KBLI 2025 Healthcare & Wellness: Hospital, Clinic, and Medical Business Codes for Indonesia

Indonesia's healthcare sector is fully open to foreign investment under KBLI 2025, with every healthcare code allowing 100% foreign ownership through a PT PMA structure. This includes hospitals, clinics, specialist practices, traditional medicine services, and medical transport. For foreign investors eyeing Bali's booming medical tourism and wellness sectors, or for healthcare professionals looking to establish practices in Indonesia, this represents a clear regulatory pathway.

But "open to foreign investment" does not mean "simple to execute." Healthcare is among the most heavily regulated sectors in Indonesia, with most codes carrying Tinggi (High) or Menengah Tinggi (Medium-High) risk classifications. This translates to extensive licensing requirements, mandatory accreditation timelines, and ongoing compliance obligations that go far beyond the basic NIB registration required for low-risk businesses.

This guide breaks down all 13 healthcare KBLI codes, explains the practical differences between hospital and clinic classifications, clarifies accreditation and licensing requirements, and shows you exactly what foreign ownership means in the context of Indonesian healthcare regulations. The June 2026 KBLI 2025 compliance deadline applies to all businesses, including healthcare operators — if you already hold a medical license under legacy KBLI codes, you need to verify your classification maps correctly to the new system.

If you are new to the KBLI classification system entirely, start with our Beginner's Guide to KBLI 2025 before diving into sector-specific details.

Complete KBLI 2025 Healthcare Code Reference

Here is the full breakdown of all healthcare codes under KBLI 2025, organized by service category:

Hospitals (861xx)

Medical Practices (862xx)

Other Health Services (869xx)

Critical takeaway: All codes allow 100% foreign ownership. But only three codes carry the Tinggi (High) risk classification requiring full Izin permits: hospitals (86101, 86103, 86109) and health support services (86993). The remaining codes sit at Menengah Tinggi (Medium-High), requiring Sertifikat Standar rather than full permits.

Understanding Risk Levels in Healthcare: What They Mean

Healthcare risk classifications directly determine the depth and duration of your licensing process. Here is what each tier means in practice.

Tinggi (High Risk) — Codes 86101, 86103, 86109, 86993

High-risk healthcare businesses require NIB + Izin — a full operational permit issued by the relevant government authority. This is the most rigorous licensing pathway in Indonesia's risk-based system. For hospitals, this means:

1. Pre-operational inspections — Physical inspection of facilities, medical equipment, infection control protocols, and staff credentials before you can open
2. Accreditation timeline — Must achieve national hospital accreditation within 2 years of operation
3. SIMRS reporting — Mandatory participation in Indonesia's hospital information system (Sistem Informasi Manajemen Rumah Sakit) for patient data, medical records, and operational metrics
4. Ongoing compliance audits — Regular inspections and documentation reviews by Kementerian Kesehatan

For health support services (86993) — which includes blood banks, medical laboratories, and pathology services — the Tinggi classification reflects the critical public health role these facilities play. Labs handling infectious disease diagnostics or blood banks managing donor supplies face rigorous oversight.

Menengah Tinggi (Medium-High Risk) — All Other Healthcare Codes

Medium-high risk businesses require NIB + Sertifikat Standar — a standards certificate confirming you meet regulatory requirements for your sector. This is less intensive than a full Izin permit, but significantly more demanding than the NIB-only pathway that low-risk businesses enjoy.

For clinics (86104, 86105) and medical practices (86201-86203), this includes:

1. Professional credentials verification — Proof that doctors and medical staff hold valid Indonesian licenses (Surat Tanda Registrasi / STR and Surat Izin Praktik / SIP)
2. Facility standards compliance — Self-assessment documentation showing your clinic meets Ministry of Health standards for medical equipment, sanitation, emergency protocols, and patient safety
3. Operational readiness inspection — Government verification that your facility is prepared to deliver medical services safely before issuing the Sertifikat Standar
4. Periodic reporting — Regular submission of activity reports covering patient volume, services provided, and compliance with health protocols

For traditional medicine (86992), the Sertifikat Standar process includes verification of practitioner certification under Indonesia's traditional medicine framework. Foreign practitioners may face additional hurdles around credential recognition.

