KBLI 2025 IT & Tech Investment Guide: Software Development, AI, Cloud Infrastructure & Digital Platforms in Bali

Indonesia's digital economy is approaching USD 100 billion in GMV with over 220 million internet users — 80% of the population. But 2026 is not a growth narrative year: it is a compliance reckoning year. The KBLI 2025 reclassification has deleted KBLI 63112 (the old hosting/cloud code) and replaced it with 63102. AI development finally has its own dedicated code: 62194. And the June 2026 migration deadline is non-negotiable for every tech company operating in Indonesia.

For digital entrepreneurs, software developers, and tech investors in Bali — particularly the 15,000+ digital nomad community concentrated in Canggu-Seminyak-Ubud — understanding which KBLI code governs your activity, and what legal structure is required to operate it, is the difference between sustainable business and deportation.

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The Critical KBLI 2025 Changes for IT/Tech

1. KBLI 63112 → KBLI 63102 (CRITICAL MIGRATION)

KBLI 2020: 63112 — Aktivitas Hosting dan Aktivitas Terkait KBLI 2025: 63102 — Aktivitas Penyediaan Infrastruktur Komputasi, Hosting, dan Layanan Terkait

What changed: The old 63112 has been formally deleted. The new 63102 explicitly covers:

• Infrastructure as a Service (IaaS)
• Platform as a Service (PaaS)
• Data center colocation
• Cloud computing infrastructure provision

Action required: All hosting/cloud operators must update OSS NIB from 63112 → 63102 now that the June 2026 transition window has closed. Failure invalidates LKPM submissions and e-Faktur integrations.

2. KBLI 62194 — AI/ML Development (NEW CODE)

KBLI 2020: No dedicated code (filed under 62010 or 62900) KBLI 2025: 62194 — Aktivitas Pengembangan Komponen Dasar Kecerdasan Buatan

AI, machine learning, and autonomous agent development now has a dedicated KBLI code. Companies building AI components, LLM applications, ML models, and autonomous workflow systems must register under 62194.

3. Category Split: J (Content/Media) vs K (Infrastructure/Tech)

KBLI 2025 splits the former unified "Information and Communication" category:

• Category J — Publishing, broadcasting, digital content production, streaming
• Category K — Telecommunications, software programming, cloud computing, IT consulting

This split affects investor eligibility and PMA rules — verify your primary category against the new taxonomy.

4. KBLI 2020 → 2025 Critical Migrations

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The Digital Nomad Legal Trap

Before reviewing individual KBLI codes, the most critical issue for Bali's tech community must be addressed.

The E33G Visa (Remote Worker KITAS) Problem:

Over 15,000 foreign tech workers in Bali operate on E33G visas (Visa Penduduk Jangka Panjang for remote workers). Requirements: USD 2,000 minimum bank balance + USD 60,000/year income from outside Indonesia.

What E33G permits: Working remotely for foreign companies while based in Bali. What E33G prohibits: Earning income from Indonesian entities or clients.

Foreign developers building SaaS tools and offering services to Bali villa operators, hospitality companies, or Indonesian businesses while on E33G are committing:

• A serious immigration violation
• Subject to deportation and IDR 1,000,000/day overstay fines
• Criminal liability under UU Keimigrasian

The only legal path to serve Indonesian B2B clients: Establish a PT PMA under the appropriate KBLI code. Setup cost: ~IDR 18M. Processing time: 2-3 weeks. This is the legal vehicle that converts your Bali tech operation from a visa violation into a compliant business.

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KBLI 62110: Video Game Development

Code: 62110 Title: PENGEMBANGAN VIDEO GIM, PERANGKAT LUNAK VIDEO GIM, DAN KONTEN INTERAKTIF LAINNYA PMA Status: 100% Foreign Ownership Allowed Activity: Game development, game engine programming, interactive entertainment software production.

2026 Investment Intelligence

Market Sentiment: Indonesia's interactive entertainment market exceeds USD 1.1B with 174M+ active players — yet 99.51% of revenue flows to foreign publishers. The government-backed Indonesia Game Developer Exchange (IGDX), hosted annually in Bali, is actively catalyzing domestic studio development. Cultural IP (Wayang mythology, Ramayana narratives, Nusantara historical epics) represents an untapped blue ocean for original Indonesian game IP.

