A PT PMA’s paid-up capital and investment value are not the same requirement. Under Indonesia’s current general investment rules, a PT PMA generally needs at least IDR 2.5 billion in issued and paid-up capital per company, while its investment plan generally must be greater than IDR 10 billion per five-digit KBLI per project location, subject to important activity-specific exceptions.
Under Article 26 of Minister of Investment and Downstream Industry/Head of BKPM Regulation No. 5 of 2025, a business entity categorized as PMA is treated as a large business and must comply with minimum investment-value rules unless another regulation provides otherwise.
PT PMA Paid Up Capital vs Investment Value: The Short Answer
The easiest way to understand the distinction is to ask what each figure measures.
Paid-up capital concerns the capital placed and paid into the Indonesian limited liability company. Investment value concerns the scale of investment planned for the business activity and project recorded through the investment-licensing framework.
Separately, Article 26 paragraph (10) sets minimum issued and paid-up capital at IDR 2.5 billion per PT PMA unless another law or regulation provides otherwise.
The general rule in Article 26 paragraph (2) requires total investment greater than IDR 10 billion, excluding land and buildings, per five-digit KBLI business field per project location.
The practical result is simple: meeting the IDR 2.5 billion paid-up-capital minimum does not automatically satisfy the investment-value requirement, and declaring an investment plan above IDR 10 billion does not replace the company’s paid-up-capital requirement.
Paid-Up Capital Is the Company’s Equity-Capital Test
Paid-up capital sits in the corporate share structure. It relates to the value of shares that have been placed and paid by the company’s shareholders.
For the current general PT PMA rule, the relevant minimum is calculated per limited liability company, not separately for every KBLI or project location.
This makes paid-up capital a company-level test. If one PT PMA conducts several qualifying business activities, the general IDR 2.5 billion minimum is not mechanically multiplied simply because the company holds several KBLI codes.
A sector-specific law can still require more, so investors should confirm whether their industry imposes a higher capital floor before finalizing the deed.
Investment Value Is the Business-Activity Investment Test
Investment value works differently. The general formula follows the business activity and project location.
A PT PMA with one five-digit KBLI at one project location generally starts with the greater-than-IDR-10-billion test. If the company conducts another separately calculated activity or operates through another project location, the investment analysis can change.
This is why investors should prepare the investment plan after confirming the real KBLI activities and project structure rather than simply writing IDR 10 billion into every incorporation budget.
Decision Matrix: Paid-Up Capital vs Investment Value
The following table summarizes the main points to compare before choosing the next step.
| Comparison | Paid-up capital | Investment value |
|---|---|---|
| Main legal purpose | Company capitalization | Scale of investment in the business activity |
| General current PT PMA minimum | IDR 2.5 billion | Greater than IDR 10 billion |
| Main unit of calculation | Per PT PMA | Generally per five-digit KBLI per project location |
| Recorded as | Corporate/share capital | OSS investment plan |
| Automatically the same as the other figure? | No | No |
| Sector exceptions possible? | Yes | Yes |
The decision matrix explains why PT PMA paid up capital vs investment value should be reviewed as two related but separate compliance tests.
The IDR 10 Billion Calculation Has Important Exceptions
The general five-digit-KBLI-per-location formula is only the starting point.
The calculation is not identical for every business: Article 26 paragraph (3) creates different aggregation rules for wholesale trade, food and beverage services, construction and industry operating within one production line.
Under that paragraph, wholesale and construction use specified four-digit KBLI aggregation, food and beverage services use specified two-digit aggregation per location, and qualifying industrial activities in one production line use a separate calculation approach.
There is another important exception: Article 26 paragraph (5) provides that for specified property, short- or long-term accommodation, agriculture, plantation, livestock and aquaculture activities, the investment-value criterion includes land and buildings.
The regulation also contains more specific treatments for property projects, public EV charging stations and activities in certain special economic zones.
