Indonesia Positive Investment List Screening for KBLI 2025
Crosswalk the current activity code to the in-force investment-business-field rules, conditions, partnerships, sector laws, and proposed ownership structure.
Indonesia no longer uses the old 2016 negative investment list as the current framework. Screen the activity under Presidential Regulation No. 10 of 2021 as amended by Presidential Regulation No. 49 of 2021 , then crosswalk the proposed KBLI 2025 code using official BPS materials and check sector-specific laws. The result may be open, subject to conditions, allocated or partnership-related, government-only, closed, or otherwise limited by a more specific rule.
Do not assume that a KBLI number appearing in a 2021 appendix maps mechanically to KBLI 2025 or that a sector is fully open because it is not listed under one category. The memo should preserve the code version, activity facts, correspondence method, applicable condition, investor nationality where relevant, business scale, location, sector regulator, and date checked. Resolve ambiguity before approving ownership percentages or nominee arrangements.
In this article
Positive investment list screening decision controls
Use the control, evidence, and release condition together; no single document should carry more meaning than it actually proves.
| Control stage | Question to resolve | Evidence anchor |
|---|---|---|
| Fix the real activity and KBLI 2025 code | document the operating facts and select the current code before reading the investment appendices | Operating narrative |
| Crosswalk the code to the 2021 framework | map the current code and activity to Perpres 10/2021 as amended, preserving correspondence assumptions | Perpres appendix reference |
| Read every condition and allocation | identify ownership limits, investor nationality, licences, recommendations, location, UMKM allocation, or partnership requirements | Ownership and nationality condition |
| Check sector laws and the proposed structure | test the result against sector-specific laws, regulators, shareholder roles, nominee prohibitions, and the planned company structure | Sector regulator rules |
| Approve a dated ownership-screen memo | record the sources, version, activity, code, conditions, interpretation, reviewers, and refresh triggers | Dated source pack |
Scope the positive investment list screening before acting
Share the company facts, intended outcome, current records, and unresolved conditions so the positive investment list screening review can be bounded.
Key takeaways
- Do not issue an ownership view without a supportable current code.
- Escalate any non-exact correspondence for legal confirmation.
- State the condition in operational terms and identify the evidence needed to satisfy it.
- Reject a structure that relies on undisclosed beneficial ownership or unsupported control.
- Use the memo as a gate for deed, OSS, funding, and shareholder agreements.
Fix the real activity and KBLI 2025 code
For positive investment list screening, document the operating facts and select the current code before reading the investment appendices. For fix the real activity and kbli 2025 code, the classification must follow the real economic activity under current KBLI 2025 materials and then be tested against ownership, investment, location, and licensing consequences.
Ownership research based on a broad sector name can miss the actual regulated activity. A reviewer should trace operating narrative and kbli 2025 description to current authoritative records and actual operating evidence, rather than a copied template, provider promise, or unexplained portal label.
For fix the real activity and kbli 2025 code, implementation should convert this stage into a dated control record rather than a conversation summary. It should connect operating narrative with kbli 2025 description, then show how legacy correspondence and mixed-activity boundary affect the next approval. Record the source for operating narrative, the reviewer of kbli 2025 description, the decision date, any unresolved exception, and the acceptance evidence so later changes preserve the original reasoning.
Release test
Do not issue an ownership view without a supportable current code.
- Operating narrative
- KBLI 2025 description
- Legacy correspondence
- Mixed-activity boundary
For fix the real activity and kbli 2025 code, the output should name the owner, source evidence, unresolved condition, acceptance test, and the event that permits the next step.
Crosswalk the code to the 2021 framework
The responsible team should map the current code and activity to Perpres 10/2021 as amended, preserving correspondence assumptions. For crosswalk the code to the 2021 framework, the classification must follow the real economic activity under current KBLI 2025 materials and then be tested against ownership, investment, location, and licensing consequences.
A code renumbering or scope change can produce a false match or omission. A reviewer should trace perpres appendix reference and 2020–2025 conversion evidence to current authoritative records and actual operating evidence, rather than a copied template, provider promise, or unexplained portal label.
For crosswalk the code to the 2021 framework, the evidence file for this stage should let a new reviewer reproduce the decision without asking the original provider what happened. It should connect perpres appendix reference with 2020–2025 conversion evidence, then show how matched activity wording and ambiguity and advice log affect the next approval. Record the source for perpres appendix reference, the reviewer of 2020–2025 conversion evidence, the decision date, any unresolved exception, and the acceptance evidence so later changes preserve the original reasoning.
Stop condition
Escalate any non-exact correspondence for legal confirmation.
- Perpres appendix reference
- 2020–2025 conversion evidence
- Matched activity wording
- Ambiguity and advice log
For crosswalk the code to the 2021 framework, preserve the source record, reviewer, date, exception, and approval so another team can reproduce the decision without relying on memory. For the adjacent control framework, compare How to Check Whether an Indonesia KBLI Allows 100% Foreign Ownership .
Read every condition and allocation
A supportable decision begins when the company can identify ownership limits, investor nationality, licences, recommendations, location, UMKM allocation, or partnership requirements. For read every condition and allocation, the classification must follow the real economic activity under current KBLI 2025 materials and then be tested against ownership, investment, location, and licensing consequences.
Calling a field open can ignore conditions that determine whether the proposed investor may enter. A reviewer should trace ownership and nationality condition and scale and umkm treatment to current authoritative records and actual operating evidence, rather than a copied template, provider promise, or unexplained portal label.