2026 Regulatory: Indonesia Game Rating System (IGRS)

Mandatory from 2026, IGRS requires all games distributed on Indonesian platforms to carry age classification:

• 3+, 7+, 13+, 15+, 18+ aligned with IARC/ESRB/PEGI international standards
• Games with gambling mechanics using real currency: automatic blocking by Komdigi
• Games with extreme mutilation or cannibalism: Refused Classification

Operational Risks:

• IGRS submission: trailers, gameplay demos, and monetization descriptions (loot boxes, gacha) must be precisely accurate — post-classification gameplay changes risk license revocation
• PSTE registration mandatory for online multiplayer games with Indonesian user accounts
• UU PDP: games collecting under-18 demographic data face criminal DPO liability
• TKA: foreign Game Directors and Lead Programmers permitted; junior roles closed to TKA

Investment Outlook: Early-stage but high-potential. IGDX government matching grants available for studios under 62110. Cultural IP conversion (traditional Indonesian storytelling → AAA interactive narrative) is the strongest competitive moat against dominant foreign publishers.

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KBLI 62191: E-Commerce Application Development

Code: 62191 Title: AKTIVITAS PENGEMBANGAN APLIKASI PERDAGANGAN MELALUI SISTEM ELEKTRONIK DAN SEJENISNYA PMA Status: 100% Foreign Ownership Allowed Activity: Development of e-commerce platforms, marketplace applications, online transaction systems, D2C (direct-to-consumer) digital commerce.

2026 Investment Intelligence

Market Sentiment: E-commerce application development rides Indonesia's GMV trajectory past USD 100B. Video commerce (live shopping) is the dominant growth vector: 75% of sellers using video features report 90% YoY transaction volume growth.

Bali-Specific Opportunity: B2B e-commerce tools for Bali's artisan and sustainable fashion export sector — platforms connecting Balinese craft producers to international B2B buyers — are an underserved niche with strong export economics.

Operational Risks:

• PPN 12% digital: E-commerce platforms are designated Pemungut PPN — payment architecture must automatically deduct and remit 12% VAT on digital transactions
• PSTE registration (Komdigi PP 71/2019) mandatory before platform launch
• UU PDP: platforms processing Indonesian consumer transaction data require DPO if operating at scale
• Komdigi content takedown authority: platforms hosting fraudulent sellers or prohibited content face immediate domain blocking within 24 hours of Komdigi order
• OTA competition: Bali hospitality booking platforms face formidable network effects from Airbnb/Booking.com

Investment Outlook: Niche B2B tools (channel manager, inventory sync, cross-border logistics API) for Bali's SME hospitality sector represent IDR 50B+ addressable market. D2C platforms for Bali artisan export brands have 3-year international growth trajectory.

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KBLI 62192: Health-Tech Application Development

Code: 62192 Title: AKTIVITAS PENGEMBANGAN APLIKASI DAN PRODUKSI KONTEN DIGITAL BIDANG KESEHATAN PMA Status: 100% Foreign Ownership Allowed Activity: Development of medical applications, telehealth platforms, EMR systems, health data management, medical diagnostic software.

2026 Investment Intelligence

Market Sentiment: Health-tech is Indonesia's fastest-growing software sub-sector. KEK Sanur's medical tourism infrastructure — Bali International Hospital, Mayo Clinic partnership, IDR 2.29T investment — creates immediate and sustained demand for EMR systems, telemedicine platforms, patient data management, AI diagnostics, and clinical trial management software.

