The Broadcasting Tax on Digital Innovation
If you are building a streaming platform, podcast network, or social media app in Indonesia, KBLI 2025 has a surprise for you: your digital business inherits a regulatory framework designed for television and radio broadcasters. This is not a metaphor. The two primary streaming codes in KBLI 2025 — 60103 (audio streaming) and 60203 (video streaming) — were directly renumbered from their broadcasting predecessors, 60102 and 60202 respectively. They carried their licensing requirements with them.
The consequence is concrete. Both codes are classified as Tinggi (High Risk) under PP 28/2025, with a 29-day processing timeline that includes administrative review, technical inspections, and fee verification. Applicants must submit broadcasting plans with revenue projections, coverage maps, facility specifications, sworn statements, and undergo an operational feasibility test. These are requirements that make sense for a television network broadcasting to millions. For a podcast hosting platform or a niche music streaming service, they represent a significant regulatory burden.
Yet there is also good news. All three streaming and digital media codes — 60103, 60203, and the brand-new 60390 (social media platforms) — allow 100% foreign ownership through PT PMA. Indonesia has not restricted foreign capital from entering digital media. It has, however, required that foreign-owned digital media companies navigate a licensing process that was built for an earlier era of content distribution.
This article maps every streaming and digital media code in KBLI 2025, explains the licensing requirements, and provides a practical framework for determining whether your Bali-based business actually needs these codes — or whether you are better served by alternatives.
Complete Table: Streaming and Digital Media KBLI 2025 Codes
The following table covers the three codes directly relevant to streaming platforms, on-demand media services, and social media operators in Indonesia.
| KBLI Code | Name (English) | Risk Level | Processing | PMA % | Origin |
|---|---|---|---|---|---|
| 60103 | Audio Streaming & On-Demand Distribution | Tinggi (High) | 29 days | 100% | Renumbered from 60102 |
| 60203 | Video Streaming & On-Demand Distribution | Tinggi (High) | 29 days | 100% | Renumbered from 60202 |
| 60390 | Social Media & Content Distribution | BPS Only | Pending | 100% | NEW in 2025 |
Key: "BPS Only" means the code exists in the BPS statistical classification but has not yet been assigned a formal risk level under PP 28/2025. "Pending" processing time means the licensing framework is still being developed. A code's origin indicates whether it was renumbered from a KBLI 2020 predecessor or is entirely new.
60103 — Audio Streaming: When Spotify Meets Broadcasting Law
KBLI 60103 covers all forms of audio streaming and on-demand audio distribution. This includes music streaming platforms, podcast hosting and distribution services, audiobook platforms, on-demand audio libraries, and any business that delivers audio content to consumers over the internet on a subscription, ad-supported, or pay-per-download basis.
What It Covers
Any platform that enables users to stream or download audio content on demand falls under 60103. If your business model involves aggregating, hosting, or distributing audio content created by third parties — or original audio content produced in-house — this is your code. Think Spotify, Apple Podcasts, Audible, SoundCloud, or any regional equivalent.
What It Does NOT Cover
Traditional radio broadcasting remains under 60101 (public radio) and 60102 (commercial radio). If your business broadcasts scheduled audio programming over radio frequencies, those codes apply instead. Code 60103 is specifically for internet-based, on-demand audio delivery.
Content creators who produce audio but distribute through existing platforms (uploading podcasts to Spotify, publishing audiobooks on Audible) do not need 60103. That code is for the platform operator, not the content creator.
Licensing Requirements
Because 60103 inherited its regulatory framework from broadcasting, the licensing burden is substantial:
- NIB (Nomor Induk Berusaha) plus full Izin (license) — not just a standard business registration
- Broadcasting plan with revenue projections demonstrating financial viability
- Coverage maps specifying the geographic scope of your service
- Facility specifications detailing your technical infrastructure
- Sworn statement (surat pernyataan) regarding compliance with broadcasting regulations
- Operational feasibility test conducted by the licensing authority
- Broadcasting license fee payable upon approval
Processing Timeline
The 29-day processing timeline breaks down as follows: 7 days for administrative review of submitted documents, 15 days for the technical inspection and feasibility assessment, and 7 days for fee verification and final approval. The licensing authority is the Minister or Agency Head (not a local government office), which means decisions are made at the national level.
Bali Context
In practice, most Bali-based podcast creators and audio content producers avoid 60103 entirely. They operate as content producers under creative or IT codes — distributing through established platforms like Spotify, Apple Podcasts, or YouTube Music where the platform operator bears the broadcasting regulatory burden. Only entrepreneurs who intend to build and operate their own audio streaming platform need this classification.
60203 — Video Streaming: VOD in the Broadcasting Framework
KBLI 60203 covers video streaming and on-demand video distribution. This is the code for subscription video-on-demand (SVOD) platforms, ad-supported video services (AVOD), digital video download stores, and — notably — game streaming platforms where the business model is view-only content delivery (similar to Twitch).
