KBLI 2025 Finance & Capital Markets Bali | Bali Zero

Q: Which financial services KBLI code is easiest for a foreign PT PMA to enter in Bali?

KBLI 66151 (Investment Advisory) is the easiest — it is listed as 'seluruh' (fully open) in the Positive Investment List, requires only the standard IDR 10 billion PMA investment, and has no sectoral ownership cap. OJK classifies it as high risk requiring an OJK license, but the barriers are significantly lower than insurance or P2P lending. Bali's growing HNWI expat and digital nomad community creates strong demand.

Q: Does the Bank Indonesia money changer (KUPVA BB) moratorium apply to Bali?

No. The BI moratorium on new money changer licenses applies only to Jakarta (July 2025 – December 2026) due to market saturation with 482 offices in the capital. Bali remains fully open for new KUPVA BB license applications. With 7M+ international arrivals annually, Bali is one of Indonesia's most attractive markets for licensed FX operations, with break-even typically achievable in 12–18 months.

Q: What is KBLI 64995 carbon unit trading and is it a good investment in Bali?

KBLI 64995 is an entirely new code introduced in KBLI 2025 for carbon unit trading. IDXCarbon has recorded 1.6 million tonnes CO2e in cumulative volume but liquidity has stalled (only 8 tonnes traded in June 2025). Bali has natural carbon assets in geothermal, renewable energy, and forest conservation. The recommended strategy is to build a project pipeline now and monetize in 2027–2030 when the market matures under Perpres 110/2025.

Q: What are the foreign ownership caps for insurance companies in Indonesia?

Insurance has the strictest PMA cap in the financial sector: 80% maximum under PP 14/2018 (amended PP 3/2020). Listed companies (Tbk) are exempt. Foreign shareholders must be insurance companies or holding companies with an insurance subsidiary, and their equity must be at least 5x the direct investment. Minimum capital is IDR 100 billion (life) and IDR 150 billion (general). The insurance broker/agent model (KBLI 66221/66222) has lower barriers.

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Indonesia's financial services sector is undergoing its deepest regulatory transformation in a generation. The convergence of KBLI 2025 (BPS Reg 7/2025), UU P2SK (Law 4/2023), and BKPM Reg 5/2025 has reshuffled the rules for every foreign investor seeking to operate in KBLI categories 64, 65, and 66. This guide provides actionable 2026 intelligence on 10 priority financial KBLI codes — including the ownership caps, capital thresholds, licensing timelines, and Bali-specific market dynamics that determine investability.

Cross-Sector Regulatory Framework 2026

KBLI 2025 Transition (BPS Reg 7/2025)

The KBLI 2025 now functions as a legal infrastructure, not merely a statistical catalog. It determines business licensing, investment screening, and risk allocation across all 64–66 subcategories. Key changes for finance:

New codes introduced: 64994 (proprietary crypto trading), 64995 (carbon unit trading — entirely new), 64999 (crypto issuance with liabilities)
Transition deadline: the now-closed June 2026 transition window — all companies must update KBLI codes in AHU and OSS systems
Existing licenses remain valid during the transition period

PMA Capital Requirements (BKPM Reg 5/2025)

Parameter	Before (BKPM 4/2021)	After (BKPM 5/2025)
Minimum paid-up capital	IDR 10 billion	IDR 2.5 billion
Minimum total investment per KBLI/location	>IDR 10 billion	>IDR 10 billion (unchanged)
Capital lock-up period	Not required	12 months mandatory
Use of capital during lock-up	N/A	Asset purchase, construction, operations only

Note: Sectoral regulators (OJK, BI) impose significantly higher capital requirements on top of the BKPM general threshold.

PPN 12% on Digital Financial Services

From 1 January 2025, 12% VAT applies to fintech services including: payment services, investment settlement, crowdfunding, P2P lending, investment management, online insurance, and market support services. The tax applies on the service fee, not the transaction value.