For that reason, the correct question is not merely ‘Is the minimum investment IDR 10 billion?’ It is ‘How does Article 26 calculate the minimum for this particular KBLI, location and sector?’
What Counts Inside the OSS Investment Plan?
Investment value is broader than the shareholders’ paid-up equity.
The distinction becomes clearer in Article 37, where the OSS investment plan includes planned values for land, buildings, machinery or equipment, other investment expenditure and working capital for one turnover.
The listed components include items such as project land preparation, buildings and infrastructure, machinery and equipment, operational vehicles and office equipment, feasibility and survey costs, licensing expenditure, construction-period operating costs and one operating-cycle working-capital plan.
This is why an investor should not treat the greater-than-IDR-10-billion figure as though the entire amount must appear as shareholder equity in the deed.
Investment Plan Is a Project Budget
The investment plan describes how the company expects to deploy resources into its Indonesian activity. Depending on the business, machinery, facilities, working capital and other permitted investment components can form part of that plan.
Paid-Up Capital Is One Funding Component
Paid-up capital can help finance the project, but it is not conceptually identical to the whole investment value. The corporate-capital figure and the OSS investment-plan figure should therefore be reconciled rather than copied from one field into the other.
How Can the Investment Plan Be Financed?
The regulation reinforces the distinction by separating the value of the investment plan from its source of financing.
The same Article 37 records financing sources separately and identifies own capital, loans, retained earnings and share premium as possible sources of financing.
For an investor, this means the planning exercise should answer two separate questions:
- How much investment will this activity and project require under the regulatory calculation?
- How will that investment be financed?
Shareholder paid-up capital is relevant to the second question, but it does not need to be assumed to equal the entire investment plan.
A practical funding schedule can therefore separate:
- issued and paid-up shareholder capital
- additional equity or share premium where applicable
- shareholder or third-party financing structured lawfully
- retained earnings for an existing operation
- timing of machinery, fit-out, construction and working-capital expenditure
The company’s deed, bank evidence, accounting records and OSS investment plan should tell a consistent story even though the figures serve different functions.
What Happens to the IDR 2.5 Billion Paid-Up Capital?
Paid-up capital should also not be described as a professional setup fee or as money that disappears when the company is incorporated.
For the funding itself, Article 27 states that the relevant issued and paid-up funds may not be moved from the business entity’s account for at least 12 months after placement or payment, except for asset purchases, building construction or company operations.
That exception is commercially important. The rule does not state that the money must remain untouched while the company separately finances its operations from another source. It expressly recognizes specified business uses.
Investors should nevertheless preserve a clear bank and accounting trail showing the capital contribution and any subsequent permitted business use.
Which Figure Should an Investor Use?
There is no single figure that replaces the other. Which number matters depends on the decision being made.
If You Are Drafting the PT PMA Deed
Focus on the corporate capital structure and confirm that the issued and paid-up capital satisfies the applicable PT PMA and sector rules.
If You Are Preparing the OSS Investment Plan
Focus on the correct KBLI, project location, applicable Article 26 calculation and the components of the investment plan.
If You Have Several KBLI Activities
Do not multiply IDR 10 billion automatically. First test whether each activity follows the general five-digit formula or one of the activity-specific aggregation rules.
If You Operate Property or Accommodation
Do not automatically exclude land and buildings from the calculation. Article 26 provides different treatment for specified activities.
If Your Budget Is Below the General Investment Threshold
Do not try to solve that issue merely by increasing the paid-up-capital figure. Paid-up capital and investment value are separate tests; the proposed project, KBLI and investment plan need to be reviewed together.
