KBLI 2025 Foreign Ownership | 100% PMA Codes Guide Indonesia

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The Foreign Ownership Question Every Investor Asks First

Before a single rupiah crosses the border, every foreign investor in Indonesia asks the same question: "Can I own 100% of my company?"

The answer used to be buried in the Daftar Negatif Investasi (DNI) — a sprawling negative list that told you what you couldn't do. That system is dead. Replaced first by PP 5/2021, then updated by PP 28/2025, Indonesia now operates on a Positive Investment List that maps ownership rules directly to KBLI codes.

With the KBLI 2025 reclassification (BPS Regulation No. 7 of 2025), the codes themselves have changed. Some sectors that were restricted are now open. Others that seemed open have acquired new conditions. If you're setting up a PT PMA in 2026, this is the map you need.

From DNI to Positive Investment List: What Changed

The Old System (DNI)

Indonesia's Daftar Negatif Investasi was a list of sectors either closed or conditionally open to foreign investment. It operated by exclusion: if your business wasn't on the list, you were free to proceed. In practice, the DNI was vague, inconsistently applied across regional offices, and created a culture of regulatory uncertainty.

The New System (PP 5/2021, Updated PP 28/2025)

The Positive Investment List flipped the model. Instead of listing restrictions, it specifies conditions for every KBLI code:

TERBUKA — Open. 100% foreign ownership permitted. No conditions.
TERBUKA BERSYARAT — Open with conditions. Foreign ownership allowed up to a specified percentage (e.g., 49%, 67%, 95%), or subject to partnership requirements, scale limitations, or geographic restrictions.
TERTUTUP — Closed. Reserved for the government or cooperatives. Extremely rare under KBLI 2025.

PP 28/2025 specifically updated the ownership percentages and conditions to align with the new KBLI 2025 code structure. If you are referencing old DNI-era guidance, it is outdated. The legal basis for foreign ownership in Indonesia is now exclusively the Positive Investment List as mapped to KBLI 2025 codes.

TERBUKA vs. Restricted: The Ownership Spectrum

Not every "open" sector is the same. Understanding the classification spectrum is critical for structuring your PT PMA correctly.

Fully Open (TERBUKA) — 100% PMA

These sectors have no foreign ownership cap. A single foreign shareholder (individual or entity) can hold the entire company. The only requirement is meeting the capital thresholds.

Conditionally Open (TERBUKA BERSYARAT) — Partial PMA

These codes allow foreign investment but cap ownership at a specific percentage. Common caps include:

49% — Foreign investor is a minority shareholder. Indonesian partner(s) must hold 51%+.
67% — Foreign majority allowed, but Indonesian participation required.
95% — Effectively foreign-controlled, with a nominal 5% local partner.

Some codes add non-percentage conditions: mandatory partnerships with cooperatives, MSME reservation (micro/small enterprises excluded from PMA), or geographic restrictions.

Closed (TERTUTUP)

A handful of sectors remain fully closed to any foreign participation: alcohol production, gambling, and specific defense-related activities. These represent a tiny fraction of the total KBLI universe.

Sector-by-Sector PMA Status Under KBLI 2025

The following table maps the most relevant sectors for foreign investors in Bali and Indonesia to their PMA status under the combined framework of KBLI 2025 and PP 28/2025.

Sector	Key KBLI 2025 Codes	PMA Status	Max Foreign Ownership	Notes
Consulting	70201 – 70209	TERBUKA	100%	All management & technical consulting codes fully open
IT Services	62012, 62019, 62024	TERBUKA	100%	Software development, IT consulting, data processing
Hospitality	55110 – 55199	TERBUKA	100%	Hotels, resorts, villas, guesthouses — all open
Real Estate	68xxx (all 14 codes)	TERBUKA	100%	Major improvement from KBLI 2020. All 14 codes now PMA-eligible
Tourism Services	79111 – 79120	TERBUKA	100%	Travel agencies, tour operators, reservation services

The Real Estate Breakthrough

Under the previous KBLI 2020 classification, real estate had only 5 codes, and PMA eligibility was ambiguous for several of them. KBLI 2025 expanded the sector to 14 distinct codes — a 180% increase — and classified every single one as TERBUKA with 100% PMA eligibility.

This is the single largest improvement for foreign property investors in recent Indonesian regulatory history. If you're building, managing, or trading real estate through a PT PMA, the classification landscape has never been more favorable. See our complete real estate KBLI analysis for the full code breakdown.

The Broadcasting Trap

KBLI 2025 split the old "Information & Communication" category into two distinct sectors:

Category J — Publishing, broadcasting, and content production (20% foreign cap)
Category K — Telecommunications, programming, and IT infrastructure (100% PMA)

This matters enormously for digital agencies in Bali. A company that classifies itself as a "content publisher" or "media production house" falls under Category J restrictions. The same company, correctly classified as an IT services provider under Category K, operates with zero foreign ownership restrictions. Your KBLI code selection is not an administrative formality — it is a legal structure decision.

How Risk Levels Affect Your PMA Process

KBLI 2025 assigns every business activity a risk level based on the OSS (Online Single Submission) risk-based licensing framework. The risk level does not change your ownership percentage, but it dramatically affects the process complexity for obtaining your business license.

Low Risk

License type: NIB (Nomor Induk Berusaha) only
Process: Automatic issuance through OSS. No manual review.
Timeline: Same day to 3 business days.
PMA impact: Smoothest path. Register, deposit capital, receive NIB.