Hospital vs. Clinic: A Critical Distinction

One of the most consequential decisions in healthcare business classification is whether your facility registers as a hospital (rumah sakit) or a clinic (klinik). The regulatory burden differs dramatically.

Hospital (86101, 86103, 86109) — Tinggi Risk

Hospitals are defined by their capacity to provide inpatient care (rawat inap), 24/7 emergency services, and comprehensive medical departments. Under Indonesian regulations, a hospital must:

• Operate minimum bed capacity based on regional demand assessments
• Maintain 24/7 emergency department with qualified emergency medicine specialists
• Employ specialists across multiple medical disciplines (internal medicine, surgery, pediatrics, obstetrics)
• Achieve national accreditation within 2 years — this is non-negotiable and enforced by Kementerian Kesehatan
• Participate in SIMRS data reporting — all patient admissions, diagnoses, treatments, and outcomes must be recorded in the national system
• Maintain medical waste disposal protocols and infection control infrastructure

The accreditation requirement is particularly significant. Hospitals that fail to achieve accreditation within the 2-year window face operational restrictions, fines, and potentially permit revocation. Accreditation is not a formality — it involves extensive external audits of clinical quality, patient safety protocols, staff competencies, and management systems.

Clinic (86104, 86105) — Menengah Tinggi Risk

Clinics provide outpatient care (rawat jalan) and may offer limited inpatient observation beds, but they do not operate as full-service hospitals. A clinic's regulatory burden is lighter:

• No mandatory national accreditation system (though quality standards still apply)
• No SIMRS reporting requirement (clinics report through different channels)
• Smaller staff requirements — a clinic can operate with general practitioners; specialists are optional
• Lower infrastructure thresholds — no requirement for 24/7 emergency departments or multiple medical departments

The practical consequence: If your business model centers on outpatient services — a general practice clinic, a specialist consultation center, a diagnostic imaging facility — registering under the clinic code (86105 for private clinics) avoids the Tinggi risk classification and the hospital accreditation mandate. This dramatically shortens the licensing timeline and reduces operational compliance costs.

Foreign Ownership in Practice: What 100% PMA Means for Healthcare

Every healthcare KBLI code allows 100% foreign ownership through a PT PMA structure. This is a clear regulatory statement: Indonesia wants foreign investment in healthcare. But ownership and operational control are not identical concepts in the healthcare sector.

Capital Requirements

PT PMA capital requirements apply uniformly across all sectors, including healthcare:

• Total investment commitment: IDR 10 billion (~USD 625,000) — this is your projected investment over the business plan period, including capital expenses, equipment, working capital, and salaries
• Paid-up capital (per company): IDR 2.5 billion (~USD 156,000) (BKPM Regulation 5/2025, Art. 26(10)) — this is actual cash deposited in the company's Indonesian bank account

For healthcare businesses, these thresholds are on the low end of realistic costs. A private hospital project in Bali typically requires IDR 50-100 billion in total investment (USD 3-6 million) when you account for land, construction, medical equipment, accreditation preparation, and initial staffing. A specialist clinic might run IDR 15-25 billion (USD 1-1.5 million). Traditional medicine practices sit closer to the minimum threshold.

Practitioner Licensing: The Indonesian Credential Requirement

Here is where foreign ownership meets regulatory reality. To practice medicine in Indonesia, you must hold an Indonesian medical license. This applies to doctors, specialists, dentists, nurses, and traditional medicine practitioners.