KEK Sanur as Bali's Health-Tech Hub: The 41-hectare international medical zone needs:

• Bilingual (English-Bahasa) EMR systems compatible with JCI/KARS accreditation standards
• Patient management platforms handling cross-border insurance claims
• Telemedicine APIs for international specialist consultations
• Genomics data pipelines for precision medicine research

Operational Risks:

• UU PDP Critical: Clinical data is "data spesifik/sensitif" — Constitutional Court July 2025 ruling makes DPO appointment mandatory for ANY health-tech company processing medical records, regardless of scale
• Data localization: Health data of Indonesian patients cannot be transferred offshore without Ministry of Health approval — servers must be Indonesia-resident
• BPOM electronic labeling: Draft regulation requires apps distributing pharmaceutical products to display ingredient origin and alcohol content — Halal certification integration required by October 2026
• OJK POJK 30/2025 applies if health app interfaces with BPJS payment systems or insurance products

Investment Outlook: 10-year growth runway anchored by KEK Sanur infrastructure. International hospital groups partnering with Mayo Clinic need certified, JCI-compatible health software that local Indonesian vendors cannot yet provide — this is the prime PT PMA opportunity.

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KBLI 62193: Fintech Application Development

Code: 62193 Title: AKTIVITAS PENGEMBANGAN APLIKASI BERBASIS TEKNOLOGI KEUANGAN (FINANCIAL TECHNOLOGY) PMA Status: 100% Foreign Ownership Allowed Activity: Development of financial technology applications — neo-banking, P2P lending, payment gateways, QRIS integration, alternative credit scoring, Islamic fintech.

2026 Investment Intelligence

Market Sentiment: Indonesian fintech projects USD 35B market size by 2031 at 9%+ CAGR. Neo-banking, QRIS payment integration, and alternative credit scoring are primary development verticals.

Bali-Specific Opportunity: QRIS ITTP (Indonesia Tourist Travel Pack) integration for Bali's cashless tourism ecosystem is a near-term, high-demand development project. The 7M+ annual international tourist flow creates demand for multi-currency QRIS solutions, instant IDR conversion tools, and tourism-specific payment UX.

Regulatory Gauntlet:

OJK POJK 30/2025 (Regulatory Sandbox):

• Every fintech application must pass Regulatory Sandbox before commercial launch
• Process: 6-18 months, very selective approval rate
• Requirements: minimum 2 qualified board directors, comprehensive risk governance documentation

Komdigi Biometric SIM Registration (Peraturan 7/2026):

• Mandatory biometric facial recognition for SIM card registration from July 2026
• Forces fintech apps to synchronize OTP and KYC flows with national biometric identity database
• API integration with national identity database required for AML/KYC compliance

PSTE registration: Mandatory for any fintech platform with Indonesian users.

Investment Outlook: Strong long-term but regulatory sandbox gatekeeping creates 6-18 month pre-revenue period. Best entry: narrow vertical (QRIS tourism payments, Islamic finance digitalization) rather than broad neo-banking reduces sandbox complexity.

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KBLI 62194: AI & Machine Learning Development

Code: 62194 Title: AKTIVITAS PENGEMBANGAN KOMPONEN DASAR KECERDASAN BUATAN PMA Status: 100% Foreign Ownership Allowed Activity: Development of AI/ML core components, autonomous agents, LLM applications, ML models, AI automation platforms.

2026 Investment Intelligence

Market Sentiment: AI development is Indonesia's highest-growth software vertical in 2026. Enterprise demand for AI agents, workflow automation, and ML model development is accelerating. Agentic AI platforms (replacing fragmented SaaS stacks with unified AI orchestration) represent the frontier opportunity.

Bali Captive Market: The Canggu/Seminyak ecosystem has a high concentration of AI developers building automation tools for Bali's hospitality sector:

• Villa management AI (dynamic pricing, guest communication bots)
• Predictive maintenance systems (IoT sensors for pool pumps, HVAC)
• AI concierge platforms for 24/7 multilingual guest service
• Revenue optimization engines (RevPAR maximization)

These 10,000+ short-term rental properties are currently managed mostly manually — a captive addressable market for AI automation tools.

The E33G Trap (critical for AI developers): Many AI developers in Canggu are offering these automation services to villa operators while on E33G visas. This is a deportation risk. Legal path: PT PMA under 62194. Setup ~IDR 18M, 2-3 weeks processing.

TKDN Government Contracts: AI platforms targeting BUMN or government contracts must achieve 25% TKDN + 40% BMP (Bobot Manfaat Perusahaan) under Perpres 46/2025. Requirements: local data processing, Indonesian engineering staff, or R&D investment in Indonesia.