Medium Risk

License type: NIB + Standard Certificate (Sertifikat Standar)
Process: Self-declaration or third-party verification required.
Timeline: 1–2 weeks.
PMA impact: Slightly longer setup. May require additional documentation proving compliance with sector-specific standards.

High Risk

License type: NIB + Full License (Izin)
Process: Government inspection and approval required before operations begin.
Timeline: 1–3 months.
PMA impact: Most scrutiny. Inspections may cover premises, equipment, staffing, environmental compliance. Foreign-owned companies in high-risk categories should budget additional time and legal support.

What This Means in Practice

A consulting firm (KBLI 70201, low risk, TERBUKA) can be fully licensed and operational within days. A construction company (KBLI 41017, high risk, TERBUKA) has the same 100% ownership right but may need months of inspections before starting work.

Risk level is the hidden variable that determines your time-to-market. Two businesses with identical PMA eligibility can have wildly different launch timelines.

Capital Requirements for PT PMA

Foreign ownership under KBLI 2025 is gated by capital thresholds established under BKPM Regulation No. 5 of 2025:

The Two-Stage Capital Structure

Paid-up Capital (Modal Disetor): IDR 2.5 billion (~USD 160,000) per shareholder. This is cash that must be deposited in the company's Indonesian bank account at incorporation. Subject to a 12-month lock-up.
Total Investment Plan (Rencana Investasi): IDR 10 billion (~USD 640,000) per business line (per 5-digit KBLI code). This is the aggregate commitment of capital expenditure and operating expenditure over the investment period.

Per-Code Investment

Each KBLI code in your NIB carries its own IDR 10 billion investment obligation. A PT PMA with three KBLI codes theoretically commits to IDR 30 billion in total investment. In practice, BKPM allows overlapping expenditures to be allocated across codes — but the commitment structure means you should not add codes speculatively.

The KITAS Connection

While the paid-up capital threshold has been reduced to IDR 2.5 billion, the KITAS (temporary stay permit) for foreign directors and shareholders still references the IDR 10 billion total investment figure. This creates a practical disconnect: you can incorporate cheaply, but sponsoring yourself for a work permit requires demonstrating the full investment commitment.

Strategic Implications for Foreign Investors

1. Code Selection Is a Legal Architecture Decision

Your choice of KBLI codes determines your ownership ceiling, licensing complexity, tax benchmarks, and operational scope. Selecting codes without understanding the PMA implications is the most common — and most expensive — mistake foreign investors make.

2. The Post-Deadline Migration Applies to Everyone

All existing businesses should treat unresolved KBLI 2020-to-2025 migration as overdue now that the June 2026 transition window has closed. For PT PMA entities, this migration may change your ownership eligibility if the new code maps to a different TERBUKA/BERSYARAT classification. Audit your codes before the next filing or amendment.

3. Restructuring Opportunities

The reclassification has opened sectors that were previously restricted. If your PT PMA was structured with an Indonesian nominee partner due to old DNI restrictions, and your sector is now TERBUKA under KBLI 2025, you may be able to restructure to 100% foreign ownership. This requires a formal share transfer and OSS update.

4. Multi-Code Strategy

Sophisticated investors register multiple KBLI codes to cover adjacent business activities. Under KBLI 2025, ensure every code in your NIB is individually PMA-eligible. A single restricted code in a multi-code NIB can create compliance complications for the entire entity.

Frequently Asked Questions

What is the Positive Investment List?

PP 28/2025 replaced the old DNI (Negative Investment List) with a Positive approach. Instead of listing what's restricted, it now specifies conditions for each KBLI code — including PMA percentage, risk level, and scale requirements. The philosophical shift is from "everything is open unless listed as closed" to "here are the exact conditions for every code."

Can foreigners own 100% of a consulting company?

Yes. All consulting KBLI codes (70201–70209) are classified as TERBUKA under KBLI 2025, meaning 100% foreign ownership through PT PMA is allowed with no restrictions. This covers management consulting, technical consulting, and specialized advisory services.

Which sectors still restrict foreign ownership?

Broadcasting and some content production (Category J) is capped at 20% foreign ownership — the most restrictive cap in the system. Some retail codes are reserved for MSMEs, excluding PMA. Certain transport and education codes cap foreign ownership between 49% and 67%. Agriculture and fisheries have partial restrictions depending on scale.

Does the risk level affect my ownership percentage?

No. Risk level determines the licensing process (how many approvals and inspections you need), not the ownership ceiling. A low-risk TERBUKA code and a high-risk TERBUKA code both allow 100% PMA. The difference is operational timeline, not legal structure.

What happens if I picked the wrong KBLI code?

You can amend your KBLI codes through the OSS system. However, if the new code has a different PMA classification (e.g., switching from TERBUKA to BERSYARAT), you may need to restructure your shareholding. This is not automatic and requires legal review.

Next Steps

The intersection of KBLI 2025 and foreign ownership rules is where regulatory compliance meets business strategy. Getting it right means lower costs, faster licensing, and full control of your company. Getting it wrong means restructuring fees, delayed permits, and potential forced divestment.

If you are planning a PT PMA in Indonesia — or already operating one — the action items are clear:

Verify your KBLI codes against the KBLI 2025 classification
Check each code's PMA status on the Positive Investment List (PP 28/2025)
Assess risk levels to understand your licensing timeline
Plan your capital structure around the IDR 2.5B / IDR 10B dual-gate system
Remediate any unresolved KBLI 2020-to-2025 migration before the next filing or amendment

Use our KBLI Navigator to search codes and check PMA eligibility instantly, or explore the full BKPM capital requirements analysis for detailed investment planning.