What It Covers
The scope of 60203 is broad within the video domain:
- Subscription video platforms (Netflix-style, where users pay monthly for access to a library)
- Ad-supported video services (free-to-watch platforms monetized through advertising)
- Pay-per-view and digital download stores for video content
- Game streaming platforms where the service delivers video of gameplay to viewers (Twitch-style platforms fall here, not under gaming codes, because the core service is video delivery)
The game streaming classification is a point of confusion worth addressing directly. If your platform allows users to watch other people play games — live or on-demand — that is video streaming under 60203. If your platform allows users to play games themselves (cloud gaming where the user controls the game remotely), that falls under different codes in the gaming and IT sectors.
Licensing Structure
The licensing requirements for 60203 are identical to 60103: NIB plus full Izin, broadcasting plan, coverage maps, facility specifications, sworn statement, operational feasibility test, and broadcasting license fee. The same 29-day processing timeline applies, with the same administrative-technical-fee breakdown.
One additional consideration applies to video streaming: if your service uses foreign satellite infrastructure for content delivery, you may need to obtain Hak Labuh Satelit (Satellite Mooring Rights). This is relevant for platforms that rely on satellite-based CDN infrastructure rather than purely terrestrial internet delivery. Most modern streaming services use terrestrial CDN networks (AWS CloudFront, Google Cloud CDN, Cloudflare), making this requirement inapplicable, but it is worth verifying if your infrastructure design involves satellite components.
Bali Context
The same practical dynamic applies here as with audio streaming. Most video content creators based in Bali distribute through YouTube, Instagram Reels, TikTok, or Vimeo — platforms where the operator holds the broadcasting licenses. A Bali-based filmmaker who publishes content on YouTube does not need KBLI 60203. A Bali-based startup building a video streaming platform for the Indonesian market does.
For businesses focused on video and film production rather than platform operation, the relevant codes are in a different family entirely: 59112 (film production) and 59201 (sound recording and music publishing). These carry different risk profiles and are covered in our guide on KBLI 2025 Creative and Design Industry codes.
60390 — Social Media Platforms: The New Frontier
KBLI 60390 is an entirely new code in KBLI 2025 with no predecessor in KBLI 2020. It represents Indonesia's first formal classification for social media platform operators — a recognition that social media has become a distinct business category requiring its own regulatory framework.
What It Covers
The scope of 60390 is deliberately broad, encompassing the full spectrum of social media and user-generated content platforms:
- Social networking sites (platforms enabling user connections, profiles, and social interaction)
- Content sharing platforms (user-generated content hosting and distribution)
- Blog and wiki platforms (publishing infrastructure for user-created text content)
- Gaming video sites (platforms specifically for gaming-related video content)
- E-book distribution platforms (digital book marketplaces)
- Digital game marketplaces (platforms selling game vouchers, in-game items, and digital game downloads)
The inclusion of digital game marketplaces and e-book distribution under a "social media" code may seem unusual, but it reflects the convergence of social features, content distribution, and digital commerce that characterizes modern platforms. A platform like Steam, which combines game sales, community features, user reviews, and streaming, would logically fall under 60390.
Regulatory Status: BPS Only
As of February 2026, KBLI 60390 exists in the BPS (Badan Pusat Statistik) classification system but has not yet been assigned a formal risk level under PP 28/2025. This means:
- The code is valid for statistical and classification purposes
- No formal licensing pathway has been established through OSS
- The processing timeline, specific permit requirements, and compliance obligations are still pending
- PSE (Penyelenggara Sistem Elektronik) registration with Kominfo is mandatory regardless of the PP 28/2025 status — all digital platform operators must register as electronic system providers
Given the regulatory trajectory of Indonesia's digital governance, 60390 is widely expected to receive a Tinggi (High Risk) classification when it is formally integrated into the PP 28 framework. Social media platforms involve content moderation, data privacy, user safety, and information integrity — all areas of increasing regulatory focus.
The Critical Distinction: Operators vs. Creators
This is the single most important point about KBLI 60390: it applies to platform operators, not content creators.
If you are building a social networking application, a content sharing platform, or a digital marketplace — you are an operator and need 60390. If you are creating content on Instagram, posting videos on TikTok, writing on Medium, or selling products through an existing marketplace — you are a user of someone else's platform and do not need this code.
This distinction eliminates 60390 from consideration for the vast majority of Bali's digital entrepreneurs, who create and distribute content through established platforms rather than building their own.
The Practical Question: Do You Actually Need These Codes?
For most Bali-based content creators and digital entrepreneurs, the honest answer is no. The streaming and social media codes (60103, 60203, 60390) are designed for platform operators — companies that build, host, and operate the infrastructure through which content is delivered. The regulatory burden reflects this: broadcasting plans, technical inspections, and license fees are appropriate for platform-scale operations, not for individual creators or small content studios.
