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Bali Zero handles visas, company setup, tax and property compliance in Indonesia. Ask us directly on WhatsApp.
Chat with Bali Zero on WhatsAppIf you are building a tech startup, SaaS platform, digital agency, or e-commerce business in Bali, the single most consequential regulatory decision you will make in 2026 is not about tax rates or visa types. It is about which KBLI code you register on your NIB. KBLI 2025 — mandated by BPS Regulation No. 7 of 2025 and aligned with ISIC Revision 5 — has split the old "Information & Communication" sector into two fundamentally different categories: Category J (publishing, broadcasting, and content production) and Category K (telecommunications, programming, and IT infrastructure). Category J carries foreign ownership restrictions, with broadcasting capped at 20%. Category K is generally open to 100% foreign ownership through PT PMA. A digital agency that describes its activities as "content creation" lands in Category J. The same agency, classified as "IT consulting and software development," operates freely under Category K. The codes are different. The legal consequences are worlds apart.
This guide maps every IT and software-related KBLI 2025 code, explains the risk levels and PMA rules, and gives you a practical framework for choosing the right classification for your business in Bali.
The following table covers the primary codes relevant to tech startups, software companies, digital agencies, and IT service providers operating in Indonesia.
| KBLI Code | Name (English) | Risk Level | PMA % | Category |
|---|---|---|---|---|
| 62011 | Computer Programming Activities | Varies | Varies | K |
| 62012 | E-Commerce Application Development | Rendah (Low) | 100% | K |
| 62013 | Immersive Media Programming (VR/AR) | Rendah (Low) | — | K |
| 62015 | Software Products and Games | — | — | K |
| 62019 | Other Computer Programming Activities | Rendah (Low) | — | K |
| 62021 | Various IT Activities | — | — | K |
| 62022 | Digital Identity Provision | Tinggi (High) | — | K |
| 62023 | Electronic Certificate Provision | Tinggi (High) | 100% | K |
| 62024 | IoT Consulting and Design | Rendah (Low) | 100% | K |
| 62029 | Other IT Activities | — | — | K |
| 62090 | Real Estate-related IT Activities | — | — | K |
| 70201 | Tourism Consulting Activities | Rendah (Low) | — | G/M |
| 70202 | Transportation Consulting Activities | Tinggi (High) | — | G/M |
| 70203 | PR/Communications Consulting | Rendah (Low) | 100% | G/M |
| 70209 | Other Management Consulting Activities | Rendah (Low) | — | G/M |
Key: Codes in the 620xx range fall under Category K (IT infrastructure and programming). Codes in the 702xx range are management consulting codes that many IT businesses use as complementary classifications. A dash (—) indicates the specific PMA percentage or risk level should be confirmed against the latest PP 28/2025 Positive Investment List, as conditions may vary by sub-activity.
This is the structural change in KBLI 2025 that every tech founder in Bali must understand.
Category J covers publishing, broadcasting, and content production. This includes television and radio broadcasting, film production, music publishing, news agencies, and — critically — social media content production and video content creation when classified as broadcasting or publishing activities.
Foreign ownership in broadcasting is capped at 20%. Other Category J activities have varying restrictions. If your business creates content as its primary revenue stream (a YouTube production studio, a social media marketing agency that produces original content, a podcast network), you risk falling into Category J.
Category K covers telecommunications, computer programming, and IT infrastructure. This includes software development, SaaS platforms, IT consulting, system integration, e-commerce application development, IoT, and data processing services.
Most Category K activities are classified as TERBUKA (open) with 100% foreign ownership permitted. The IT consulting codes (62021, 62024, 62029) and programming codes (62012, 62019) are generally open to full PMA ownership.
Bali hosts hundreds of digital agencies run by foreign entrepreneurs. These businesses typically do a mix of activities: building websites (software), managing social media (content), running paid advertising (consulting), producing video content (broadcasting), and providing IT support (infrastructure).
Under KBLI 2020, all of this could be loosely bundled under a single "Information & Communication" code. Under KBLI 2025, you must disaggregate your activities:
The practical rule: lead with your technology activities on the NIB. Register your primary KBLI code as a Category K software or IT consulting code. If you also produce content, add it as a secondary code — but understand that your foreign ownership percentage must comply with the most restrictive code on your NIB.
For a deeper analysis of how this affects Bali's broader business landscape, see our guide on KBLI 2025 and Bali's Business Transformation.
KBLI 2025 introduces several codes that did not exist in KBLI 2020, reflecting Indonesia's recognition of emerging technology sectors.
Aktivitas Konsultansi dan Perancangan Internet of Things
This is a brand-new code for businesses that design, consult on, or implement IoT solutions. It covers smart building systems, industrial IoT sensors, agricultural technology, connected device platforms, and IoT system architecture consulting.
For tech companies building IoT products in Bali — whether agricultural sensors for rice paddies or smart villa management systems for the hospitality industry — this code provides a clean, low-risk classification with full foreign ownership rights. Previously, IoT businesses had to shoehorn themselves into generic IT consulting codes. Now there is a purpose-built classification.
Aktivitas Pemrograman dan Produksi Konten Media Imersif
This code covers the development of virtual reality, augmented reality, and mixed reality software and content. It includes VR game development, AR application programming, immersive training simulations, and metaverse platform development.
Note that this code sits in Category K (programming/infrastructure), not Category J (content/broadcasting). This is significant: even though VR/AR involves "content," the classification treats it as a programming activity. This distinction protects VR/AR developers from the broadcasting ownership restrictions that affect traditional content producers.
For Bali's growing creative tech scene — studios building VR tourism experiences, AR cultural heritage apps, or immersive wellness platforms — code 62013 is the correct home.