Foreign medical professionals face a multi-step process:

1. Credential recognition — Your foreign medical degree must be recognized by Kementerian Kesehatan. Degrees from certain countries (US, UK, Australia, Singapore) have streamlined pathways; others face longer evaluation timelines.
2. Competency examination — Foreign doctors must pass Indonesia's medical competency examination (Uji Kompetensi Mahasiswa Program Profesi Dokter / UKMPPD equivalent for foreign graduates) to demonstrate their clinical knowledge aligns with Indonesian standards.
3. Registration (STR) — After passing competency exams, you receive a Surat Tanda Registrasi (STR) from Konsil Kedokteran Indonesia, valid for 5 years.
4. Practice permit (SIP) — With an STR in hand, you apply for a Surat Izin Praktik (SIP) from the regional health office where you will practice.

The practical implication: You can own 100% of a healthcare PT PMA and employ Indonesian doctors to deliver services. But if you, as the foreign owner, want to personally practice medicine, you must go through the Indonesian licensing process. Many foreign investors in Indonesian healthcare operate as business owners and administrators, not as practicing clinicians.

Specialist Practices: The Foreign Doctor Pathway

For specialist medical practices (86202), Indonesia has been gradually opening pathways for foreign specialists in high-demand fields — particularly in areas where Indonesia faces domestic shortages. Medical tourism hubs like Bali and Jakarta have seen foreign specialists (especially from Australia, Singapore, and Malaysia) obtain Indonesian practice permits after meeting the credential and competency requirements.

But this remains a complex pathway with significant lead time. If your business model depends on a foreign doctor practicing in Indonesia, budget 12-18 months for the full licensing process, and work with a legal advisor experienced in medical credential recognition.

Medical Tourism and Wellness: Bali's Growing Opportunity

Bali's healthcare sector is undergoing rapid transformation, driven by medical tourism demand, an aging expat population, and rising domestic healthcare expectations. The opportunities fall into several categories:

Specialist Clinics for Expats and Medical Tourists

Bali's foreign resident population (estimated 50,000-80,000) represents a stable patient base seeking Western-standard medical care. High-demand specialties include:

• Orthopedics and sports medicine — serving surfers, divers, and active expats
• Dermatology and aesthetic medicine — Bali's tropical climate creates demand for skin treatments
• Obstetrics and pediatrics — expatriate families seek English-speaking practitioners
• Dental clinics (86203) — dental tourism is a major growth area, with Australian and European patients seeking cost-effective treatment

A specialist clinic under KBLI 86202 or 86203, targeting this demographic with English-speaking practitioners and international insurance billing, avoids the Tinggi risk hospital classification while serving a lucrative market segment.

Traditional Medicine and Integrative Wellness

Indonesia's traditional medicine sector (86992) is enormous — spanning herbal medicine (jamu), traditional massage, acupuncture, and indigenous healing practices. Bali's wellness tourism industry creates a natural overlap between traditional medicine and spa/wellness services.

Key distinction: Therapeutic traditional medicine (86992) is different from spa services (96xxx). A traditional medicine practice involves diagnosis and treatment of health conditions by certified practitioners. A spa offers relaxation and beauty services. The line blurs in integrative wellness centers that combine both, which may need to register multiple KBLI codes.

For foreign investors interested in Bali's wellness sector, the 86992 pathway requires engaging licensed Indonesian traditional medicine practitioners (Penyehat Tradisional) who hold certification from Kementerian Kesehatan. You can own the business; the practitioners deliver the services.

Health Support Services: Labs and Diagnostics

Medical laboratories and diagnostic imaging centers (86993) represent a growing market as healthcare infrastructure expands across Indonesia. These facilities serve both hospitals (which may outsource certain diagnostics) and direct-to-consumer health screening markets.

The Tinggi risk classification reflects the public health importance of accurate diagnostics — a lab misdiagnosing infectious diseases can cause public health emergencies. Expect rigorous inspections, equipment certification requirements, and quality control audits.

Medical Transport and Evacuation

Medical transport (86994) covers ambulance services, medical evacuation flights, and patient transfer services. Bali's medical evacuation market is substantial — thousands of tourists and expats require medical evacuation annually, typically to Singapore or Australia for complex procedures.

A medical evacuation business under 86994 requires coordination with hospitals, insurance providers, and international medical transport networks. The Menengah Tinggi risk classification reflects safety requirements for patient transport, but this is significantly less burdensome than operating a hospital.

