Indonesia Positive Investment List Explained

Foreign direct investment (FDI) plays a crucial role in Indonesia’s economic growth. In the first quarter of 2025, Indonesia attracted FDI totaling approximately US$13.67 billion. This is a 12.7% increase compared to the same period last year. 

Ushering this growth in foreign investment is the Positive Investment List in Indonesia. But what does this list mean for foreign investors?  In this article we will discuss the Positive Investment List, its different categories, the industries opened for FDI, and what it means for your business.

Key Sectors Opened Up by the Positive Investment List (Foreign Ownership Changes)

One of the most impactful aspects of the Positive Investment List is the elimination or raising of foreign ownership caps in over 200 business lines. The general rule is business sectors are open to 100% foreign ownership unless explicitly limited.

With the Positive Investment List, the following business activities are now permitted 100% foreign ownership: 

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Business Activity/ Sector	KBLI No.	Description of Business Activity Covered	Class Risk	License Required
Manufacture of Iron and Steel (Making)	24101	The manufacture of iron and steel in basic forms, such as iron ore pellets, sponge iron, and pig iron, and the manufacture of iron and steel in the form of crude steel, such as steel ingots, steel billets, steel blooms, and steel slabs. This also includes the manufacture of iron and alloy steel.	High	Operational License a. Located in an Industrial park b. Fulfillment of the SNI of steel c. Registered with the National Industrial System (SIINAS)
Non-Ferrous Base Metal Manufacturing Industry	24202	Manufacture of brass ingots, aluminum ingots, zinc ingots, copper ingots, tin ingots, brass billets, aluminum billets, brass slabs, aluminum slabs, brass rods, aluminum rods, brass pellets, aluminum pellets, bronze alloys, nickel alloys, and anti-friction metals	High	Operational License a. Located in an Industrial park b. Fulfillment of the SNI of Non-Ferrous Base Metal c. Registered with the National Industrial System (SIINAS)
Pharmaceutical Industry for Humans	21011	The manufacturing of processing medicinal materials, auxiliary materials, and packaging materials for humans, which are derived from chemical materials, natural materials, animals, and plants, including those derived from biological products	High	Operational License a. Located in an Industrial park b. Fulfillment of the SNI of Non-Ferrous Base Metal c. Registered with the National Industrial System (SIINAS)
Pharmaceutical Products Industry for Humans	21012	The manufacturing and processing of medicines, health/food supplements, in finished form (preparations) for humans, in the form of tablets, capsules, ointments, powders, solutions, parenteral solutions and suspensions, hormonal contraceptive drugs, and the biotechnology pharmaceutical industry.	High	a. Located in an Industrial park b. Fulfillment of the SNI of Non-Ferrous Base Metal c. Registered with the National Industrial System (SIINAS) d. Meets the Industrial Standards for Pharmaceutical Products for Human Use;
Electric Power Generation	35111	Producing electricity through power plants using various energy sources. Fossil fuels (coal, gas, fuel oil, and diesel) / Renewable energy (geothermal energy, wind, bioenergy, sunlight, water flows, and waterfalls), and the movement and temperature differences of ocean layers.	High	IUPTL (Electricity Supply Business Permit)  a. An electricity purchase agreement between the applicant and the prospective buyer b. Feasibility study of the electricity supply business c. Fulfilling Basic Infrastructure Commitments according to Business needs (AMDAL / PKKPR)
Software publishing	58200	Publishing ready-to-use (not custom-made) software, such as operating systems, business and other applications, and video games for all operating system platforms.	High	a. Located in an Industrial park / obtain an industrial park exception license b. Registered with the National Industrial System (SIINAS)
Web Portals and/or Digital Platforms with Commercial Purposes (e-commerce)	63122	Operation of commercial websites and digital platforms that provide searchable internet databases, act as online portals with regularly updated content, or facilitate electronic transactions for goods, services, and other offerings, including ordering, payment, and delivery	Medium High	PPMSE License a. Own a Web Portals and/or Digital Platforms for Commercial Purposes; b. Located in an Industrial park / obtain an industrial park exception license c. Registered with the National Industrial System (SIINAS)
Wholesale Trade of Pharmaceutical Drugs for Humans	46441	Wholesale trade of pharmaceutical drugs for household use, such as medicines and health supplements for humans.	High	a. Facility / Warehouse Registration (CDOB) b. Product Registration to BPOM