Investment Outlook: IDR 2.5B PT PMA setup unlocks the Bali hospitality automation market. AI subscription model targeting 20-30 villa operators can achieve IDR 200M+ ARR within 12 months.

Legacy Bridge: 62194 is entirely new in KBLI 2025 — no equivalent existed in KBLI 2020. AI developers previously registered under 62010 or 62900 must register 62194 for AI-specific activities.

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KBLI 62900: Other IT & Computer Services

Code: 62900 Title: AKTIVITAS JASA TEKNOLOGI INFORMASI DAN KOMPUTER LAINNYA PMA Status: 100% Foreign Ownership Allowed Activity: Custom software development, IT systems integration, IoT consulting, software architecture advisory, general IT services not covered by 62191-62194.

2026 Investment Intelligence

Market Sentiment: Catch-all IT services code for multi-service technology firms. Highly relevant for Bali's villa management tech, property management system (PMS) customization, and bespoke software development for wellness retreats.

When to use 62900 vs. specialized codes:

• 62191: Primarily e-commerce platform development
• 62192: Primarily health/medical application development
• 62193: Primarily fintech application development
• 62194: Primarily AI/ML component development
• 62900: Multi-service IT consultancy, custom development, systems integration, IoT

Operational Risks:

• Scope precision: actual services must match OSS KBLI description — cross-scope billing triggers PP 28/2025 audit
• E33G visa trap: same deportation risk as 62194 for foreign developers serving Indonesian clients
• TKA: senior IT architects and project managers permitted; junior developers and admins closed to TKA
• PSTE registration required for deployed software platforms with Indonesian users

Investment Outlook: Stable IT services model. Bali's 10,000+ short-term rental properties represent IDR 500B+ annual addressable tech spend.

Legacy Bridge: KBLI 2020 62090 → KBLI 2025 62900. Treat OSS/NIB remediation as overdue if it is still unresolved.

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KBLI 63101: Data Processing Services

Code: 63101 Title: AKTIVITAS PENGOLAHAN DATA PMA Status: 100% Foreign Ownership Allowed Activity: Data processing bureaus, analytics services, data pipeline operations, ML training data processing.

2026 Investment Intelligence

Market Sentiment: Data processing demand is surging from: (1) local ML model training (TKDN rules creating demand for Indonesia-resident data processing), (2) KEK Sanur genomic and medical imaging analytics, (3) CoreTax CTAS audit support and tax data analytics.

KEK Sanur Anchor Demand: The Bali International Hospital complex needs:

• Genomics data processing pipelines
• Medical imaging AI analytics (low-latency, Indonesia-resident)
• Clinical trial data management
• Cross-institutional patient record processing

Critical: KBLI Migration 63111 → 63101

Many data processing companies are registered under KBLI 2020 63111. In KBLI 2025, this is renumbered to 63101. Failure to update OSS NIB now that the June 2026 transition window has closed will invalidate LKPM submissions and e-Faktur integrations.

Operational Risks:

• UU PDP: data processors handling personal data at scale must appoint DPO — no exemptions post-Constitutional Court ruling
• BSSN cybersecurity certification required for government and financial data processing contracts
• TKDN Perpres 46/2025 Layer 1 (25% TKDN + 40% BMP): required to compete for BUMN/government data processing contracts

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KBLI 63102: Cloud Computing & Hosting Infrastructure

Code: 63102 Title: AKTIVITAS PENYEDIAAN INFRASTRUKTUR KOMPUTASI, HOSTING, DAN LAYANAN TERKAIT PMA Status: 100% Foreign Ownership Allowed Activity: IaaS, PaaS, data center colocation, cloud computing infrastructure, hosting services.

2026 Investment Intelligence

Market Sentiment: Cloud infrastructure is in a structural permitting crisis — KBLI 63112 has been deleted and replaced with 63102. Companies still registered under 63112 will have their OSS profiles invalidated after June 2026. This is simultaneously a threat (for non-compliant incumbents) and a market entry opportunity (for compliant new entrants).

