KBLI 2020 to 2025 Migration Guide: Post-Deadline Classification Remediation

The Classification Reset

On paper, migrating from KBLI 2020 to KBLI 2025 sounds straightforward: find your old code, look up the new one, update your records. In practice, it is anything but. BPS Regulation No. 7 of 2025 did not simply renumber existing codes. It restructured the entire classification hierarchy, aligned it with the international ISIC Revision 5 standard, and fundamentally changed how Indonesia categorizes economic activity.

The result: KBLI 2020's approximately 1,790 five-digit codes have been reorganized into roughly 1,562 five-digit codes under 22 categories (up from 21). Some codes survived intact. Many were split into finer-grained activities. Others were merged, consolidated, or eliminated entirely. The June 2026 transition window has closed.

This guide walks you through exactly what changed, how to find your new code, and what to do when there is no clean one-to-one match. If you are new to KBLI entirely, start with our Beginner's Guide to KBLI 2025 first, then return here for the migration specifics.

The Four Types of Code Changes

Every KBLI 2020 code falls into one of four migration scenarios. Understanding which scenario applies to your business determines your migration strategy.

1. Direct Mapping (1:1)

The simplest case. Your old KBLI 2020 code has a single, direct equivalent in KBLI 2025. The code number may have changed, but the activity description remains substantially the same.

Action required: Update the code in your records. No additional analysis needed.

Example: Basic retail activities, standard manufacturing categories, and simple agricultural codes often have direct mappings. The BPS concordance table will show a single arrow from old to new.

2. Split Codes (1:Many)

This is the most common and most consequential change in KBLI 2025. One broad KBLI 2020 code has been split into multiple, more specific KBLI 2025 codes. You must choose the code that most precisely describes your actual business activity.

Action required: Review all new codes derived from your old one. Select the most specific match based on what your company actually does — not what your old code generically covered.

Real estate example: Under KBLI 2020, the real estate sector was covered by roughly 5 codes. KBLI 2025 expands this to 14 codes — a 180% increase. A company previously classified under a general "real estate activities" code must now determine whether it is engaged in residential property development, commercial property management, land subdivision, real estate brokerage, or property valuation services. Each has its own code, its own risk level, and its own licensing requirements.

IT and telecommunications example: KBLI 2020's Category I (Information and Communication) has been bifurcated into two entirely new categories:

If your company was classified under Category I, you now need to determine whether your primary activity falls under content/publishing (J) or technology/IT services (K). A digital agency that both produces content and builds software may need codes from both categories.

3. Merged Codes (Many:1)

The inverse of splitting. Multiple KBLI 2020 codes have been consolidated into a single KBLI 2025 code. This typically happens when BPS determined that previous distinctions were unnecessarily granular or no longer economically meaningful.

Action required: Confirm the new unified code covers your activity. If your company held multiple old codes that now merge into one, you may be able to simplify your NIB by listing fewer codes.

4. Deprecated Codes (1:0)

Some KBLI 2020 codes have no direct equivalent in KBLI 2025. The activity was either absorbed into a broader category, reclassified under an entirely different section, or deemed obsolete.

Action required: This is the most complex scenario. You must analyze your actual business operations and find the closest matching KBLI 2025 code. In some cases, you may need professional guidance to determine the correct classification, especially if the deprecated code straddles multiple new categories.

How to Find Your New KBLI Code

Follow this systematic process to map every KBLI 2020 code on your NIB to its KBLI 2025 equivalent.

Step 1: Inventory Your Current Codes

Pull your current NIB from the OSS system. List every KBLI 2020 code registered to your company. For each code, note:

• The five-digit code number
• The activity description (in Bahasa Indonesia)
• Whether the activity is actually being conducted

This last point matters. Many companies registered "aspirational" codes during initial setup that they never actually used. The migration is an opportunity to clean up your NIB.

Step 2: Consult the BPS Concordance Table

BPS publishes an official concordance table (tabel korespondensi) mapping KBLI 2020 codes to KBLI 2025 codes. This is your primary reference document. For each of your codes, the table will show one of the four scenarios described above.

Step 3: Validate Against Your Actual Operations

For split codes and deprecated codes, do not simply pick the first option in the concordance table. Match the code to what your business actually does on the ground. The wrong code can result in:

• Incorrect risk classification — triggering unnecessary permits or inspections
• Foreign ownership restrictions — some new codes have different PMA thresholds
• Tax misalignment — your KLU (tax classification) derives from your KBLI, affecting tax benchmarks and reporting obligations
• Import license issues — API-U vs. API-P eligibility depends on your KBLI category

For a deep dive on how KBLI and KLU interact with fiscal policy, see our KBLI-KLU Fiscal Control analysis.