Wholesale of Other Food and Beverages	46339	Includes wholesale trade of various foods and beverages, such as flours (rice, tapioca), bakery mixes, caramel, processed honey, snacks (like shrimp crackers), cereals and cereal-based products, soy drinks, ready-to-eat foods, food for special nutrition (babies, children, adults), food additives, processing aids, as well as wholesale trade of pet food and animal feed.	Low	N/A
Petroleum Mining	06100	Crude oil mining activities include efforts to search for petroleum deposits, drilling, mining, reconnaissance and storage, production of crude oil condensate, processing to produce crude oil by means of storage, filtering, drying, stabilization and others. The results of petroleum mining include crude oil or crude oil and condensate.	High	a. Ministerial Decree for the Determination of Contractors for New Oil and Gas Working Area Cooperation Contracts; b. Submitting Implementation Guarantees. c. Proof of Signature Bonus deposit;
Land Transport Services	49211	transportation business using double-decker, maxi, large, medium and/or small public bus motor vehicles based on a specific schedule and on designated AKAP routes.	Medium High	a. Partnership agreement with Maintenance Facility b. Prepare a business plan for a Public Transportation Company; c. Preparing Safety Management System documents; d. Have at least 5 (five) vehicles as evidenced by a copy of the STNK, SRUT (for new vehicles) e. Implementing an electronic ordering system; f. Own and/or control storage space; g. Meet the Minimum Service Standards for passenger transportation on the route; h. Installing electronic vehicle movement monitoring devices.
Domestic Sea Transportation for Tourism	50113	transportation business for tourism or recreation at sea, and/or marine tourism. Including the business of renting sea transportation and its operators.	High	a. SIOPSUS (special operating business permit) b. Tourism Certificate Standard c. Health Certificate
Wired Telecommunications Services	61100	Providing and maintaining facilities for sending voice, data, text, sound, and video through telecommunication cables. This includes running and maintaining transmission systems for landlines, microwaves, data or satellite links, cable networks for data and TV distribution, and telegraph or other non-voice communication services using own facilities.	High	Network provider license a. Have no outstanding Non-Tax State Revenue obligations b. Telecommunication network implementation plan c. Implementation of Operational Feasibility Test d. Obtaining telecommunications numbering assignment e. Prove that the Directors, Management and/or Legal Entity of the Business Actor are not included in the Blacklist.
Wireless Telecommunications Services	61200	Covers operating networks that provide mobile telecommunication services using cellular technology. This includes running and maintaining wireless systems for voice, data, text, sound, and video transmission, as well as managing paging services.	High	Mobile Cellular Network Operation Permit a. Have no outstanding Non-Tax State Revenue obligations b. Telecommunication network implementation plan c. Implementation of Operational Feasibility Test d. Obtaining telecommunications numbering assignment e. Prove that the Directors, Management and/or Legal Entity of the Business Actor are not included in the Blacklist.
Animal Feed Concentrate Industry	10802	includes the business of making concentrated feed for livestock, poultry, and other animals. The processing of concentrated feed for livestock, poultry, and other animals that cannot be separated from livestock businesses is included in group 014 (Livestock).	High	Operational License a. Located in an Industrial park b. Fulfillment of the SNI of steelRegistered with the National Industrial System (SIINAS)
Battery Industry for Electric Motor Vehicles	27203	usaha pembuatan segala macam baterai untuk kendaraan bermotor listrik.	High	Operational License a. Located in an Industrial park b. Fulfillment of the SNI of steel c. Registered with the National Industrial System (SIINAS)
Private Hospital Activities	86103	includes health care and physical treatment activities, both for outpatient and inpatient care, carried out by private general hospitals, private maternity hospitals, private specialist hospitals.	High	Private Hospital License
Health Support Service Activities	86903	Includes health support services provided by the government or private sector, such as medical labs, stem cell labs, pharmaceutical warehouses, eye and blood banks, sperm and organ banks, tissue banks, optical services, and other medical support activities.	High	Medical Laboratory Permit

For a more comprehensive list, it is advisable to refer to the Appendices of Presidential Regulation No. 10/2021 or contact Emerhub’s business advisors using the form below. 

