TL;DR
**## The opportunity—and the important caveat
Indonesia is refining how its foreign-investment threshold applies to public electric vehicle charging st**
The Facts
The opportunity—and the important caveat
Indonesia is refining how its foreign-investment threshold applies to public electric vehicle charging stations, known as SPKLU.
BKPM materials indicate that the minimum investment value for a foreign-owned SPKLU business is more than IDR 10 billion, excluding land and buildings, within one province. This can make a network of charging points more commercially realistic than applying the threshold independently to every location.
However, investors should not interpret this as the IDR 10 billion requirement being abolished. They should also verify the final enacted regulation and its implementation in OSS before relying on the province-wide calculation for an investment decision.
Why the location calculation matters
A charging network is different from a conventional single-site business. One charging point may not require enough equipment to reach a large investment threshold, while a commercially viable network may involve many smaller sites.
A province-wide approach allows the investment plan to reflect the economics of a network. For example, several SPKLU locations within Bali may potentially be assessed as one provincial investment plan rather than as unrelated IDR 10 billion projects.
The distinction affects capital planning, project phasing, location selection, and how the business records its commitments in OSS and investment reports.
What the BKPM material says
A BKPM urgency paper for the risk-based business licensing regulation describes a minimum SPKLU investment value of more than IDR 10 billion, excluding land and buildings, in one province. It also recognises that a standalone SPKLU point may not realistically exceed that amount by itself.
That source is important, but it is a policy and regulatory-development document. The final legal instrument, sector rules, OSS configuration, and the company's approved investment plan remain decisive.
What foreign investors still need to verify
The investment threshold is only one part of the setup. A prospective operator should also confirm:
- the correct KBLI classification for the planned activities;
- whether the company will own, operate, lease, or merely provide technology to the charging network;
- foreign ownership eligibility for every activity;
- electricity-sector licences and technical standards;
- land or site agreements for each charging point;
- cooperation requirements with PLN or other relevant parties;
- environmental and construction approvals;
- how investment values are allocated and reported in OSS and LKPM; and
- whether all locations can legitimately be grouped within one provincial project.
A network operating across Bali and another province may require separate calculations or project treatment.
Practical structuring questions
Before incorporating or adding the activity to an existing PT PMA, investors should prepare a location map, equipment budget, operational model, and phased investment schedule. The documents should tell the same story across the deed, NIB, OSS project data, sector licences, and LKPM reporting.
Avoid basing the company structure on a headline that says the per-site rule has been “scrapped.” The safer conclusion is that BKPM has recognised the network nature of SPKLU investment and is moving toward a province-level assessment, subject to the final rules and system implementation.
Bali Zero take
The policy direction is positive for EV-infrastructure investors, particularly in areas such as Bali where a useful charging network requires multiple distributed locations. But the commercial benefit depends on careful licensing and investment-plan execution.
Bali Zero can help coordinate the corporate and OSS review while the investor obtains technical and sector-specific advice.
Sources: BKPM urgency paper for the proposed risk-based licensing regulation and Warta Ekonomi report on BKPM's SPKLU explanation. Verify the final regulation and OSS treatment before committing capital.
Bali Zero Take
The Hidden Insight
The policy direction is positive for EV-infrastructure investors, particularly in areas such as Bali where a useful charging network requires multiple distributed locations. But the commercial benefit
Our Analysis
depends on careful licensing and investment-plan execution.
Bali Zero can help coordinate the corporate and OSS review while the investor obtains technical and sector-specific advice.
*Sources: [BK
Our Advice
PM urgency paper for the proposed risk-based licensing regulation](https://jdih-storage.bkpm.go.id/jdih/jdih/Naskah-Urgensi-Rapermen-PBBR-%28OSS%29-.pdf) and Warta Ekonomi report on BKPM's SPKLU explanation. Verify the final regulation and OSS treatment before committing capital.*
Next Steps
Action Items
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