Aktivitas Penyediaan Identitas Digital
This code covers businesses that provide digital identity verification services, biometric authentication platforms, and digital ID infrastructure.
Aktivitas Penyediaan Sertifikat Elektronik
This code covers certificate authorities, electronic signature services, and digital certificate infrastructure.
Both 62022 and 62023 are high-risk classifications due to their national security implications. They require additional licensing, stricter compliance requirements, and longer processing times. Unless your core business is specifically digital identity or electronic certificates, avoid these codes.
Not all Category K codes are created equal. The risk level assigned to a KBLI code determines the licensing burden, the number of permits required, and the scrutiny your business will face during registration and ongoing compliance.
| Code | Activity | Why It Works |
|---|---|---|
| 62012 | E-Commerce App Development | Perfect for SaaS, marketplaces, and app studios. Low risk, 100% PMA. |
| 62019 | Other Computer Programming | Catch-all for software development. Low risk. Broad enough for most tech activities. |
| 62024 | IoT Consulting and Design | New in 2025. Ideal for hardware-software integration businesses. Low risk, 100% PMA. |
| 62013 | Immersive Media (VR/AR) | New in 2025. VR/AR development classified as programming, not content. Low risk. |
| Code | Activity | Why It Is Risky |
|---|---|---|
| 62022 | Digital Identity | National security implications. Requires additional certifications. High compliance burden. |
| 62023 | Electronic Certificates | Requires certification authority licensing. Highly regulated. Government oversight. |
| 70202 | Transportation Consulting | High risk classification, potentially restricting PMA structures. |
The practical advice: If you are a SaaS company that happens to include user identity verification as a feature (login authentication, KYC integration), you do not need code 62022. That code is for businesses whose primary activity is providing digital identity infrastructure. Use 62012 or 62019 as your primary code and implement identity features as a component of your software platform.
Similarly, if you build an e-commerce platform that processes payments, you do not need electronic certificate codes. Your payment processing is a feature of your platform (62012), not a standalone certificate authority business.
Recommended primary code: 62019 (Other Computer Programming Activities) or 62012 (E-Commerce Application Development)
Both are low risk. Code 62012 is more specific if your SaaS serves e-commerce or marketplace functions. Code 62019 is broader and covers general software development, making it suitable for B2B SaaS, project management tools, analytics platforms, and similar products.
If you want comprehensive guidance on launching a tech company in Indonesia, see our Tech Startup Guide.
Recommended primary code: 62012 (E-Commerce Application Development)
This code was specifically designed for businesses that develop and operate e-commerce platforms, online marketplaces, and internet-based trading applications. It carries low risk and allows 100% foreign ownership — the optimal combination for foreign entrepreneurs building e-commerce businesses in Bali.
For marketplace operators, fulfillment platforms, and online retail technology providers, this is the cleanest classification available. See our detailed E-Commerce Business Guide for the full regulatory picture.
Recommended primary code: 62019 (Other Computer Programming) + secondary codes as needed
Digital agencies are the trickiest to classify because they typically perform multiple activities across different KBLI categories. The strategy:
The order matters. Your primary KBLI code signals to regulators what your business fundamentally does. Lead with technology.
Recommended primary code: 62024 (IoT Consulting and Design) if IoT-focused, or 62029 (Other IT Activities) for general IT consulting
IT consulting firms that provide system integration, technology strategy, infrastructure design, and digital transformation services fit naturally into the 620xx code family. All IT consulting codes under Category K are classified as TERBUKA (open) with 100% foreign ownership allowed.
The 702xx consulting codes serve as powerful complements to IT codes, especially for businesses that combine technology delivery with advisory services.
Relevant for Bali tech companies that serve the hospitality industry. If you build hotel management software, tourism analytics platforms, or digital booking systems, pairing 62012 with 70201 covers both the technology and the advisory dimensions of your business.
Useful for digital agencies that provide communications strategy alongside their technology services. This code is low risk with 100% PMA allowed — a safe addition to any digital agency's NIB.
The broadest consulting code. Covers business strategy, operational consulting, management advisory, and general professional services. Low risk. Nearly every tech business can justify this as a secondary code for the advisory component of their client engagements.
Warning on 70202 (Transportation Consulting): This code carries a Tinggi (High) risk classification. Unless your business specifically consults on transportation systems, logistics infrastructure, or mobility technology, avoid it. The high-risk designation adds compliance complexity that most tech businesses do not need.
The mandatory compliance deadline for KBLI 2025 migration is June 18, 2026 (per BPS Regulation No. 7 of 2025). However, as of February 2026, the OSS (Online Single Submission) system has not yet been fully updated to support KBLI 2025 codes. This creates a window for preparation.
KBLI 2025 is, on balance, good news for technology businesses in Indonesia. The new classification system recognizes emerging sectors (IoT, VR/AR, immersive media) with dedicated codes. It maintains open foreign ownership for most IT and software activities. And it provides clearer boundaries between content businesses and technology businesses.
The risk lies in misclassification. A digital agency that registers as a content publisher when it should be an IT consultancy. A SaaS company that accidentally picks a high-risk digital identity code. A VR studio that lands in broadcasting instead of programming. These are avoidable mistakes with significant legal and financial consequences.
Choose your codes deliberately. Lead with Category K. Keep your risk level low. And make sure your classification reflects what your business actually does — not what it might do someday.
Need help classifying your tech business under KBLI 2025? Bali Zero provides end-to-end company setup and KBLI compliance advisory for tech startups, SaaS companies, and digital agencies operating in Bali. Contact us to get your classification right before the June 2026 deadline.