Published 22 May 2026. The compliance deadline is 18 June 2026, which is 27 days from the date of publication.
BPS Regulation No. 7 of 2025 came into force on 18 December 2025. It revoked KBLI 2020, established KBLI 2025 as Indonesia’s operative standard industrial classification, and set a six-month transition deadline of 18 June 2026 for all entities to align their registered business classifications with the new framework. That deadline applies to every PT PMA operating in Indonesia, and it is 27 days away.
For many entities, the migration from KBLI 2020 to KBLI 2025 will be automatic and will require no company action. For PT PMA entities whose 2020 codes split into multiple 2025 codes, the migration requires a structured assessment, a decision on which codes to carry forward, and in some cases an amendment to the company’s articles of association. The articles of association amendment process operates under Permenkum 49/2025, which tightened the procedures for corporate amendments at the Ministry of Law in December 2025. PT PMA entities that identify a code split requiring an articles of association amendment have fewer days remaining than the calendar suggests, because the notarisation and SABH registration process under the revised procedures takes longer than it did before December 2025.
What KBLI Is and Why It Determines Licences, Investment, and Risk
The Klasifikasi Baku Lapangan Usaha Indonesia is Indonesia’s national standard for classifying business activities. Every company registered in Indonesia carries one or more KBLI codes. Those codes define what the company is legally permitted to do, how the OSS risk-based licensing system classifies its operational risk, which licenses it is eligible to apply for, and whether the activity is open to foreign investment or subject to restriction under the applicable investment rules.
For a PT PMA, the KBLI code defines the legal scope of its permitted business activities and carries direct consequences across its investment position, its foreign investment status, and its licensing obligations. The code is the primary reference through which the OSS system determines whether an activity is open to foreign capital investment under the Positive Investment List. It also sets the applicable investment threshold at IDR 10 billion per five-digit KBLI code per project location under BKPM Regulation No. 5 of 2025, with IDR 2.5 billion in paid-up capital. Because the risk classification of each business activity derives from the KBLI code, any reclassification changes the licences and permits the company must carry before operations can commence.
A KBLI code change revises the legal foundation on which the company’s licences, investment commitments, and regulatory compliance position rest.
What BPS Regulation No. 7 of 2025 Changed
The regulation aligned Indonesia’s classification system with the International Standard Industrial Classification of All Economic Activities, Revision 5 (ISIC Rev. 5). The revision reflected changes in the structure of the Indonesian economy, particularly in digital services, platform-based business models, climate-related activities, green economy sectors, and health-related wholesale trade.
The number of classification categories increased from 21 to 22. Across the code structure, the changes took three forms.
In the majority of cases, the transition is a direct renumbering: a 2020 code is assigned a new five-digit number under KBLI 2025 without any change to the scope of the classified activity. Updates of this type are processed automatically in the OSS system and require no company action.
Where several 2020 codes merge into a single 2025 code, the consolidation is similarly handled automatically and requires no additional steps.
Where a single 2020 code divides into two or more distinct 2025 codes, each covering a more narrowly defined activity, the company must determine which resulting codes apply to its actual operations. This transition type requires active management and is the primary source of compliance risk for PT PMA entities in the migration process.
BPS published an official code comparison table at s.bps.go.id/perbanKBLI2025. The table allows any entity to identify exactly how its current codes translate into the 2025 framework and which of the three transition forms applies to each code in its current registration.
The Split-Code Risk for PT PMA Entities
When a KBLI 2020 code splits into multiple KBLI 2025 codes, the company must determine which of the resulting codes accurately reflects its actual business activities. This is a legal and commercial decision, not a mapping exercise.
When a KBLI 2020 code splits into multiple KBLI 2025 codes, the company must determine which resulting codes accurately reflect its actual business activities. For a PT PMA, that determination carries three distinct compliance implications.
The minimum investment threshold applies per five-digit KBLI code per project location under BKPM Regulation No. 5 of 2025, set at IDR 10 billion with IDR 2.5 billion in paid-up capital. A company whose activities under one 2020 code now map across two 2025 codes must confirm whether its declared investment plan covers both codes at the required level. Carrying forward a code whose investment threshold the declared plan does not support creates a gap between the investment position and the registered KBLI scope.
