KBLI 2025 OSS Remediation | Verify NIB After June 2026

Q: When will OSS be updated to KBLI 2025?

Verify the current OSS workflow before acting. The June 2026 transition window has closed, so businesses should keep their mapping evidence ready and remediate any legacy KBLI 2020 records before new filings or amendments.

Q: What is OSS-RBA and how does it affect my business?

OSS-RBA (Risk-Based Approach) assigns your business a risk classification based on your KBLI code. Low risk = NIB only, medium risk = NIB + Standard Certificate, high risk = NIB + full Permit. KBLI 2025 may change your risk classification.

Q: What is Fiktif Positif?

For 258 specific KBLI codes, if the government doesn't respond to your license application within the SLA deadline, your permit is automatically approved. This mechanism encourages bureaucratic efficiency and benefits low-risk businesses.

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The Window Has Closed, but the Workflow Still Needs Verification

Indonesia mandated KBLI 2025 through BPS Regulation No. 7 of 2025, effective December 18, 2025, with a transition window that closed in June 2026. Every business operating in Indonesia should now verify that its registered activities align with the new classification system and document any remediation through the current OSS workflow.

There is one operational risk. The system businesses use to register those activities — the Online Single Submission (OSS) portal — must be verified live before filing. Do not rely on February 2026 portal behavior or assume every KBLI 2025 mapping is available for your sector.

This is not speculation. It is the documented operational reality. It now creates a remediation window where prepared businesses can move faster than operators starting from zero.

What Is OSS and Why It Matters

For anyone unfamiliar with the system, OSS (Online Single Submission) is Indonesia's centralized business licensing portal. Managed by BKPM (the Investment Ministry), it is the sole gateway for obtaining your NIB (Nomor Induk Berusaha) — the master business identification number that underpins every permit, license, and regulatory interaction your company will have in Indonesia.

When you register on OSS, you select KBLI codes that describe your business activities. The system then assigns each activity a risk classification using the Risk-Based Approach (RBA) framework. That classification determines your entire licensing pathway.

OSS-RBA Risk Classification

The following table shows how OSS-RBA categorizes business activities and what each risk level requires:

Risk Level	Classification	Licensing Requirement	Approval Process	Examples
Low	Minimal environmental/safety impact	NIB only	Automatic — issued instantly upon registration	Small retail, basic consulting, personal services
Medium-Low	Limited risk, standard oversight	NIB + Standard Certificate	Self-declared — business submits compliance statement	Restaurants under certain size, general trading, small workshops
Medium-High	Moderate risk, requires verification	NIB + Standard Certificate (Verified)	Government verification required — inspector reviews	Medium manufacturing, food processing, education services
High	Significant public safety/environmental impact	NIB + Full Permit (Izin)	Full assessment — AMDAL, technical review, site inspection	Large manufacturing, mining, hazardous chemicals, healthcare facilities

This table is not academic. Your KBLI code directly determines which row you fall into. When KBLI 2025 introduces new codes, splits existing ones, or reclassifies activities, your risk level — and therefore your entire licensing burden — can change overnight.

The Current Status: A System in Limbo

Here is what remains useful from the February 2026 operating picture, with live verification required before filing:

OSS readiness must be verified live. Earlier 2026 checks showed KBLI 2020 behavior in the portal. Do not rely on those observations today; confirm the current dropdowns, search functions, and risk-classification engine before filing.

The legal mandate is already in effect. BPS Regulation 7/2025 is not a future obligation — it is current law. Businesses are legally expected to operate under the new classification, yet the registration system does not support it.

No official migration date has been announced. BKPM has not published a timeline for the OSS update. Internal government coordination between BPS (which issues the classification), BKPM (which runs OSS), and the technical ministries (which define risk parameters for each code) is ongoing but opaque.

The June 2026 transition window has closed. There has been no indication of an extension. Treat unresolved KBLI 2020 mappings as overdue unless a live OSS or ministry instruction gives a different pathway for your sector.