For read every condition and allocation, operational ownership matters here because the same fact may be presented differently in corporate, licensing, tax, bank, contract, and site records. It should connect ownership and nationality condition with scale and umkm treatment, then show how partnership or recommendation and location and licensing condition affect the next approval. Record the source for ownership and nationality condition, the reviewer of scale and umkm treatment, the decision date, any unresolved exception, and the acceptance evidence so later changes preserve the original reasoning.
Record standard
State the condition in operational terms and identify the evidence needed to satisfy it.
- Ownership and nationality condition
- Scale and UMKM treatment
- Partnership or recommendation
- Location and licensing condition
For read every condition and allocation, turn the result into a controlled work item with a responsible person, due date, evidence location, escalation path, and release condition.
Test the positive investment list screening evidence
Reconcile the authoritative, operational, contractual, tax, banking, and evidence fields that affect the positive investment list screening decision.
Official References and Review Basis
Primary materials for Indonesia Positive Investment List Screening for KBLI 2025 were checked on August 4, 2026 and support this page's framework; they do not replace a matter-specific legal, tax, licensing, accounting, security, premises, or bank review of Indonesia Positive Investment List Screening for KBLI 2025.
- Presidential Regulation No. 10 of 2021 : Investment business-field framework, as amended.
- Presidential Regulation No. 49 of 2021 : Current amendment to the investment business-field framework.
- BPS KBLI 2020–2025 conversion table : Official correspondence table for reviewing changes between KBLI 2020 and KBLI 2025.
- BPS release on KBLI 2025 : Official explanation that KBLI 2025 was established by BPS Regulation No. 7 of 2025 and updates KBLI 2020.
- Online Single Submission portal : Official NIB, four-level risk classification, business licensing, KBLI, and support portal.
Regulatory Notes and Limitations
Indonesia Positive Investment List Screening for KBLI 2025 provides a decision and evidence framework, not a universal legal opinion. Review the current official output and company-specific facts before filing, contracting, paying, or operating.
- For Indonesia Positive Investment List Screening for KBLI 2025, kBLI classification describes economic activity; it does not by itself prove foreign-ownership eligibility, premises suitability, or completion of every licence condition.
- For Indonesia Positive Investment List Screening for KBLI 2025, kBLI 2025 and the official 2020–2025 correspondence table must be reviewed against the actual product, service, customer, delivery model, and location.
- For Indonesia Positive Investment List Screening for KBLI 2025, changing an activity can affect investment, licensing, tax, customs, employment, environmental, building, and bank records, so each function should confirm its own field.
Check sector laws and the proposed structure
Before the next commitment, management should test the result against sector-specific laws, regulators, shareholder roles, nominee prohibitions, and the planned company structure. For check sector laws and the proposed structure, the classification must follow the real economic activity under current KBLI 2025 materials and then be tested against ownership, investment, location, and licensing consequences.
The investment list is not the only source of sector or governance restrictions. A reviewer should trace sector regulator rules and shareholder and ubo evidence to current authoritative records and actual operating evidence, rather than a copied template, provider promise, or unexplained portal label.
For check sector laws and the proposed structure, a defensible review separates facts already evidenced, facts requested but not received, assumptions approved for planning, and conditions that still block release. It should connect sector regulator rules with shareholder and ubo evidence, then show how governance and control rights and alternative compliant structures affect the next approval. Record the source for sector regulator rules, the reviewer of shareholder and ubo evidence, the decision date, any unresolved exception, and the acceptance evidence so later changes preserve the original reasoning.
Decision rule
Reject a structure that relies on undisclosed beneficial ownership or unsupported control.
- Sector regulator rules
- Shareholder and UBO evidence
- Governance and control rights
- Alternative compliant structures
For check sector laws and the proposed structure, record both the accepted position and the rejected alternatives; this prevents a later portal edit or provider message from silently changing the decision. Where this stage changes another workstream, review Foreign Ownership Changes When a PT PMA Adds a New KBLI .
Approve a dated ownership-screen memo
The control file must show how the company will record the sources, version, activity, code, conditions, interpretation, reviewers, and refresh triggers. For approve a dated ownership-screen memo, the classification must follow the real economic activity under current KBLI 2025 materials and then be tested against ownership, investment, location, and licensing consequences.
A verbal open-sector assurance becomes stale when codes, ownership, or operations change. A reviewer should trace dated source pack and decision and condition matrix to current authoritative records and actual operating evidence, rather than a copied template, provider promise, or unexplained portal label.
For approve a dated ownership-screen memo, the practical deliverable is a version-controlled decision row that remains usable when the activity, location, counterparty, or responsible person changes. It should connect dated source pack with decision and condition matrix, then show how legal and commercial approval and change and annual refresh triggers affect the next approval. Record the source for dated source pack, the reviewer of decision and condition matrix, the decision date, any unresolved exception, and the acceptance evidence so later changes preserve the original reasoning.
Evidence rule
Use the memo as a gate for deed, OSS, funding, and shareholder agreements.
- Dated source pack
- Decision and condition matrix
- Legal and commercial approval
- Change and annual refresh triggers
For approve a dated ownership-screen memo, close the stage only when the authoritative record and the operating evidence agree, or when an unresolved difference has a named owner and stop condition.
Connect the positive investment list screening control to the wider Indonesia company registration workstream before committing people, travel, or funds.
Approve foreign ownership from the current code and exact conditions
The positive investment list is a screening framework, not a one-line percentage table. The reliable answer starts with the real activity and KBLI 2025, then preserves the legal crosswalk and every applicable condition.
Attach the dated screen to the structure approval and repeat it before adding activities, changing ownership, or entering a regulated sector.
Turn the positive investment list screening into an approved next step
Create a sequenced action file with owners, evidence, exceptions, stop conditions, and an approved release point for positive investment list screening.
Frequently asked questions
