-

Andi Refandi
Andi serves as a Senior Account Executive on Emerhub’s global team.
Indonesia has officially transitioned to a new business classification system under Regulation No. 7 of 2025, known as KBLI 2025. This update replaces the 2020 version and requires all businesses (both local PTs and foreign-owned PT PMAs) to update their KBLIs within the 6-month time frame.
As a business owner, you are required to align your company’s legal classifications with these new codes before the June 18, 2026 deadline. Failure to act will result in your Business Identification Number (NIB) being flagged or blocked in the OSS system.
This guide breaks down what has changed and the steps you need to take to stay compliant.
Overview of KBLI Structural Changes in 2025
The KBLI 2025 update significantly expands the number of available business codes to reflect Indonesia’s growing digital and green economies. The transition involves an increase in granularity across all levels of classification.
| Metric | KBLI 2020 | KBLI 2025 (New) | Change Description |
|---|---|---|---|
| Categories (Sections) | 21 Categories | 22 Categories | Added Section V for Carbon & Environment. |
| Groups (3-Digits) | ~514 Groups | 524 Groups | New clusters for specialized tech and services. |
| Sub-Groups (4-Digits) | ~1,324 Sub-Groups | 1,364 Sub-Groups | Finer distinction between service types. |
| Total 5-Digit Codes | 1,790 Codes | 1,933 Codes | +143 New Codes added to the system. |
Here are major changes you should know about:
- The Introduction of Environmental and Carbon Market Services (Section V): this KBLI aims to support Indonesia’s Net Zero targets and carbon exchange goals.
- Activity-Based Digital Codes: A definitive move away from generic “Web Portal” classifications to codes that reflect the actual service provided (e.g., travel booking, retail intermediation, or media streaming).
- Recognition of Deep Tech and AI: New, dedicated codes for Artificial Intelligence (AI) programming, autonomous systems (UAVs/Drones), and blockchain-related assets.
- Unified Retail Coding: The elimination of the distinction between online and offline sales, treating all retail as product-centric rather than channel-centric. (e.g., selling electronics via an app now uses the same code as a physical electronics store).
- Simplified F&B Classifications: Restaurants and cafes are now distinct based on how permanent the establishment is rather than the menu served.
This structural expansion is driven by the need to align with the International Standard Industrial Classification (ISIC) Revision 5. By providing more specific codes, the government aims to give businesses more legal certainty while making it easier for regulators to monitor specific industries.
Significant KBLI Reclassifications in Indonesia
Under new KBLI Regulation No. 7 of 2025, some KBLIs have been reclassified or removed to clarify specific business activities and make way for new digital economies. We recommend reviewing your current KBLI codes if you belong in the restaurant or cafe industry or e-commerce.
Stricter Supervision of PT PMA Companies in Bali (2026)
Stricter supervision measures will be implemented for PT PMA companies operating in Bali. This is following recent socialization sessions conducted by the Ministry of Investment (BKPM) and the Bali Provincial Government.
Field inspections and full regulatory enforcement are expected to begin by June 2026.
This supervision particularly targets:
- PT PMA under low and medium–low risk KBLI classifications
- PMA companies using Virtual Office addresses in Bali
- PMA entities that have not demonstrated actual investment realization
The regulatory focus has shifted toward substance-based compliance. This means, authorities will evaluate whether the company’s operational activities reflect its registered KBLI and declared investment value.
These following KBLI are under strict monitoring in Bali:
- 68111 (Real Estate) are now under strict review. Authorities have identified misuse of this KBLI for small-scale villa developments that do not meet foreign investment capital standards. Authorities will be focused on examining the following:
- Residential (Hunian): Private dwellings used solely for residence
- Mixed-Use Residential (Hunian Campuran): Residential property combined with commercial use (e.g., ruko, rukan)
- 70209 (Management Consultancy) New PMA companies cannot activate KBLI 70209 in Bali using a Virtual Office address. Virtual Offices are no longer considered sufficient proof of operational presence. Existing PMA entities remain subject to supervision and inspection, especially regarding compliance with the minimum IDR 10 billion investment realization requirement.
For KBLI 68111 (Real Estate), authorities have identified misuse of this KBLI for small-scale villa developments that do not meet foreign investment capital standards. You could face the following:
- Field inspections
- Verification of actual project scale
- Review of investment realization value
- Administrative sanctions if non-compliant
- Direction to restructure to hotel-related KBLI
- Requirement to convert to a domestic investment company (PMDN) if PMA status is unjustified
To enforce these changes, the government will issue an administrative warning, followed by temporary suspension of business license, and its revocation. Non-compliance to proper KBLI in this sector can affect your OSS licensing updates, NIB status, and future business expansions.
The Removal of KBLI 6312 (Web Portals and Digital Platforms)
In the 2020 version, KBLI 6312 was a “catch-all” code for almost any digital business. Whether you ran an e-commerce site, a news portal, or a booking app, 6312 was often the default choice.