The foreign investment status of each resulting code must also be confirmed against the Positive Investment List. A split code may place one resulting 2025 code in an open category and another in a restricted or closed category. A PT PMA that carries both codes forward without this review may find itself registered for an activity no longer permitted under foreign capital investment rules.
Where a split produces a 2025 code carrying a higher risk classification than the original 2020 code, additional licences or permits may be required that were not required under the previous classification. Operating under the higher-risk code without those permits creates a licensing gap that will surface during any regulatory interaction referencing the OSS record.
The Articles of Association Dimension
Where a KBLI change requires the company to add, remove, or replace a stated business activity in its articles of association, the amendment must be processed through the Ministry of Law via the SABH system. This is a notarial process: the amendment requires notarial minutes, a notarial deed of amendment, and SABH registration.
Permenkum 49/2025, which came into force on 17 December 2025, tightened the procedures for corporate amendments at the Ministry of Law. The regulation introduced stricter administrative requirements and more precise documentation standards for SABH submissions. The practical effect is that articles of association amendments now take longer to process than they did before December 2025.
A PT PMA that identifies a KBLI split requiring an articles of association amendment and initiates that process in the final week of May 2026 is unlikely to complete the notarisation and SABH registration before 18 June 2026. The window for companies with structural changes is narrowing.
The LKPM Connection
Every PT PMA must file a quarterly LKPM (Laporan Kegiatan Penanaman Modal) through the OSS system. The LKPM reports capital investment, employment, and operational activity for the quarter against the company’s declared investment plan. The LKPM is filed under the company’s registered KBLI codes.
An LKPM filed after 18 June 2026 under KBLI 2020 codes will not accurately reflect the company’s licensed activities under the current classification framework. The Q2 2026 LKPM, covering the period from April to June 2026, carries a deadline of 15 July 2026. That filing will be the first quarterly submission due after the KBLI 2025 migration deadline. Entities that have not completed their KBLI assessment and updated their OSS records before the migration deadline will file their Q2 2026 LKPM under an outdated classification, creating a data inconsistency in the OSS system.
The Joint Circular of 25 March 2026
On 25 March 2026, the Minister of Investment and Downstream Industry (Head of BKPM), the Minister of Law, and the Head of BPS jointly issued a Surat Edaran Bersama (Joint Circular Letter) on the implementation of KBLI 2025 adjustments across risk-based business licensing administration. The Joint Circular addressed two specific implementation dimensions: the Direktorat Jenderal Administrasi Hukum Umum (Ditjen AHU) system at the Ministry of Law and the OSS system at BKPM.
At the time of publication of this article, the OSS system continues to operate on KBLI 2020. The Ditjen AHU system similarly continues to process corporate administration, including company establishment and articles of association amendments, by reference to KBLI 2020. The 18 June 2026 deadline is therefore both the company compliance deadline and the government systems deadline. Companies completing the KBLI 2025 assessment and any required amendments now are doing so in advance of the system’s own technical migration, which is the operationally prudent position.
The Consequences of Non-Alignment
BPS Regulation No. 7 of 2025 prescribes no specific administrative sanctions for failure to complete the migration by 18 June 2026 in the graduated form that LKPM non-compliance produces. The compliance risk is operational and structural in character.
A company whose OSS record carries KBLI 2020 codes after the migration deadline will have licensing data that does not align with the operative classification framework. OSS processes licence applications, permit renewals, import approval requests, and RPTKA applications for foreign workers by reference to the company’s registered KBLI codes. A mismatch between the registered codes and the current operative framework can produce administrative flags on OSS transactions, delays in permit approvals and renewals, complications during regulatory audits or due diligence exercises, and inconsistencies across the three data sources that BKPM cross-references against LKPM submissions: the LKPM itself, the company’s tax filings, and its BPJS employment records.
The practical exposure compounds where a company’s activities have expanded since initial registration. The KBLI 2025 migration assessment is frequently the point at which TraceWorthy identifies a gap between the codes a company was registered under at incorporation and the activities the company is actually conducting at the time of the review. A company trading under KBLI codes that no longer reflect its actual business activities, whether because of the KBLI 2020 to 2025 migration or because activities evolved without a corresponding OSS update, carries a compliance exposure that will surface during any regulatory interaction that references the OSS record.
