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ACTIVITY BEFORE CODE

How to Choose KBLI Codes for PT PMA Setup Guide

The right KBLI is the code whose official scope matches what the PT PMA will actually sell, deliver, locate, staff, invoice, and license—not the broadest label in a search result.

Choose KBLI codes for a PT PMA by writing an activity-and-revenue map first, then matching each distinct activity to the current official KBLI description and scope. For every candidate code, test foreign-investment access, reserved or partnership conditions, risk level, location and spatial requirements, sector license and PB UMKU dependencies, investment and capital implications, staffing, tax and customs consequences, and the evidence the company can produce. Only then approve the code set for the deed and OSS application.

Use the Indonesia KBLI directory to identify possible codes, but approve none until the activity map, foreign-investment conditions, risk level, location, licensing, capital, tax, customs, staffing, and evidence tests are complete. Record why each code is included or rejected, identify any activity that must be separated or conditioned, and obtain current sector-specific advice when the official description does not clearly match the planned revenue and operating model.

In this article

Key takeaways

  • Describe activities in operational verbs, customers, deliverables, locations, channels, and revenue flows before searching codes.
  • Use the current OSS KBLI 2025 information and preserve the exact description and scope checked.
  • Test ownership, risk, sector, premises, PB UMKU, capital, tax, customs, and staffing consequences by code and project.
  • Reject decorative codes that the company cannot support with contracts, people, premises, systems, and permits.

Map the real activities

Turn products, customers, deliverables, locations, people, systems, invoices, and launch dates into a code-ready map.

Write the PT PMA activity map before searching KBLI

Interview commercial, operations, product, finance, and legal owners and describe each activity without code language. Record what is sold, who the customer is, whether the company manufactures, imports, distributes, hosts, consults, licenses intellectual property, operates a platform, holds inventory, employs regulated professionals, or receives commission, where the work occurs, who performs it, what the customer receives, how the company invoices, and what happens during the first twelve months. Separate current launch activities from later options.

KBLI is a classification system, while OSS uses the selected business activity with location and other data to determine the licensing route. The official OSS KBLI page now identifies KBLI 2025. That is why an old adviser checklist, a competitor's NIB, or a KBLI 2020 label should not be copied without checking the current classification and transition position. Preserve the official page or record checked and the date.

Turn the interview into an activity matrix with one row per revenue or regulated activity. Add product or service, customer, contract promise, delivery evidence, location, facility, staff or professional role, equipment, supplier and subcontractor, payment flow, tax invoice, import or export, data or platform element, expected start date, and owner. If two teams describe the activity differently, resolve the commercial facts before debating codes. The code decision cannot repair an unclear business model.

Activity fact Question Evidence
Customer promise What exact output is contracted and invoiced? Contract, proposal, order, invoice design and acceptance
Delivery model Who performs what, where, with which assets or platform? Process map, staff plan, premises, systems and suppliers
Commercial stage What launches now and what is only a future option? Board plan, budget, hiring and implementation milestones
Regulatory interface Which activity, site, profession, product or channel may require approval? Sector analysis and current official requirements

Match each activity to KBLI 2025 scope

Search the current official KBLI material using the operational nouns and verbs from the activity map. Read the full description, inclusions, exclusions, scope options, and any linked licensing information; do not select from the code title alone. Where one old code maps to several new codes or several old codes map to one, document why the chosen KBLI 2025 scope fits the real activity. Keep rejected candidates and reasons so a later reviewer can see that the answer was deliberate.

OSS has issued a current KBLI 2020-to-2025 conversion guide . It shows that conversion can be one-to-one, one-to-many, or many-to-one and tells users to choose the correct activity, scope, and location before continuing to NIB issuance. Treat conversion as a substantive mapping exercise, not a mechanical rename.

Build a decision note for every selected code: current code and label, full scope excerpt paraphrased in the company's words, matched activity, excluded activities, customer and deliverable, location, launch date, source URL, access date, reviewer, and uncertainty. If the planned service bundles several activities, decide whether the company needs multiple codes, a different lead code, separate contracts, subcontracting, or a narrower launch. Do not add a broad code merely to look flexible.

Scope match

Explain which contracted activity and evidence fits the official description and what falls outside it.

Version control

Record KBLI 2025, any conversion relationship, source date, selected scope and rejected alternatives.

Launch boundary

Mark code as launch, conditional, later phase, or rejected; connect it to a real owner and milestone.

Test the KBLI consequences

Check scope, ownership, risk, permits, premises, capital, tax, customs, staffing, and operating conditions.