Step 4: Document Your Mapping Decisions

For every code where the mapping is not a simple 1:1, create a written justification explaining why you selected a particular KBLI 2025 code. Include:

• The old code and its description
• The new code and its description
• A brief explanation of why this code matches your operations
• Supporting evidence (company profile, SIUP, operational permits)

This documentation serves two purposes: it protects you during any regulatory audit, and it provides a clear record for your accountant and legal team.

Step 5: Prepare the Update Package

Compile your complete code mapping into a single document. This becomes the instruction set for whoever verifies or remediates the update in the current OSS workflow. Include:

• Old code → New code mapping table
• Supporting justifications for non-obvious mappings
• Any codes to be removed (activities no longer conducted)
• Any new codes to be added (new activities enabled by KBLI 2025)

The OSS Transition: Verify Now, Remediate Through the Live Workflow

OSS readiness must be verified live before execution. Do not rely on February 2026 portal behavior when making a July 2026 filing decision.

This creates a strategic window. The June 2026 transition window has closed. Treat any unresolved KBLI 2020-to-2025 mapping as overdue, but still verify the current OSS workflow before filing. The smart approach:

Companies that wait until a blocked transaction will face a bottleneck. Having your mapping ready in advance means you can verify and remediate through the current OSS workflow in hours, not weeks.

What Happens If You Miss the Deadline

The June 2026 transition window was not symbolic. If your NIB still relies on KBLI 2020 codes, expect friction with:

• New permit applications — any new license or permit will require KBLI 2025 codes
• LKPM reports — your quarterly investment activity report must use the new classification
• Import approvals — customs and trade ministry systems will reference KBLI 2025
• License renewals — when your existing permits come up for renewal, the old codes will not process
• Tax administration — DJP alignment with KBLI 2025 affects your KLU and tax benchmarks

Your existing permits will not evaporate overnight. But any new regulatory interaction — filing a report, renewing a license, applying for an import quota — will require the updated codes. The practical effect is that a company stuck on KBLI 2020 codes after the deadline cannot conduct normal business operations.

Special Considerations for Foreign-Owned Companies (PT PMA)

The migration carries additional implications for PT PMA entities:

Foreign ownership thresholds may change. When a code splits, the resulting new codes may have different entries in the Daftar Negatif Investasi (DNI) or the new Positive Investment List. A PT PMA that was 100% foreign-owned under a broad KBLI 2020 code needs to verify that the specific KBLI 2025 code it migrates to still permits 100% foreign ownership.

Investment plan alignment. Your BKPM-approved investment plan references specific KBLI codes. A code change may trigger the need to update your Rencana Penanaman Modal (investment plan) through BKPM, particularly if the new code falls under a different sector classification.

RPTKA implications. Your foreign worker quota (RPTKA) is tied to your KBLI codes. A migration to a different sector category could affect your approved positions and ratios.

For a broader understanding of how KBLI 2025 creates strategic opportunities for foreign investors, read our analysis of the KBLI 2025 Gold Rush.

Step-by-Step Migration Checklist

Use this as your operational checklist:

1. Export your current NIB from OSS — capture all registered KBLI 2020 codes
2. Obtain the BPS concordance table — the official KBLI 2020 to 2025 mapping document
3. Classify each code into one of the four scenarios: direct mapping, split, merged, or deprecated
4. For split codes — analyze your actual operations and select the most specific new code
5. For deprecated codes — research the closest KBLI 2025 equivalent; consider professional consultation
6. For merged codes — confirm the unified code and identify any NIB simplification opportunities
7. Document all mapping decisions with written justifications
8. Review PMA implications — check foreign ownership, investment plan, and RPTKA alignment
9. Prepare your update package — a single document ready for OSS submission
10. Verify OSS readiness live — check the current official workflow before any filing or amendment
11. Execute remediation immediately through the available OSS/NIB path if your mapping is outdated
12. Verify your updated NIB — confirm all codes are correctly recorded after submission

The Bottom Line

KBLI migration is not a bureaucratic checkbox. The reclassification from KBLI 2020 to KBLI 2025 changes risk levels, ownership rules, tax benchmarks, and licensing requirements. A code chosen carelessly can cost your business access to incentives, trigger unnecessary compliance burdens, or create foreign ownership complications that take months to resolve.

The companies that will navigate the post-window phase smoothly are the ones verifying now — mapping codes, documenting decisions, and keeping update packages ready — so they can execute quickly through the current OSS/NIB path.

If you are operating in Bali specifically, our KBLI 2025 Bali Transformation guide covers the island-specific implications for hospitality, F&B, and digital businesses. For OSS registration fundamentals, see our OSS Registration Guide.

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Need help mapping your specific KBLI codes? Contact Bali Zero for a personalized KBLI migration assessment. Our team handles the research, documentation, and execution so you can focus on running your business.