Under KBLI 2025, KBLI 6312 has been removed. Digital platforms are no longer classified by the technology they use (the “portal”). Instead, they are now classified by the actual service they provide.
For example:
- An online travel booking platform is now classified under the tourism or accommodation sector.
- A digital retail platform is now classified under retail trade intermediation.
The Removal of KBLI 4791 (Online Retail)
Previously, businesses that sold goods exclusively online used KBLI 4791. The 2025 regulation has removed this because the government no longer wants to differentiate retail trade based on the location of the sale (online vs. offline).
You must now choose codes based on the products you sell. If you sell electronics, you use the electronics retail code, regardless of whether you sell them in a physical shop or via an app.
For example, an online store selling high-end laptops and gaming peripherals. Under the 2020 rules, this company is likely registered under KBLI 47911 (Retail Sale via Mail Order or Internet). With the 2025 update, this company must now change its classification to KBLI 47411 (Retail Sale of Computers and Computer Peripheral Equipment).
This shift means the business is now regulated as a computer retailer first, rather than a “tech platform.” If they also decide to open a small showroom in a mall later, they no longer need to add a new KBLI, since their code now covers the product category regardless of the sales channel.
F&B Sector Simplification (The End of “Cafes”)
The food and beverage sector has been simplified by removing the confusing distinction between menus. Under the previous KBLI 2020, businesses often struggled to choose between a “Restaurant” (56101) and a “Cafe” (56303), since the difference was based on whether you served “full meals” or just “snacks and drinks.”
The KBLI update in 2025 removes this ambiguity by focusing on the physical nature of the setup rather than the menu. The classification is now split into two primary categories:
- 56101 (Permanent Location): This covers any establishment—be it a restaurant, cafe, or buffet—that operates out of a permanent, fixed building.
- 56102 (Non-Permanent/Mobile Location): This is for businesses with a mobile or semi-permanent setup, such as food trucks, street stalls (warung), or portable booths.
This shift provides much more clarity since they no longer have to justify their business model based on the specific items they sell, but simply by where they operate.
New Business Categories and Codes
KBLI 2025 introduces several new codes to accommodate the modern economy. By introducing new sectors in technology and the digital economy, the government is moving away from “residual” codes that described these sectors as legal gray areas.
Digital Content and Creators
The 2020 version had no specific codes for content creators. Many creators had to use generic “other services” codes. KBLI 2025 now explicitly includes:
| Business Activity | KBLI Code | Description of Business Activity |
|---|---|---|
| Audio Podcast Creation | 5920 | Activities involved in the planning, recording, and post-production editing of episodic audio content intended for digital distribution. |
| Video Podcast Creation | 5911 | The production and studio-based recording of audiovisual talk shows or interviews primarily distributed via video-sharing platforms. |
| On-demand Audio Streaming | 6010 | The operation of digital libraries or applications that allow users to play or download music, podcasts, and audiobooks on demand. |
| On-demand Video Streaming | 6020 | The hosting and distribution of video-on-demand content (VOD) through Over-The-Top (OTT) platforms and internet-based libraries. |
Dedicated Codes for AI and Emerging Technology
As AI becomes a standard part of software development, the government has introduced specific codes for AI-based software publishing and the development of autonomous systems.
Here are key examples of KBLIs in this sector:
| Business Activity | KBLI Code | Description of Business Activity |
|---|---|---|
| Artificial Intelligence Programming | 62015 | Development, consultation, and programming of systems using AI technologies such as machine learning, natural language processing (NLP), and expert systems. |
| Software Publishing | 58200 | Publishing and distribution of ready-made software products that integrate Artificial Intelligence for general business or consumer use. |
| UAV/Drone Manufacturing | 30303 | The manufacturing, assembly, and integration of specialized hardware and flight control systems for Unmanned Aerial Vehicles (UAVs). |
| Drone-Based Technical Mapping | 74902 | Specialized technical surveying and geospatial mapping activities utilizing drone technology for data collection and analysis. |
Institutionalizing Crypto-Assets and Trading
While crypto was previously handled through specific Bappebti regulations, it now has its own formal KBLI codes. This provides the banking sector with the confidence to process transactions for these entities, as their NIBs will now reflect recognized financial activities. There are now distinct codes for:
| Business Activity | KBLI Code | Description of Business Activity |
|---|---|---|
| Proprietary Trading of Crypto Assets | 64994 | Engaging in the buying and selling of crypto assets using the company’s own capital for its own account. |
| Operating Crypto Asset Exchanges | 6611 | The provision and operation of digital platforms for the exchange of crypto assets between different parties. |
| Crypto Asset Brokerage Services | 6612 | Acting as an intermediary in the purchase and sale of crypto assets on behalf of clients. |
| Issuance of Crypto Assets with Liabilities | 64999 | Financial service activities related to the creation and issuance of crypto assets that carry specific obligations or liabilities. |
Supporting Green Energy and Carbon Markets
To support Indonesia’s carbon exchange goals, there are now specific classifications for Carbon Capture and Storage (CCS) and Carbon Credit Trading. These codes fall under the new Section V, highlighting Indonesia’s commitment to environmental sustainability and the development of a formalized carbon credit ecosystem.