Test foreign-investment and license effects by KBLI

For every candidate code, run a separate access and licensing test. Check whether the activity is open to foreign investment, subject to a foreign ownership limit, reserved or allocated to cooperatives or UMKM, requires partnership, is closed, or is affected by a sector-specific rule. Then identify the OSS risk level, NIB role, standard certificate or license, verification, PB UMKU, technical approval, professional requirement, product approval, environmental and spatial condition, and competent authority.

The investment-field framework is contained in Presidential Regulation 10 of 2021 as amended by Presidential Regulation 49 of 2021. The official BPK record for the amendment explains that commercial fields are generally open except closed or central-government-only activities, while schedules and conditions still matter. PP 28 of 2025 now governs risk-based licensing. These high-level rules do not replace a current code, sector, location, shareholder, and project analysis.

Create a license path card for each code and location. List the risk result, NIB, certificate or license, verification, PB UMKU, sector and local authority, spatial and environmental prerequisites, premises type, documents, inspection or technical evidence, dependency, owner, and earliest lawful operating gate. Compare the result with the foreign-ownership verification guide . Stop the setup if the shareholder plan, premises, or launch date assumes a permission the current activity cannot obtain.

Ownership gate

Current investment-field schedule, sector condition, shareholder nationality and percentages, partnership or UMKM limitation.

License gate

Risk level, NIB, certificate or license, verification, PB UMKU, authority, documents and operating condition.

Location gate

Project coordinates, zoning or spatial status, building and environmental evidence, landlord rights and sector suitability.

Approve a defensible KBLI set for deed and OSS

Before incorporation or amendment, reconcile the proposed code set with the deed's purposes, shareholder and ownership analysis, OSS project plan, location, investment and capital schedule, operating budget, staffing, contracts, invoice descriptions, tax and customs registrations, bank KYC narrative, website claims, and implementation calendar. One code may affect several downstream records, and a mismatch discovered after contracts are signed can require more than a simple portal edit.

PP 28 of 2025 defines risk-based business licensing and requires business operators to hold the permissions applicable to their activities. Review the current official risk-based licensing record . OSS acceptance of a code or issuance of an NIB should not be represented as proof that every certificate, verification, sector approval, site condition, or operating requirement is complete.

Hold a board or authorized management approval with the activity map, selected and rejected codes, ownership analysis, license paths, location results, investment and staffing effects, adviser assumptions, unresolved items, and change triggers. Assign a pre-contract check so sales and operations cannot launch an unapproved activity. If a mismatch is already present, use the PT PMA KBLI correction sequence rather than disguising the activity under an adjacent code.

Corporate alignment

Deed, shareholders, code descriptions, projects, locations, investment plan and approval record agree.

Operating alignment

Contracts, staff, premises, systems, suppliers, invoices, bank narrative and tax or customs setup agree.

Change control

New product, customer promise, location, platform, import, professional role or revenue model triggers review before launch.

Official references and review basis

The following primary sources were checked on August 1, 2026. They establish the regulatory or service boundary used in this article; bank, tax office, OSS, AHU, and immigration decisions can still depend on the current record and the facts of a particular application.

The approval test for a PT PMA KBLI set

Approve only codes that match a documented launch activity, use the current KBLI version, pass foreign-investment and sector checks, produce a feasible risk-based license path, fit the real location, and reconcile with the deed, contracts, staffing, investment plan, tax, customs, banking, and operating evidence. More codes do not create more legal flexibility when the underlying activities are unsupported.

Keep a rejected-code record and a future-activity gate. Escalate ambiguous scope, foreign ownership, UMKM reservation, sector licensing, location, or capital effects to qualified Indonesian advisers before filing. Use the Indonesia company registration framework to sequence the approved code set with the rest of setup.

Approve the launch code set

Reconcile deed, OSS, contracts, location, investment, bank, tax, and operating evidence before filing.

Frequently asked questions

Should a PT PMA select as many KBLI codes as possible?
No. Select codes supported by real activities, ownership, location, investment, staffing, contracts and a feasible license path. Decorative codes can create inconsistency and compliance work.
Is the KBLI title enough to confirm a match?
No. Read the current full scope, inclusions, exclusions and linked conditions, then match them to operational facts and preserve the analysis.
Can an old KBLI 2020 code simply be reused?
Check the current KBLI 2025 classification and official conversion guidance. Mapping can be one-to-one, one-to-many or many-to-one, so a substantive review may be required.
Does a selected KBLI prove 100 percent foreign ownership is allowed?
No. Run a separate current investment-field and sector analysis for the code, shareholder plan and facts. A code match and foreign-investment eligibility are different tests.
What should trigger a KBLI review after setup?
A new product, service, customer promise, revenue model, location, import, platform, professional role, equipment or operating method should be reviewed before launch.
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