This means businesses face a practical compliance risk: legacy mappings can surface during NIB amendments, LKPM submissions, permit renewals, import approvals, or sector-specific filings.

Why the Delay Exists

The OSS update is not a simple database swap. The system must integrate several interdependent layers:

Code mapping — Every KBLI 2020 code must be mapped to its 2025 equivalent(s). Some codes split into multiple new codes (one-to-many), others consolidate (many-to-one), and entirely new codes exist with no predecessor.
Risk parameter assignment — Each new KBLI 2025 code requires a risk classification from the relevant technical ministry. A new code for Carbon Capture (39001) needs KLHK to define whether it requires AMDAL. A new digital content code needs Kominfo to set verification requirements.
Investment list alignment — For PT PMA (foreign-owned companies), each code must be cross-referenced against the Positive Investment List (DNI) to determine foreign ownership limits and capital requirements.
System testing — OSS processes thousands of applications daily. Deploying a new classification engine without adequate testing would risk corrupting active applications, issuing incorrect risk levels, or blocking legitimate registrations.

The technical ministries are the bottleneck. BPS published the classification. BKPM is ready to integrate it. But without risk parameters from 30+ ministries and agencies for over 1,500 codes, OSS cannot calculate the licensing pathway.

The Remediation Strategy: Map Now, Execute Through the Live Workflow

The correct approach is not to wait passively. Businesses that prepare their evidence now can execute through the current OSS path faster than operators who discover the mismatch only when a transaction is blocked.

Step 1: Audit Your Current NIB

Log into OSS and document every KBLI code currently registered on your NIB. For each code, record:

The five-digit KBLI 2020 code
The associated risk classification (Low, Medium-Low, Medium-High, High)
The licenses and certificates issued under that code
Whether the activity is your primary (KBLI Utama) or secondary business line

Step 2: Map to KBLI 2025 Equivalents

Using the official concordance table published by BPS, identify the KBLI 2025 code(s) that correspond to each of your current codes. Pay attention to three scenarios:

Direct replacement (1:1) — Your code has a single, clear equivalent. This is the simplest case.
Code split (1:many) — Your current code has been divided into multiple specialized codes. You must determine which of the new codes accurately describes your actual operations.
Code consolidation (many:1) — Multiple old codes merged into one. Verify the new code covers all your registered activities.

Document every mapping with notes on why you selected each new code. This documentation serves as evidence of due diligence if audited.

Step 3: Assess Potential Risk Reclassification

Compare the risk classification of your current KBLI 2020 code with the expected classification of the KBLI 2025 equivalent. While official risk levels for new codes have not all been published, you can anticipate changes based on:

Whether your activity moved to a more specific or regulated sub-category
Whether new environmental or safety requirements have been attached to the sector
Whether the activity was previously in a grey area that is now explicitly classified

If your risk level increases — say from Low to Medium-High — you will need additional licenses that you did not previously require. Budget and plan for this now.

Step 4: Prepare Supporting Documents

Gather the documents you may need when the current OSS remediation path requires evidence:

Updated deed of establishment (if your business activities description needs revision)
Current NPWP and tax compliance certificates
Environmental documents if moving to a higher risk tier
Technical capability statements for newly classified activities
Updated shareholder/director information if any changes are pending

Step 5: Set Up Monitoring

OSS behavior can change without a long announcement window. Set up monitoring:

Check the OSS portal weekly for interface changes
Follow BKPM's official announcements and social media
Subscribe to updates from your legal/corporate secretary provider
Monitor industry associations and chambers of commerce for early signals

What to Expect When OSS Updates

When the current OSS workflow allows KBLI 2025 remediation, businesses should take immediate action. Here is the practical process to verify:

The Transition Process

Log into OSS at oss.go.id with your existing credentials
Navigate to your NIB profile and business activity section
Review the auto-mapped codes — OSS may automatically suggest KBLI 2025 equivalents for your registered activities
Verify or correct the mapping — Confirm each suggested code accurately reflects your operations, or manually select the correct KBLI 2025 code
Check your updated risk classification — The system will recalculate your risk level based on the new code
Confirm or apply for additional licenses — If your risk level increased, the system will prompt you to submit additional requirements
Download your updated NIB — Once all codes are confirmed and any new requirements are met, your NIB will reflect KBLI 2025

The entire process should be completable in a single session for businesses with straightforward mappings. Complex cases — particularly those with code splits or risk reclassifications — may require multiple sessions and additional document uploads.

Fiktif Positif: Your Safety Net

For businesses whose updated KBLI codes trigger new licensing requirements, the Fiktif Positif (Deemed Approval) mechanism provides an important safeguard.

Under PP No. 28 of 2025 and the Job Creation Law framework, Fiktif Positif applies to 258 specific KBLI codes. The principle is straightforward: if the relevant government agency fails to respond to your license application within the mandated Service Level Agreement (SLA), your application is automatically approved.

How Fiktif Positif Works in Practice

Stage	What Happens	Timeline
Application submitted	Business submits license application through OSS	Day 0
Routed to ministry	OSS forwards application to relevant technical ministry	Day 1
Review period	Ministry reviews, may request clarification	SLA varies by license type
SLA expires without response	No approval, rejection, or revision request issued	SLA deadline day
Automatic approval	OSS system changes status from "Pending" to "Approved"	Day after SLA expiry
License issued	Digital license/certificate generated with full legal validity	Immediate

The license issued through Fiktif Positif carries the same legal weight as a manually approved one. It is not a temporary or provisional document.

Important Caveats

Fiktif Positif does not eliminate accountability. The government retains the right to conduct post-license audits. If an audit reveals that the business does not actually meet the requirements for the license, the approval can be revoked retroactively. This shifts the model from pre-license gatekeeping to post-license enforcement.

Businesses should not rely on Fiktif Positif as a strategy to circumvent legitimate requirements. Instead, treat it as insurance against bureaucratic delay — submit complete and accurate applications, and let the mechanism protect you from slow processing.

Common Mistakes to Avoid

Registering under a "close enough" KBLI 2020 code while waiting. If your actual activity aligns with a new KBLI 2025 code that does not exist in the current system, do not register under an approximate KBLI 2020 code. This creates a discrepancy that could be flagged as data falsification during future audits.

Ignoring the transition because the portal path looks unclear. The legal obligation exists independent of interface uncertainty. Businesses that cannot demonstrate proactive remediation steps may face scrutiny after the deadline.

Assuming your risk level will stay the same. KBLI 2025 introduces new codes with potentially different risk profiles. A code split could place part of your operations in a higher risk tier, requiring licenses you have never needed before.

Waiting until a blocked transaction. When a filing, import approval, or LKPM report exposes a legacy mapping, the remediation window becomes compressed. Operators with pre-approved mapping evidence move faster than those starting from zero.

Timeline Summary

Date	Event	Action Required
December 18, 2025	KBLI 2025 takes legal effect	Begin preparation
Earlier 2026 baseline	OSS behavior required monitoring	Keep code mapping and evidence ready
Current OSS check	Verify live KBLI 2025 handling	Execute remediation through the current workflow
Post-window	Transition window closed	Treat unresolved KBLI 2020 mappings as overdue

The Bottom Line

The gap between KBLI 2025's legal mandate and day-to-day OSS execution is not a reason to delay remediation — it is the reason to accelerate it. Businesses that have their code mappings documented, their risk reclassifications anticipated, and their supporting documents ready can move faster when a filing exposes the issue.

The post-deadline question is whether your records are ready for the current OSS remediation path.

This article reflects the regulatory landscape as of February 2026. OSS system updates may change the procedures described. Consult with a licensed Indonesian corporate secretary or legal advisor for guidance specific to your business situation.