KBLI 64991 & 64992 — Venture Capital (Conventional & Syariah)

Indonesia's VC market is nascent but growing. With GDP growth exceeding 5% in Q2 2025 and government projections of 6–8% for 2026, OJK has issued 9 new POJKs for the PVML sector (venture capital, microfinance, other financial institutions) signaling strong regulatory intent.

PMA ownership cap: 85% of paid-up capital. Citizens can hold VCC shares only through stock exchange transactions.

Operational Requirements

Requirement	Venture Capital Corporation (VCC)	Venture Debt Corporation (VDC/Syariah)
Minimum equity	IDR 50 billion	IDR 25 billion
Regulator	OJK (POJK 25/2023 + POJK 46/2024)	OJK + DSN-MUI (syariah)
Foreign ownership cap	85%	85%
Dana Ventura	Separate OJK license required	Separate OJK license required

Bali angle: Coworking hubs (Dojo Bali, Outpost, BWork) function as informal incubators for founders and remote teams. Potential for micro-VC focused on tourism tech, wellness tech, and PropTech. The syariah variant (64992) accesses Gulf and Islamic institutional capital pools with halal mandates.

Investment outlook: High ROI potential in the medium-to-long term given Indonesia's underpenetrated startup ecosystem relative to 300M+ population. Entry barriers are significant: IDR 50B equity minimum, complex OJK licensing, mandatory 15% local partner. The UU P2SK framework facilitates integrated fintech/VC structures as a 2026 structural opportunity.

KBLI 64995 — Carbon Unit Trading

This code is entirely new in KBLI 2025 — it did not exist under KBLI 2020. IDXCarbon, operational since September 2023, has recorded cumulative volume of 1.6 million tonnes CO₂e (IDR 77.95 billion, ~USD 4.9M). However, trading has stalled: only 8 tonnes traded in June 2025 (-98.5% vs prior month), with 90% domestic buyers and just 8 listed projects.

Regulatory framework: Perpres 98/2021 updated by Perpres 110/2025, which strengthens the national carbon market with a more structured roadmap and joint ministerial oversight. IDXCarbon is the sole official exchange, operated by IDX under OJK supervision. International participation was opened in January 2025.

Bali angle: Natural assets for carbon credits: geothermal energy, renewable power, sustainable tourism, and forest conservation. The Canggu/Seminyak green-tech founder community creates a favorable ecosystem for carbon intermediaries.

Investment outlook: Uncertain short-term ROI given low liquidity. Structural potential is enormous — Indonesia targets 29–41% emissions reduction by 2030. Recommended strategy: build project pipeline now, monetize 2027–2030. First-mover window is open.

KBLI 64910 & 64930 — Leasing & Factoring

Both fall under Perusahaan Pembiayaan regulated by OJK (POJK 46/2024). Foreign ownership capped at 85%. Minimum capital for national operations: IDR 100 billion — the highest barrier in this guide.

Code	Activity	Market Context	Bali Opportunity
64910	Financial leasing	Mature market, dominated by banking subsidiaries (Astra, BCA, Mandiri)	Leasing of renewable energy assets (solar, HVAC) for resorts; vehicle fleets
64930	Factoring/accounts receivable	Underdeveloped vs leasing; growing digital factoring	B2B supply chain finance for hospitality sector; villa economy invoices

Practical recommendation: Both codes are more viable as JV structures with established local banking/financial groups. Standalone PMA entry at IDR 100B minimum capital is viable only for large financial institutions.

KBLI 65111 & 65121 — Life & General Insurance

Indonesia's insurance market is structurally underpenetrated (<3% of GDP), creating long-term growth potential. Post-Jiwasraya and AJB Bumiputera scandals, OJK supervision has intensified under the UU P2SK framework.

PMA cap: 80% maximum (stricter than other financial sectors) — per PP 14/2018 as amended by PP 3/2020. Listed companies (Tbk) are exempt. Foreign shareholders must be insurance companies or holding companies with an insurance subsidiary. Foreign shareholder equity must be at least 5× the direct investment.