Multi-KBLI Strategy for Healthcare Businesses

Many healthcare businesses register multiple KBLI codes to cover different service lines under a single PT PMA. Here are common combinations:

Hospital + Specialist Clinics + Labs

86103 (Private Hospital) + 86202 (Specialist Practice) + 86993 (Lab Services)

A comprehensive medical center might register all three codes — the hospital code for inpatient services, specialist codes for outpatient consultations, and lab codes for diagnostics. This allows the business to bill appropriately for different service types and maintain clarity in regulatory compliance.

Clinic + Traditional Medicine + Wellness

86105 (Private Clinic) + 86992 (Traditional Medicine) + 96190 (Spa Services)

An integrative wellness center offering both conventional medicine and traditional healing services would register the clinic code for general medical services, traditional medicine for therapies like acupuncture or herbal treatment, and spa codes (from the 961xx group) for non-medical wellness services.

Medical Tourism Facilitator + Clinic

86910 (Health Intermediation Services) + 86105 (Private Clinic)

A medical tourism facilitator that also operates its own clinic might register both codes — 86910 for arranging patient referrals to other hospitals and 86105 for delivering direct patient care in its own facility.

Rules for Multi-KBLI Registration

• Your highest risk code determines overall licensing requirements — if you register 86103 (Tinggi) alongside 86105 (Menengah Tinggi), you face the Tinggi licensing pathway for the entire business
• All codes must allow your ownership structure — since all healthcare codes allow 100% PMA, this is not an issue for foreign-owned healthcare businesses
• Register only codes you actively use — OSS audits can flag dormant KBLI codes with no corresponding revenue

Licensing Timeline: What to Expect

Healthcare licensing in Indonesia is measured in months, not weeks. Here is a realistic timeline for different healthcare business types.

Private Clinic (86105) — 6-9 Months

1. PT PMA registration (2-3 months) — company formation, notary deed, MENKUMHAM approval, tax registration
2. Facility preparation (3-4 months) — lease or construct clinic space, purchase medical equipment, hire staff
3. Professional licensing (ongoing) — ensure doctors hold valid STR and SIP
4. NIB + Sertifikat Standar application (1-2 months) — submit facility documentation, undergo inspection, receive standards certificate
5. Operational launch — once Sertifikat Standar is issued, you can open

Private Hospital (86103) — 12-18 Months (Minimum)

1. PT PMA registration (2-3 months)
2. Facility construction/preparation (6-12 months) — hospitals require extensive infrastructure work
3. Equipment procurement and installation (2-4 months) — medical equipment often requires import permits and installation validation
4. Staff recruitment and training (3-6 months) — hospitals need specialists, nurses, administrative staff, and support personnel
5. NIB + Izin application (2-4 months) — submit comprehensive facility documentation, undergo pre-operational inspection, receive operational permit
6. Soft opening and operational stabilization (2-3 months) — operate under probationary status while preparing for accreditation
7. Accreditation process (within 2 years) — mandatory national hospital accreditation must be achieved within 24 months of operational launch

The accreditation deadline is firm. Plan your hospital project timeline so that you can realistically achieve accreditation standards within the 2-year window. Many foreign hospital operators bring in accreditation consultants during the construction phase to ensure facilities are designed to meet accreditation criteria from day one.

Capital Investment Realities

The IDR 10 billion PT PMA minimum investment commitment is legally binding, but it represents only the baseline. Actual healthcare investment costs vary dramatically by business type.

Traditional Medicine Practice: IDR 10-20 Billion

A traditional medicine clinic with 2-3 treatment rooms, herbal pharmacy, and 5-10 staff can launch near the minimum investment threshold. Costs include facility lease/renovation, treatment equipment, inventory of herbs and compounds, and initial working capital.

Specialist Clinic: IDR 15-30 Billion

A specialist clinic (dermatology, dental, orthopedics) requires specialized medical equipment, which drives costs. A dental clinic needs dental chairs, imaging equipment, sterilization systems. A dermatology clinic needs lasers and aesthetic treatment devices. Budget IDR 20-25 billion for a well-equipped specialist clinic.