Here are some examples of KBLI codes for carbon markets:
| Business Activity | KBLI Code | Description of Business Activity |
|---|---|---|
| Carbon Capture | 39001 | Industrial activities focused on the separation and capture of CO2 from industrial or atmospheric sources. |
| Carbon Storage | 39002 | The process of injecting and permanently storing captured CO2 in geological formations or under the seabed (CCS/CCUS). |
| Carbon Credit Trading | 64995 | The commercial trading of carbon units or emission reduction certificates on regulated or voluntary exchanges. |
| Carbon Brokerage & Exchanges | 6611 | Provision of infrastructure and intermediary services for the systematic exchange of carbon credits. |
Note: For integrated projects, such as power plants (KBLI 35111) or forestry (KBLI 01 & 02), the sale of carbon units is often included as a sub-activity within their primary sectoral codes.
Sector-Specific Impacts for Investors and Developers
The new KBLI structure provides specific advantages for high-growth sectors by refining classifications for real estate, manufacturing, and logistics. These updates offer businesses legal clarity, potential tax benefits, and more accurate regulatory alignment.
Property Management and Real Estate Clarity in Bali
Many foreign investors in Bali own property management or villa rental companies. Under KBLI 2020, KBLI 68111 was the standard for real estate activities.
On the other hand, updates from 2025, this sector has become more detailed. It now distinguishes strictly between:
- Residential vs. Non-Residential: You must specify if you are dealing with houses/apartments or offices/malls.
- Developers vs. Managers: There is a clearer split between companies that build and sell property and companies that lease and manage it.
For example, if you are an existing client in Bali currently using KBLI 68111 for villa management, you will likely need to transition to KBLI 68112 under the new framework. This ensures that your license specifically covers property management rather than general real estate activities.
The Rise of Factoryless Manufacturing (FGP)
This is one of the most significant wins for brands that do not want to own a factory. Previously, if you designed a product (like clothing or electronics) but hired a third party to manufacture it, you were often stuck in a “trading” KBLI.
KBLI 2025 now officially recognizes Factoryless Goods Producers (FGP) under Category C (Manufacturing). This allows brands to be classified as manufacturers even if they outsource the physical production. This can provide tax benefits and better access to certain import/export facilities.
Refining Logistics and Transportation Support
Group 523 (general umbrella for transportation support) is now split for more clarity. The 2025 KBLI update creates a distinct separation based on the subject of transportation, which directly impacts which sectoral regulations and safety standards a company must follow.
- KBLI 5231 (Cargo Intermediation): Specifically for freight and goods.
- KBLI 5232 (Passenger Intermediation): Specifically for passenger transport.
If you run a logistics app or a ride-hailing service, you must now choose the code that matches your primary user base (goods vs. people). This distinction ensures that cargo-focused startups are not burdened with passenger safety regulations, and vice versa, providing a more tailored regulatory environment for each.
What You Should Do to Comply with New KBLI 2025 Codes?
Because KBLI codes are written into your company’s Articles of Association (AOA), changing them requires a formal legal process. Together with our team of local experts in Indonesia, we can help you do the following:
- Gap Analysis: We can review your current 2020 codes against the 2025 list. We can identify if your codes are still valid for your business activity or you need to switch.
- Notarial Deed of Amendment: We can help connect you with a notary to draft the amendment to your company’s AoA. This document formally lists the new KBLI codes your company will use.
- Ministry of Law Approval: Once the deed is signed, we can submit the AoA to the Ministry of Law and Human Rights (MoLaw) and receive an official approval letter (SK Mentri). This usually takes 3 to 5 working days.
- OSS RBA Update: We can update your KBLIs directly to your OSS account. The system should ideally sync with the MoLaw data, but you often need to manually update the project details to reflect the new codes and ensure your NIB is reissued correctly.
If you need help updating your KBLIs in Indonesia, our local experts can help coordinate this process. Fill out the form below for a free consultation.
Common FAQs About KBLI 2025
Not every single company, but most will need to. If your current KBLI 2020 code was deleted, split, or significantly re-described in the 2025 version, you must update it. Even if the code number remains the same, the scope of the activity may have changed, affecting your risk level or permit requirements.
In Indonesia, the business activities (KBLI) are part of the company’s formal Articles of Association. To change the activities on your NIB, you must first amend the corporate deed via a notary and get approval from the Ministry of Law.
The transition period is six months from the regulation’s effective date, ending on June 18, 2026. After this date, any NIB that has not been aligned with KBLI 2025 may be considered invalid for licensing and reporting purposes.
Existing licenses remain valid during the transition period. However, you cannot renew, amend, or apply for new permits until you have synchronized your KBLI codes to the 2025 version.
The LKPM system is integrated with your KBLI codes. If you are reporting investments for a KBLI code that no longer exists in the 2025 framework, the system may reject your submission. This could lead to administrative sanctions from BKPM.