Code	Activity	Min Capital	Licensing Timeline
65111	Life insurance	IDR 100 billion	12–24 months
65121	General insurance	IDR 150 billion	12–24 months

Bali opportunity for 65121 (general insurance): With 7M+ international tourist arrivals in 2025, demand is structural for: travel insurance, property all-risk for villa economy, health insurance for expatriates and digital nomads, liability for tourism operators.

Entry strategy: Insurtech via OJK sandbox, micro-insurance products, or partnership with existing licensed players is more practical than a greenfield PMA given the 80% cap and IDR 100–150B capital requirements.

KBLI 66125 — Money Changer (KUPVA BB)

BI has imposed a temporary moratorium on new licenses in Jakarta only (July 2025 – December 2026) due to market saturation (482 offices in the capital, 31% of the national total). Outside Jakarta, licenses remain fully available.

Bali is one of the most attractive markets for money changers:

7M+ international arrivals generating structural FX demand (AUD, EUR, USD, GBP)
Moratorium does NOT apply to Bali
Strong margins in high-traffic tourist zones (Kuta, Seminyak, Ubud, Canggu)
Growing digital nomad population requiring reliable FX services

Regulated by Bank Indonesia (not OJK). Requires KUPVA BB license. Compliance: AML/KYC obligations, periodic BI reporting, digital compliance per PADG 11/2024.

Investment outlook: Stable, predictable ROI. Break-even in 12–18 months for well-located operators. Opportunity to integrate with digital platforms for nomads and cross-border remittance services. FX apps create competitive pressure in low-margin segments but not in the tourist cash-exchange market.

KBLI 66151 — Investment Advisory

PMA parameter: "Seluruh" (fully open). This makes 66151 one of the most accessible financial codes for foreign investors.

OJK classifies the activity as high risk in OSS, requiring an OJK license (not just an NIB). Minimum investment: IDR 10B standard PMA. PPN 12% on advisory fees.

Bali opportunity: Growing community of HNWI expatriates, international retirees, and digital entrepreneurs requiring advisory for Indonesian and ASEAN investments. Crypto/Web3 community creates demand for regulated digital asset advisory. Boutique advisory firms focused on real estate, capital markets, and ESG investments are underserved in Bali.

Investment outlook: High ROI potential with relatively low operating costs vs other financial services. POJK 3/2024 (ITSK) enables innovative digital advisory models via OJK sandbox. Scalable lean-team model. Best entry point in the financial services cluster for a PMA with investment expertise.

KBLI 66161 & 66162 — P2P Lending (Conventional & Syariah)

POJK 40/2024 (issued 24 December 2024, effective 27 December 2024) replaces POJK 10/2022 with significantly stricter rules. The sector is in consolidation mode after NPL problems and predatory lending practices.

Key Requirements (POJK 40/2024)

Parameter	Detail
Foreign ownership cap	Max 85% of paid-up capital
Minimum paid-up capital	IDR 25 billion (deposited immediately in time deposit)
Controlling shareholder	Must be operational for at least 2 years
Foreign workers	OJK prior approval required
Maximum lending	IDR 2B (consumer), up to IDR 5B (productive)
Prohibition	Direct public fund-raising not permitted

Bali nuance: Borrowers must be Indonesian entities (not foreigners). Lenders can be foreign. Potential for P2P platforms specializing in tourism, hospitality, and the Bali creative economy serving the underbanked micro-enterprise base.

Investment outlook: High potential ROI but significant regulatory risk. Break-even 2–3 years. Access via OJK sandbox (POJK 3/2024) is a more prudent entry path. High reputational risk given the sector's track record.

KBLI 66301 — Fund Management

AUM is expanding as Indonesia's middle class grows and retail investors access markets via digital platforms. Includes reksadana (mutual funds), dana investasi, and individual portfolio management. PMA parameter confirmed as open in OSS.