Bali's Edge Computing Opportunity: Canggu/Seminyak coworking ecosystem with 15,000+ remote workers demands low-latency edge computing nodes. Microserver installations in co-working facilities provide stable compute capacity without the latency of Jakarta-based data centers.

TKDN Government Procurement (Perpres 46/2025):

International cloud providers (AWS, GCP, Azure) without Indonesian data centers are locked out of Layer 1-2 government contracts — creating subcontract revenue opportunities for local cloud operators who can serve as certified Indonesian infrastructure partners.

Operational Risks:

• June 2026 migration deadline: 63112 → 63102 is non-negotiable
• BSSN certification required for providers handling government or financial data
• Data residency: all Indonesian user data must be stored on Indonesia-resident infrastructure (KMK financial data rules)
• Komdigi PSTE registration mandatory

Investment Outlook: Structural opportunity driven by data localization mandates and TKDN procurement rules. Rack colocation model in Bali coworking facilities achieves IDR 500M+ ARR with low capex.

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KBLI 63900: Web Portals & Digital Information Platforms

Code: 63900 Title: AKTIVITAS JASA PORTAL PENCARIAN WEB DAN INFORMASI PMA Status: 100% Foreign Ownership Allowed Activity: Web portals, digital information platforms, search portals, community platforms, vertical industry portals.

2026 Investment Intelligence

Market Sentiment: Web portals show moderate growth compared to the e-commerce peak. Niche vertical portals (luxury villa booking, curated wellness retreats, B2B property listings, regulatory compliance resources) outperform horizontal general portals.

Digital Nusantara Integration Opportunity: The government's Digital Nusantara Tourist Information Center (launched late 2024) is creating integration partnership opportunities for:

• E-visa processing portal integrations
• QRIS ITTP cashless payment portal interfaces
• Verified destination information content partnerships
• Tourist analytics data sharing agreements

Operational Risks:

• PSTE registration: mandatory before operating in Indonesia — Komdigi will block domain unilaterally if non-compliant
• Content moderation: Komdigi takedown orders must be executed within 24 hours or platform faces suspension
• UU ITE liability: user-generated defamatory content triggers criminal liability for platform operators who fail to remove it
• PPN 12% digital: premium listing fees and transaction commissions must include and remit digital services tax
• Cookie/tracking: ad-targeting via cookies requires user consent under UU PDP's new disjunctive DPO threshold

Investment Outlook: Luxury villa and wellness retreat vertical portals serving international B2B travel trade (DMCs, luxury travel agencies) show highest ARPU. Government portal integration partnerships represent non-dilutive revenue.

Legacy Bridge: KBLI 2020 63120 → KBLI 2025 63900. Treat the OSS/NIB update as overdue if it is still unresolved.

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Regulatory Compliance Matrix for Bali Tech PT PMA

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PT PMA Setup for Tech Founders in Bali

For the Canggu/Seminyak digital nomad community wanting to legally serve Indonesian B2B clients:

Minimum viable PT PMA (tech/software):

1. Company name (exactly 3 words — e.g., "PT Bali Teknologi Digital")
2. KBLI code selection (62194 for AI, 62900 for general IT, etc.)
3. Physical or virtual office address (minimum 1-year lease)
4. IDR 2.5B paid-up capital (USD ~150K) — maintain in company account 12 months
5. Indonesian corporate notary + BKPM registration — IDR 18M-50M total setup cost
6. RPTKA for any foreign employee/founder holding executive title

Processing time: 2-3 weeks for standard applications via OSS.

E33G visa transition: Foreign tech founders can operate on E33G while PT PMA is being established, but cannot bill Indonesian clients until PT PMA NIB is issued. Plan for a 2-3 week gap period.

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Data sourced from KBLI 2025 (BPS Reg. 7/2025), PP 28/2025 (OSS-RBA), BKPM Reg. 5/2025, UU PDP 27/2022, Constitutional Court Decision 151/PUU-XXII/2024, Komdigi PP 71/2019, OJK POJK 30/2025, Perpres 46/2025 (TKDN), Kepmenaker 228/2019. Intelligence accurate as of February 2026. Consult a qualified Indonesian corporate lawyer before establishing PT PMA operations.