KBLI 2025: What the New Business Classification Means for an Existing Company
Updated 12 October 2026 · Okusi Associates · All guides
Indonesia replaced its standard industrial classification on 18 December 2025. Peraturan BPS Nomor 7 Tahun 2025 put the KBLI 2025 (Klasifikasi Baku Lapangan Usaha Indonesia) in place of the 2020 edition, gave every user of the old codes six months to adjust, and left the licensing systems that actually run on those codes to catch up afterwards. They did, on 15 June 2026. Every company in Indonesia holds its business identification number (NIB), its licences, its foreign-ownership position and its tax classification against five-digit KBLI codes, so a change to the codebook is a change to the paperwork of every company at once. Most companies needed to do nothing. Some needed to do a great deal, and a company cannot tell which it is without looking.
What changed, and why it matters
The KBLI is issued by the Central Statistics Agency (BPS) and follows the United Nations’ ISIC standard. The 2020 edition sat on ISIC Revision 4; the 2025 edition moves to Revision 5. In the process the number of five-digit classifications fell from 1,789 to roughly 1,560, the top-level categories grew from 21 to 22, and a good many activities were split, merged or redescribed. BPS published the official conversion table in April 2026. It maps each old code to its successor in one of three ways: one-to-one, where only the number changes; many-to-one, where several old codes collapse into a new one; and one-to-many, where an old code has been split and the company must say which of the new codes it belongs under.
The classification is not a statistical nicety. In Indonesia the KBLI code determines the risk level of an activity under PP 28/2025 and therefore which licences a company needs; it determines whether a sector is open to foreign ownership under the positive investment list; it fixes the business-field tax code (KLU) at the tax office; and it is the unit against which the IDR 10 billion investment plan for a PMA company is measured. Move the code and every one of those can move with it.
The transition, as it actually ran
The six-month adjustment period in Article 5 of the BPS regulation ran from 18 December 2025 to 18 June 2026. For the first three months nothing could be adjusted, because neither the Ministry of Law’s company registry (AHU) nor the OSS licensing system had been updated. On 27 March 2026 the Minister of Investment, the Minister of Law and the Head of BPS issued a joint circular letter setting out how the change would be applied. Its substance:
- Every licence issued before the switch, whether a basic requirement, a business licence or a supporting licence, remains valid.
- The OSS and AHU systems would implement KBLI 2025 by 18 June 2026 and would carry the BPS conversion table.
- Codes on existing records would be converted by the systems. A company whose only change is the number, with no change to what it does, is not required to amend anything.
- A company whose business line or activity changes, by its own corporate action, must amend its articles of association and align the new codes through the normal process.
- The conversion table does not reach back to the 2017 or earlier editions. A company still carrying those codes gets no automatic conversion and must adjust manually, at the Ministry of Law first and OSS second, by way of a notarial deed restating a shareholders’ resolution that acknowledges the company’s codes under KBLI 2025.
OSS went down for maintenance on 13 and 14 June and came back on 15 June running KBLI 2025. From that date every new establishment and every change of company data must use the new codes. For companies still on 2020 codes, conversion is triggered the next time they touch the system with a licensing application, not on a timetable of their own choosing. One-to-many cases are not converted silently: the system requires the company to choose. On 10 September 2026 BPS promulgated Peraturan BPS Nomor 6 Tahun 2026, which corrects the descriptions of three codes (two in electric-vehicle manufacturing and one in tourism-area management) and starts no new transition period.
Does the deed have to change?
This is the question that generates the most contradictory advice, and the answer turns on a distinction the circular letter draws clearly. A company’s articles of association state its purpose and objectives (maksud dan tujuan) and its business activities, usually by reference to KBLI codes and descriptions. There are three cases.
| Situation | Deed amendment | OSS |
|---|---|---|
| Code number changes, activity and description substantively the same | Not required | Converted by system |
| Old code split (one-to-many) and the company must pick a successor | Not required for the pick alone; required if the chosen scope differs from the deed’s wording | Manual selection in OSS |
| Company adds, drops or changes an activity, or the deed no longer describes what the company does | Required: shareholders’ resolution, notarial deed, Ministry of Law approval, then OSS update, in that order | Follows the deed |
| Deed still carries KBLI 2017 or earlier codes | Required, as a restatement under KBLI 2025 | After AHU |
The order in the third case is not optional: OSS draws its company data from the Ministry of Law registry, which is why the circular letter puts the AHU step first. The caveat is that “substantively the same” is a judgment, and where an automatic conversion has placed a company under a description that no longer fits its real activity, the fact that no corporate action triggered it does not make the mismatch harmless. A notary, a bank conducting know-your-customer checks or a buyer’s due-diligence team will read the deed, the NIB and the operation side by side, and they expect the three to agree.
What a company should check now
The adjustment deadline has passed, and a company that has done nothing is not, as of this writing, being fined for it. The BPS regulation is a classification standard rather than a licensing rule, it carries no penalty clause that Okusi has seen, and the circular letter preserves existing licences. The cost of inaction is friction: a licence renewal, a new supporting licence, a change of shareholding or a quarterly LKPM investment report filed against a code OSS no longer recognises will stall until the alignment is done, and a one-to-many split discovered in the middle of a filing is a slow and expensive way to learn about it. A practical check runs in this order.
- Which edition the company is on. Read the KBLI codes on the NIB printout and in the latest deed. Codes from 2017 or earlier mean a manual adjustment, with no shortcut.
- What the conversion table does to each code. One-to-one is tidy. Many-to-one may merge two of the company’s activities into one, which can change the count of KBLI classifications the investment plan is measured against. One-to-many requires a decision, and the decision should match the deed.
- Whether the risk level moved. A successor code can carry a different risk classification, and a company that held a standard certificate may find the new code demands a verified licence, an environmental document or a sectoral approval it never needed before.
- Whether foreign ownership is still unrestricted. The positive investment list is written against KBLI codes. Where a company’s activity has been redescribed, confirm its position in the BUPM list under the new code rather than assuming the old answer carries over. In Bali, where the provincial government has closed eighteen classifications to new foreign-investment licences since May 2026, this check is not academic.
- Downstream registrations. Sectoral regulators are adopting the new codes on their own timetables; BPOM, for instance, has run its processed-food registration on KBLI 2025 since July 2026. The tax office’s KLU should agree with the NIB. Each of these is a separate record and none of them updates because OSS did.
Clients sometimes ask whether a quotation for an amendment includes “the KBLI certificate after the transition”. There is no such certificate. What exists is the NIB, which lists the company’s codes and is reissued with the converted ones, and the licences or standard certificates attached to each code, which may or may not need reissuing depending on whether the risk level changed. A quotation should say which of those it covers.
Where Okusi fits
Okusi Associates has handled company structures and licensing in Indonesia since 1997, from offices in Jakarta, Bali and Batam, and the KBLI codebook has been reissued several times in that period. For an existing company the work begins with a desk review of the deed, the NIB and the conversion table together, which tells the company in a page whether it is in the do-nothing case, the choose-a-code case or the amend-the-deed case. Where a deed amendment is needed, the shareholders’ resolution, notarial deed, Ministry of Law approval and OSS update are handled under the Amendments to Company Structure & Ownership service, priced to the scope of the change. Companies that would rather not be the ones watching the codebook can place the whole compliance calendar, LKPM reporting included, with the Company Secretary - Corporate Secretary company-secretary service at US$ 1,535 per year.
Related reading: PMA capital requirements · converting a local PT to a PMA · monthly tax reporting · companies FAQ
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