KBLI 2025 subdivides 66301 into: 66311 (conventional investment manager) and 66312 (syariah investment manager). OSS update required by the now-closed June 2026 transition window.

Requirement	Detail
Regulator	OJK (capital markets division)
Minimum capital	IDR 25 billion
Certified staff	WPPE and WMI certifications mandatory
Risk level	HIGH in OSS
Fee treatment	PPN 12% on management fees

Investment outlook: Fee-based scalable model. Break-even 2–4 years. Opportunities in 2026: robo-advisory, digital reksadana distributed via fintech platforms, ESG/green bond products. One of the more accessible financial codes for foreign investors with fund management expertise.

KBLI 66221 & 66222 — Insurance Agent & Broker

The insurance distribution market is growing in parallel with the underinsurance gap. OJK Reg 4/2025 regulates digital aggregators with an 85% PMA cap. 50 insurance brokers already operating with foreign ownership below 80% (OJK data).

Code	Model	Independence	Capital Requirement
66221 Agen	Tied agent — acts for one insurer	None	Lower than direct insurers
66222 Pialang	Independent broker — multi-insurer	Full	Moderate

Bali opportunity: High demand for brokers specializing in: travel insurance for 7M+ annual tourists, property all-risk for villa owners, health insurance for expatriates and digital nomads, liability for tourism operators. The independent pialang model (66222) is particularly well-suited to Bali's diverse international client base.

Investment outlook: Attractive ROI with contained initial investment. Commission-based model scalable across products. Break-even 12–24 months. Best entry point in the insurance sector for PMA — significantly lower barriers than direct insurers.

PMA Accessibility Matrix

KBLI	Activity	PMA Cap	Min Sectoral Capital	Entry Difficulty
64991/64992	Venture Capital	85%	IDR 25–50B	████░ High
64995	Carbon Trading	TBD	New activity	███░░ Medium
64910	Leasing	85%	IDR 100B	█████ Very High
64930	Factoring	85%	IDR 100B	█████ Very High
65111/65121	Insurance	80%	IDR 100–150B	█████ Very High
66125	Money Changer	Verify BI	Variable	███░░ Medium

Strategic Recommendations for PMA in Bali

Tier 1 — Highest Priority

66151 Investment Advisory: lowest barriers, open PMA parameter, growing HNWI/expat community demand, lean scalable model
66221/66222 Insurance Broker/Agent: accessible entry into the insurance ecosystem, strong Bali tourist/expat demand, commission-based model
66125 Money Changer: BI moratorium does not apply to Bali, structural tourist demand, rapid break-even

Tier 2 — Emerging Potential

64995 Carbon Trading: new code with first-mover advantage, Bali has natural carbon asset base, but near-term liquidity insufficient
66161/66162 P2P Lending: demand from underbanked Bali tourism micro-enterprises, but IDR 25B capital minimum and high regulatory risk

Tier 3 — High Barrier Entry (Jakarta-centric)

6–10. Venture Capital, Leasing, Factoring, Insurance, Fund Management: require IDR 25–150B in sectoral capital, complex OJK licensing, operations naturally centralized in Jakarta.

2026 Compliance Action Plan

For any PMA entering the financial services sector in 2026:

Verify KBLI code mapping in OSS now that the June 2026 transition window has closed (KBLI 2020 → 2025 transition)
OJK sandbox (POJK 3/2024) is the recommended entry path for innovative fintech/insurtech models
PPN 12% applies to all digital financial service fees from 1 January 2025 — build into pricing model
BKPM 5/2025: IDR 2.5B paid-up capital minimum with 12-month lock-up — capital must demonstrably remain available
LKPM quarterly reporting mandatory for all PMA entities

Disclaimer: This report is based on normative sources, OJK/BI publications, and market data current as of February 2026. Ownership caps and capital requirements are subject to regulatory change. Independent legal advice is required before investment decisions.