Loading Zantara...
Zantara AI
AI Research Assistant
Zantara AI
AI Research Assistant
Bali Zero handles visas, company setup, tax and property compliance in Indonesia. Ask us directly on WhatsApp.
Chat with Bali Zero on WhatsAppIndonesia is moving forward with a sweeping reclassification of its official business activity codes — the Klasifikasi Baku Lapangan Usaha Indonesia (KBLI) — updating the system to its 2025 edition. To manage the changeover, the government has produced a Joint Circular Letter (Surat Edaran Bersama, or SEB) that sets out the practical rules governing how businesses transition from their existing codes to the new framework.
The circular establishes three core principles for the transition. First, licenses already issued under the old KBLI system remain legally valid and do not require immediate replacement. Second, changes to business codes that do not alter the underlying nature of a business activity may be converted automatically by the system, with no manual intervention required from the business owner. Third, the government has targeted full integration between the Online Single Submission (OSS) platform — Indonesia's centralised business licensing portal — and the General Legal Administration system (Administrasi Hukum Umum, or AHU), which sits under the Ministry of Law and Human Rights.
The SEB operates within a broader regulatory framework anchored by Government Regulation No. 28 of 2025 (PP 28/2025), which provides the overarching legal basis for risk-based business licensing in Indonesia. The circular is intended as a more granular operational guide to help businesses, regulators and system operators navigate the KBLI 2025 migration in concrete terms.
However, on-the-ground implementation is proving more complex than the policy documents suggest. Legal practitioners working with businesses directly report that data validated and accepted in one government system does not always transfer cleanly into the next, raising questions about whether the promised OSS-AHU integration is functioning as intended for all business types.
A key source of confusion is the distinction between two separate actions available in the OSS interface: 'adjusting existing business activities' (penyesuaian kegiatan usaha eksisting) and 'adding a new business activity' (tambah kegiatan usaha). For businesses already in operation, the correct route is the conversion pathway — not the 'add new' function. The OSS system treats these as categorically different processes, and selecting the wrong one can create an entirely new business activity record rather than updating an existing one, with far-reaching administrative and compliance consequences that are not immediately visible to the business owner at the point of submission.
For our clients, the KBLI 2025 transition is a classic Indonesian regulatory update that looks tidy from the ministerial level and becomes considerably messier the moment you log into OSS. The government's assurance that old licenses 'remain valid' is genuinely good news — no one should be panicking about immediate revocation. But the automatic conversion promise deserves scrutiny: it applies only to code changes that are substantively neutral, and the system's definition of 'neutral' may not match your intuition.
The migration-versus-addition distinction is where we are already seeing clients stumble. Choosing the wrong OSS pathway is not a minor clerical error — it can mean your existing business activity loses its approval trail entirely, and you find yourself in a queue to establish what is effectively a brand-new activity on paper. In Bali, where sectors such as hospitality, wellness, creative industries and property services often sit across multiple KBLI codes, the risk of an inadvertent mis-click is real and the remediation process is time-consuming.
The integration between OSS and AHU remains a work in progress. Until that link is fully tested and stable, businesses should resist the temptation to self-serve through the system without first verifying how their specific codes are mapped under KBLI 2025.
Every business operating in Indonesia — regardless of whether the owner is a local citizen or a foreign investor holding a PT PMA — should treat the KBLI 2025 transition as an active compliance task, not a background administrative event. The most immediate practical implication is that business owners need to identify which of their current KBLI codes are affected by the reclassification. Not all codes are changing; some are being merged, split, or renamed, and each of those scenarios carries a different OSS procedure.
For businesses whose codes are changing in name only — with no substantive shift in what the company is legally permitted to do — the system should, in principle, handle the conversion automatically. However, that automation is only as reliable as the OSS-AHU integration, which is still described as a target rather than a completed state. Relying on automation without follow-up verification is a risk. Any business that holds an NIB (Nomor Induk Berusaha), sector-specific permits, or certificates tied to a KBLI code should log in to OSS and confirm that their records reflect the correct KBLI 2025 designations before making any changes to their business operations or attempting to renew or expand their licensing.
First, log in to the OSS system and retrieve your current NIB and business activity records. Note every KBLI code associated with your company. Second, cross-reference those codes against the KBLI 2025 mapping table (available through the BPS — Badan Pusat Statistik — and mirrored in OSS guidance materials) to determine which, if any, have changed. Third — and this is critical — do not click 'Add New Business Activity' if your goal is to update an existing one. That is the wrong pathway. If you need to adjust an existing activity, use the 'penyesuaian kegiatan usaha' function. Fourth, if your company has multiple KBLI codes or operates in a regulated sector (tourism, healthcare, education, food and beverage), consult a licensed legal advisor or business consultant before touching anything in OSS. The cost of professional guidance is far lower than the cost of unwinding a misfiled activity record.