number (NIB), applicable Standard Certificate or Business Licence and supporting approvals in the launch record. Issuing a company document or NIB does not answer every activity-specific licensing question.

Resolve a failed or uncertain activity without nominees

Hold the affected activity when the evidence does not support the proposed ownership. First determine whether the problem is the commercial scope, the code match, an actual restriction or a missing source. Correct the underlying item and preserve the reason for the correction. Changing the label while continuing the same restricted work does not resolve the review.

• For a classification error, restate the actual activity, compare the current descriptions and correct the mapping before reassessing ownership.
• For a genuine ownership restriction, reconsider the planned scope or a lawful ownership structure with real economic ownership and applicable approvals.
• For an uncertain qualifier or sector rule, identify the precise question, send the underlying facts for qualified review and keep the row unresolved until evidence supports a conclusion.
• For a permitted activity awaiting operational approvals, retain the ownership result but keep the launch decision on hold until its separate requirements are met.

Nominee shares are not a repair for an ownership restriction. Article 33 of the Investment Law prohibits agreements or statements declaring PT shares held for and on behalf of another person and makes those arrangements void. Do not replace a failed ownership row with a private promise that the foreign investor secretly owns the local shareholder’s shares.

Reopen the review when you add an activity, change the operating model, change a relevant location or qualifier, alter the ownership, or encounter a revised rule or classification. Preserve the previous signed-off version, then show what changed. This gives the decision owner a specific issue to approve rather than a fresh but unexplained “all clear.”

Approve 100% ownership only for the signed-off scope

Approve the proposed 100% foreign shareholding only against a defined activity schedule whose rows support that conclusion. List any remaining conditions beside the decision and keep unresolved or incompatible activities outside an unconditional approval. The company’s shareholding decision should refer to that schedule and its review date.

Escalate a missing mapping, a conflicting sector requirement or a restriction that does not clearly fit the actual work before committing to the structure. Once ownership is resolved, hand the agreed scope to the incorporation and licensing teams with their separate completion tests. The useful output is a traceable decision that states what is permitted, what remains conditional and who owns the remaining action.