TL;DR
Indonesia 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.
The Facts
Indonesia 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.
Bali Zero Take
The Hidden Insight
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 governm
Our Analysis
ent'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
Our Advice
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.
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