PT PMA Capital and Investment Reconciliation Checklist
Before incorporation or OSS submission, reconcile these items:
| Review item | Question |
|---|---|
| Shareholders | Who will fund the company and in what percentages? |
| Issued/paid-up capital | Does the PT satisfy the current company-level minimum? |
| Sector capital rule | Does another regulation require more than IDR 2.5 billion? |
| KBLI | Which five-digit activities will actually generate revenue? |
| Project locations | Where will each activity operate? |
| Article 26 exception | Does a special calculation apply? |
| Land/building treatment | Are these excluded or included for this activity? |
| Investment components | What land, facilities, machinery, other costs and working capital belong in the plan? |
| Financing sources | How will equity, loans, retained earnings or share premium finance the plan? |
| Bank trail | Can the paid-up contribution and permitted uses be documented? |
| OSS data | Does the investment plan match the commercial project? |
The official BKPM legal database lists Minister of Investment and Downstream Industry/Head of BKPM Regulation No. 5 of 2025 as in force and records that it repealed BKPM Regulations Nos. 3, 4 and 5 of 2021.
For broader structural context, Jakarta Legal ID’s PT PMA vs local PT comparison explains how foreign-investment status changes the company and licensing framework, while its NIB and OSS guide covers the licensing workflow in which the investment data is submitted.
Conclusion
PT PMA paid-up capital and investment value should be treated as two connected but separate tests.
For the general current framework, the company-level issued and paid-up capital minimum is IDR 2.5 billion per PT PMA, while the investment-value test generally exceeds IDR 10 billion per five-digit KBLI per project location. The investment calculation then needs to be adjusted where Article 26 provides a sector-specific rule.
Use the paid-up-capital figure when designing the company’s equity capitalization. Use the investment-value calculation when building the OSS project plan. For a simple single-activity project, the general formula may be straightforward; for multiple KBLIs, multiple locations, property, accommodation, wholesale, food and beverage, construction or industrial operations, verify the activity-specific calculation before finalizing either the funding plan or licensing data.
Reconcile the PT PMA Capital and OSS Investment Plan Before Filing
If you are establishing or restructuring a foreign-owned company, Jakarta Legal ID provides PT PMA/PMDN setup and NIB OSS business-licensing services within its current service scope.
Request a consultation to review the proposed share capital, KBLI activities, project locations and OSS investment plan before the corporate and licensing filings are finalized.
FAQ – PT PMA Paid Up Capital vs Investment Value
Is the minimum paid-up capital for a PT PMA still IDR 10 billion?
Not under the current general rule in Minister of Investment and Downstream Industry/Head of BKPM Regulation No. 5 of 2025. Article 26 generally sets minimum issued and paid-up capital at IDR 2.5 billion per PT PMA unless another regulation provides otherwise.
What is the current general minimum investment value for a PT PMA?
The general rule is total investment greater than IDR 10 billion excluding land and buildings per five-digit KBLI per project location, but Article 26 contains important activity-specific calculation exceptions.
Does the IDR 10 billion investment value have to be fully paid into the company as share capital?
The current regulation treats investment value and issued/paid-up capital as separate requirements. OSS also records investment components and financing sources separately, so the investment plan should not automatically be equated with shareholder paid-up capital.
What can count in the OSS investment plan?
Article 37 identifies categories including planned land expenditure, buildings, machinery or equipment, other investment expenditure and working capital for one turnover, subject to the applicable investment calculation.
Is the IDR 10 billion rule always calculated per five-digit KBLI?
No. That is the general rule, but Article 26 provides different aggregation treatments for activities including wholesale trade, food and beverage services, construction and certain industrial activities.
Can the IDR 2.5 billion paid-up capital be used for business operations?
Article 27 states that the relevant paid-up funds are subject to a minimum 12-month account restriction but expressly allows movement for asset purchases, building construction and company operations.
References & Sources
- Minister of Investment and Downstream Industry/Head of BKPM Regulation No. 5 of 2025 — jdih.bkpm.go.id
- Minister of Investment and Downstream Industry/Head of BKPM Regulation No. 5 of 2025 — Official Full Text — jdih-storage.bkpm.go.id
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