Business Facilities Offered by the Indonesian Government

The Positive Investment List prioritizes industries that are considered critical sectors for Indonesia’s economic development. This includes 245 business fields including manufacturing, renewable energy, digital economy, infrastructure, healthcare, and pharmaceuticals. Foreign investors can own 100% as well as qualify for the following incentives: 

To qualify for these business facilities, your business must meet one or more of the following criteria:

• Be labor intensive (employs ≥ 200 workers; labor costs ≥ 15% of production costs)
• Be capital intensive (≥ IDR 100 billion or ~USD 6.9 million investment capital)
• Be part of a national project or program,
• Be export-oriented,
• Involve a pioneer industry (such as renewables, oil refining, metals),
• Utilize advanced technologies,
• Implement research and development (R&D) activities.

Sectors that Remain Restricted or Closed

While sectors like e-commerce and telecommunications have been opened to 100% foreign ownership, there are still industries that have restrictions or are completely closed off. These restrictions and foreign investment caps ensure sensitive sectors have a strong domestic presence as well as integration with local MSMEs (Micro, Small, and Medium Enterprises). 

Here’s an overview of sectors that have specific requirements for FDI: 

Category	Details	Sector / Business Line
Requires Mandatory Partnerships with MSMEs	Aims to integrate MSMEs into larger supply chains and support their development. This includes traditional or simple technology industries.	– Traditional food processing – Handicrafts – Small-scale manufacturing – Labor-intensive cultural products – Some agricultural activities
Sectors with Specific Ownership Limitations	Includes sectors that are open to foreign investment in principle, but have special restrictions such as foreign ownership caps (often at 20-49% depending on the sector), mandatory licensing/approval from certain ministries, or other conditions.	– Publishing and broadcasting agencies – Postal services – Domestic air and sea transportation – Certain defense-related industries – Traditional medical products, fish processing, wood-based products, handicrafts – Construction

Meanwhile, there are 6 sectors that remain fully closed to both foreign and private domestic investment due to their sensitive nature. These sectors are reserved for government control or prohibited outright:

• Cultivation and industry of Class I narcotics (illegal drugs),
• All forms of gambling and casino operations,
• Fishing or harvesting of endangered species listed under CITES Appendix I,
• Extraction and utilization of natural corals from reefs (for souvenirs, building materials, jewelry, aquariums),
• Chemical weapons manufacturing industry,
• Industries producing ozone-depleting substances (certain harmful chemicals).

Additionally, defense and security-related activities are reserved exclusively for the government. Private companies are not allowed to undertake these activities, except in partnership with the government.

What Does This Mean for Foreign Investors in Indonesia?

The most immediate change is clear: you can now fully own businesses in sectors that were previously closed off. 

If your company is already registered under a classification that now allows foreign ownership, you can start acquiring the rest of the local shares through a company restructuring process as follows:

1. Hold a General Meeting of Shareholders to acquire local shares in the company. If locally held shares exceed 50%, a newspaper announcement needs to be formally published. 
2. Prepare for the transfer transaction through a notarial purchase and sell the deeds. If a Loan Agreement was used to acquire Pledged Shares from the local shareholders, then this must first be voided.
3. Get approval from the Ministry of Law and Human Rights for the change in shareholding structure.
4. Update the shareholding structure in all other other company licenses through Indonesia’s government OSS system.

Whether you’re entering a new sector or restructuring your existing company, Emerhub can guide you through the process. Our experts can help you select the right business classification (KBLI), structure your investment, and manage the entire company setup on your behalf.

Want to establish a business under Indonesia’s Positive Investment List? Talk to our consultants by filling out the form below.