The Four-Step Assessment TraceWorthy Conducts
TraceWorthy’s KBLI 2025 migration assessment follows a structured sequence applied consistently across every PT PMA client engagement.
Extraction: pulling the company’s current KBLI 2020 codes from its NIB and OSS record and confirming they match the company’s articles of association.
Mapping: applying the BPS comparison table to identify how each current code translates to KBLI 2025: direct renumber, consolidation, or split.
Assessment: for each split code, determining which resulting KBLI 2025 codes accurately reflect the company’s actual activities, whether each resulting code is open to foreign investment under the current Positive Investment List, what risk classification each resulting code carries, and whether the company’s declared investment plan supports the investment threshold for each code at each project location.
Implementation: where no code changes are required and the migration is automatic, confirming the OSS record is updated. Where changes are required, preparing the OSS amendment, and where an articles of association amendment is also required, preparing the notarial documentation for SABH registration.
The assessment is completed in a single advisory engagement. The implementation timeline depends on whether articles of association amendments are required.
Conclusion
The 18 June 2026 deadline is 27 days from the date of publication of this article. BPS Regulation No. 7 of 2025 established it as the mandatory completion date for every entity operating in Indonesia to align its registered business classifications with the KBLI 2025 framework.
For PT PMA entities whose codes are subject to a one-to-many split, the assessment must be completed now for two reasons. The investment position review, the foreign investment status check, and any required OSS amendments can all be completed within the remaining window. An articles of association amendment requiring notarisation and SABH registration under the Permenkum 49/2025 procedures may not complete before 18 June 2026 if it is not initiated immediately.
For PT PMA entities whose codes are subject to a direct renumber or consolidation, the migration may be automatic. Confirming this through the BPS comparison table and OSS record review takes less than a day with the right advisory support.
Contact TraceWorthy to initiate a KBLI 2025 migration assessment. The assessment confirms the current classification position, identifies any split codes requiring a decision, reviews the foreign investment status of all resulting codes, and determines whether articles of association amendments are required before the deadline. While you are chatting, ask about a “Business Health Check.”
Glossary
| Indonesian Term | Abbreviation | English Translation or Explanation |
|---|---|---|
| Badan Pusat Statistik | BPS | Statistics Indonesia; the government agency responsible for issuing and maintaining the national business classification framework |
| Daftar Prioritas Investasi | DPI | Positive Investment List; the framework establishing which business activities are open to foreign investment, which are reserved for domestic investors, and which are subject to conditions |
| Direktorat Jenderal Administrasi Hukum Umum | Ditjen AHU | Directorate General of General Legal Administration under the Ministry of Law; manages the AHU system through which corporate amendments including articles of association changes are registered |
| Klasifikasi Baku Lapangan Usaha Indonesia | KBLI | Indonesian Standard Industrial Classification; the national framework for classifying business activities, updated from KBLI 2020 to KBLI 2025 under BPS Regulation No. 7 of 2025 |
| Laporan Kegiatan Penanaman Modal | LKPM | Investment Activity Report; the quarterly filing submitted through OSS confirming capital investment, employment, and operational activity against the company’s declared investment plan |
| Nomor Induk Berusaha | NIB | Business Registration Number; the primary business identifier issued through OSS; carries the company’s registered KBLI codes and is the reference point for all licensing and compliance interactions |
| Online Single Submission | OSS | The integrated government licensing platform through which KBLI codes, NIB, business licences, LKPM filings, and permit applications are managed |
| Perseroan Terbatas Penanaman Modal Asing | PT PMA | Foreign Capital Investment Limited Liability Company; subject to the minimum investment threshold of IDR 10 billion per five-digit KBLI code per project location under BKPM Regulation No. 5 of 2025 |
| Rancangan Penggunaan Tenaga Kerja Asing | RPTKA | Expatriate Utilisation Plan; must be filed through OSS; subject to the same KBLI classification framework as other OSS processes |
| Sistem Administrasi Badan Hukum | SABH | Legal Entity Administration System at the Ministry of Law; processes articles of association amendments and corporate changes under the procedures established by Permenkum 49/2025 |
| Surat Edaran Bersama | SEB | Joint Circular Letter; the instrument issued on 25 March 2026 by the Minister of Investment, Minister of Law, and Head of BPS to clarify KBLI 2025 implementation across the AHU and OSS systems |
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