Multi-Specialty Clinic: IDR 30-60 Billion

A clinic offering multiple specialties (internal medicine, pediatrics, obstetrics, diagnostic imaging) under one roof requires larger space, more equipment, and bigger staff. This approaches small hospital scale in cost but avoids the hospital accreditation requirement by focusing on outpatient services only.

Private Hospital (Small): IDR 50-150 Billion

A 50-bed hospital in Bali with 24/7 emergency, surgery capabilities, and multiple departments represents a major capital project. Land/construction, medical equipment, information systems, initial inventory, staff recruitment, and accreditation preparation combine to push investment well above the PT PMA minimum.

Private Hospital (Medium-Large): IDR 200-500 Billion+

A 100+ bed hospital with advanced imaging (MRI, CT), intensive care units, specialized surgical suites, and international patient facilities is a large-scale infrastructure project comparable to hotel development in capital intensity.

Kementerian Kesehatan: The Regulatory Authority

All healthcare businesses in Indonesia ultimately answer to Kementerian Kesehatan (Ministry of Health), which sets standards for medical practice, facility design, equipment standards, patient safety protocols, and professional licensing.

Regional health offices (Dinas Kesehatan at provincial and district levels) issue most healthcare permits and conduct inspections. But national policies, accreditation standards, and major regulatory changes come from Kementerian Kesehatan.

Key regulatory documents for healthcare operators:

• Permenkes (Minister of Health Regulations) — sector-specific rules covering hospitals, clinics, traditional medicine, and health support services
• Hospital accreditation standards — published by Komisi Akreditasi Rumah Sakit (KARS)
• Professional practice regulations — STR and SIP requirements for doctors, nurses, and allied health professionals

Healthcare is one of the few sectors where reading Indonesian-language regulations is mandatory. Medical facility standards, professional licensing rules, and compliance requirements are not fully translated into English. If you do not have Indonesian-language capacity internally, hire a local healthcare consultant or legal advisor who specializes in health sector regulations.

KBLI 2025 Compliance Status: June 2026 transition window closed

The KBLI 2025 system became official with BPS Regulation No. 7 of 2025. All businesses in Indonesia — including healthcare operators — must ensure their registered KBLI codes align with the new classification now that the June 2026 transition window has closed.

For Existing Healthcare Businesses

If you already operate a healthcare facility with KBLI codes from the previous classification system (KBLI 2020), verify your code mapping:

1. Check code continuity — Most healthcare codes carried over with renumbering. KBLI 2020 code 8610 (Hospital Activities) split into six sub-codes (86101-86109) under KBLI 2025. If you were registered under the old hospital code, you need to specify which new code matches your facility.
2. Update through OSS — File the code update through the Online Single Submission system before the June deadline.
3. Review risk classification changes — Risk levels may have shifted for certain healthcare codes. If your risk classification increased, you may face additional licensing requirements.
4. Update business documentation — Your NIB, tax registration, and business permits should all reflect the KBLI 2025 code.

Failing to update now that the June 2026 transition window has closed does not automatically shut down your business, but it creates compliance gaps that can cause problems during inspections, permit renewals, or if you seek to expand operations.

For New Healthcare Businesses

If you are establishing a new healthcare facility, register directly with KBLI 2025 codes. Do not use legacy KBLI 2020 codes — OSS is transitioning to the new system, and outdated codes will be flagged for correction.

Why Healthcare Investment Makes Sense in Bali

Despite the regulatory complexity, Bali represents one of Indonesia's strongest markets for private healthcare investment. Several structural factors drive demand:

Growing Expat Population

Bali's foreign resident population has grown steadily, creating a patient base that seeks international-standard medical care, speaks English, and often holds international insurance that reimburses Indonesian providers at negotiated rates.

Medical Tourism Demand

Dental tourism, cosmetic procedures, and wellness retreats attract tens of thousands of international patients annually. Bali's cost advantage over Singapore and Australia — combined with its tourism appeal — makes it a natural medical tourism destination.