When You Do NOT Need Streaming Codes
- You create content and distribute it on existing platforms (YouTube, Spotify, TikTok, Instagram, Medium)
- You produce podcasts and publish them through established podcast directories
- You create video content for clients who distribute it through their own channels
- You run a digital marketing agency that manages social media accounts but does not operate a social media platform
When You DO Need Streaming Codes
- You are building a streaming platform (audio or video) that hosts and delivers content
- You are creating a social media application or content-sharing platform
- You are developing a digital marketplace for games, e-books, or digital content
- You are operating a podcast network with your own hosting and distribution infrastructure (not just publishing to Spotify)
Alternative Codes That Bali Creators Actually Use
For the majority of digital media businesses in Bali, these codes provide a cleaner regulatory path:
| KBLI Code | Name | Risk Level | Use Case |
|---|---|---|---|
| 62199 | Software Development | Rendah (Low) | Building the app or platform itself |
| 63101 | Data Processing | Rendah (Low) | Hosting, CDN infrastructure, data management |
| 73100 | Advertising | Rendah (Low) | Ad-supported content businesses, digital advertising |
| 59112 | Film Production | Rendah (Low) | Original video content creation |
| 59201 | Sound Recording & Music | Rendah (Low) | Audio content production, music publishing |
These codes carry low risk classifications, shorter processing times, and significantly less regulatory overhead than the broadcasting-derived streaming codes. For a detailed breakdown of IT and software codes, see our comprehensive guide on KBLI 2025 IT Services and Software.
Strategic Considerations for Bali Entrepreneurs
The Regulatory Burden Is Real but Navigable
For well-funded platform ventures with genuine scale ambitions in the Indonesian market, the 29-day processing timeline and broadcasting-era licensing requirements are obstacles, not barriers. Companies like Vidio (Emtek Group), GoPlay (Gojek), and various IPTV operators have successfully navigated this framework. The licensing process is bureaucratic and time-consuming, but it is well-documented and procedurally transparent.
The key variables are capital and patience. The broadcasting plan requires credible revenue projections and infrastructure documentation. The technical inspection requires functioning facilities. The license fee requires budget. None of these are insurmountable for a serious venture, but they are prohibitive for bootstrapped startups testing a minimum viable product.
The 29-Day Timeline Is Theoretical
The stated 29-day processing timeline (7 + 15 + 7) represents the regulatory maximum. Actual processing times vary based on application completeness, agency workload, the complexity of the proposed service, and whether the applicant requires clarification or revision during the technical review. In practice, first-time applicants should plan for a longer timeline and factor in pre-submission consultation with the licensing authority.
Kominfo PSE Registration Is Separate and Mandatory
Regardless of your KBLI code, all digital platform operators must register as a Penyelenggara Sistem Elektronik (PSE) with Kominfo (Ministry of Communication and Information Technology). This registration is separate from your NIB and KBLI-based licensing. It covers data localization requirements, content moderation obligations, takedown response timelines, and cooperation with law enforcement. PSE registration applies whether you use code 60103, 60203, 60390, or any other code — if you operate a digital platform accessible to Indonesian users, you must register.
Content Moderation Obligations Are Increasing
Indonesia's regulatory stance on content moderation has tightened significantly. Platform operators face obligations around harmful content removal, misinformation response, child safety, and hate speech. These obligations apply to all platform operators and are enforced through both PSE requirements and broadcasting regulations. For streaming platform operators, content moderation is not optional — it is a licensing condition.
Platform Operation vs. Content Creation
Before committing to streaming codes, ask a fundamental strategic question: does your business model truly require you to operate a platform, or are you better served creating content and distributing through established platforms? The regulatory difference between these two approaches is enormous. A content creator operating under KBLI 59112 (film production) faces low risk, minimal licensing, and straightforward compliance. A platform operator under KBLI 60203 faces high risk, broadcasting-era licensing, and ongoing regulatory oversight. If your competitive advantage lies in content quality rather than platform infrastructure, the content creation path is almost always the better regulatory strategy.
The Migration Timeline
The June 2026 KBLI 2025 transition window under BPS Regulation No. 7 of 2025 has closed. Verify the current OSS workflow before filing, and treat any legacy KBLI 2020 mapping as overdue for remediation.
What to Do Now
- Determine your classification need. Are you a platform operator (60103/60203/60390) or a content creator (59112/59201/62199)? This distinction determines your entire regulatory path.
- Audit existing codes. If your PT PMA currently holds KBLI 2020 codes 60102 or 60202, confirm that the renumbered versions (60103/60203) still match your actual business activities.
- Prepare broadcasting documentation. If you genuinely need streaming codes, begin assembling the broadcasting plan, revenue projections, coverage maps, and facility specifications now. These documents take time to prepare properly.
- Register PSE with Kominfo. This is mandatory for all platform operators and can be completed independently of the KBLI migration.
- Monitor OSS updates. When OSS adds support for KBLI 2025 codes, you want to submit immediately with complete documentation.
For a broader view of the KBLI 2025 migration process and what it means for Bali businesses across all sectors, see our overview article on KBLI 2025 and Bali's Business Transformation.
Building a streaming platform or digital media business in Bali? Bali Zero provides end-to-end PT PMA setup and KBLI compliance advisory for digital media ventures, from code selection through broadcasting license applications. Contact us to navigate the regulatory framework after the June 2026 transition window.
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