Domestic Middle-Class Growth

Indonesia's rising middle class increasingly seeks private healthcare over public facilities. Bali's domestic population of 4.3 million represents a growing market for private clinics and specialist services.

Public Healthcare Gaps

Indonesia's public healthcare system (Puskesmas and government hospitals) operates at or above capacity in many regions. Private healthcare fills gaps in service quality, specialist availability, and patient experience.

Government Support for Investment

The Positive Investment List (PP 28/2025) opening all healthcare codes to 100% foreign ownership is a deliberate policy signal. Indonesia needs healthcare infrastructure investment and is willing to accept foreign capital to accelerate development.

How to Get Started

Setting up a healthcare PT PMA in Indonesia involves multiple specialized steps. Here is the sequence:

1. Define your business model and choose KBLI codes — Hospital, clinic, specialist practice, traditional medicine, or health support services? Pick the code(s) that match your actual service delivery model.
2. Develop a detailed investment plan — Healthcare businesses need credible financial projections covering capital investment, equipment procurement, staffing costs, and operational expenses to meet the IDR 10 billion threshold.
3. Register the PT PMA — Through MENKUMHAM with a registered agent who understands healthcare sector requirements.
4. Secure facility location — Lease or purchase property for your clinic/hospital. Location matters for patient access and regulatory approval.
5. Obtain NIB through OSS — Register your business identification number and begin the licensing process (NIB + Sertifikat Standar or NIB + Izin, depending on risk level).
6. Prepare facility for inspection — Ensure your facility meets Ministry of Health standards before inspection.
7. Apply for sector-specific permits — Health office permits, operational licenses, and if applicable, begin the hospital accreditation process.
8. Hire licensed practitioners — Doctors, nurses, and medical staff must hold valid Indonesian credentials (STR and SIP).
9. Launch operations — Soft opening, staff training, operational stabilization.
10. Ongoing compliance — Periodic reporting, inspections, and for hospitals, achieving accreditation within 2 years.

Bali Zero handles PT PMA formation, NIB processing, and KITAS sponsorship for healthcare business owners. For sector-specific healthcare licensing (facility permits, accreditation consulting, professional credential verification), we work with specialized healthcare consultants. Learn more about PT PMA registration.

Key Takeaways

• All 13 healthcare KBLI codes (86xxx) allow 100% foreign ownership — no Indonesian partner required for PT PMA structure
• Risk levels vary: Hospitals (86101, 86103, 86109) are Tinggi (High), requiring NIB + Izin and 2-year accreditation mandate. Clinics and medical practices (86104, 86105, 86201-86203) are Menengah Tinggi, requiring NIB + Sertifikat Standar.
• Foreign doctors can own healthcare businesses but must obtain Indonesian medical licenses (STR + SIP) to personally practice medicine
• Hospital accreditation is mandatory within 2 years — non-negotiable for facilities operating under hospital codes
• Traditional medicine (86992) is open to foreign investment but requires licensed Indonesian practitioners for service delivery
• Medical tourism and expat healthcare demand create strong market opportunities in Bali for specialist clinics, dental practices, and integrative wellness centers
• Licensing timelines are long: 6-9 months for clinics, 12-18+ months for hospitals — plan accordingly
• KBLI 2025 compliance transition window has closed — existing healthcare operators must update their registered codes through OSS

For a broader perspective on how KBLI 2025 is reshaping Bali's business landscape, see our KBLI 2025 Bali Transformation guide. For the technical details of PT PMA formation, read our PT PMA Registration Guide.

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This analysis is based on KBLI 2025 data (BPS Regulation No. 7 of 2025), the Positive Investment List (Perpres 10/2021 as amended by Perpres 49/2021), and Ministry of Health regulations governing healthcare facility licensing in Indonesia. Healthcare regulations change frequently — always verify current requirements through Kementerian Kesehatan, regional Dinas Kesehatan offices, or a licensed healthcare business consultant before making investment decisions.