A KBLI 2025 code does not by itself tell an investor the permitted foreign ownership percentage. The current analysis requires at least three layers: identify the exact KBLI 2025 activity, reconcile it with the investment-business-field framework, and check whether a restriction applies to the specific activity rather than merely to a similar code number.

Under Presidential Regulation No. 10 of 2021 as amended by Presidential Regulation No. 49 of 2021, commercial business fields are generally open to investment except fields closed to investment or activities that may only be conducted by the Central Government.

Table of Contents

Foreign Ownership Limits by KBLI 2025: The Short Answer

There is no safe universal rule such as ‘KBLI 2025 = 100% foreign ownership.’ Many activities can be open to foreign investment, while others are subject to ownership conditions, domestic-investment requirements, special licensing, allocation to smaller domestic businesses or separate sector legislation.

For activities subject to conditions, Article 6 as amended by Presidential Regulation No. 49 of 2021 includes categories such as domestic-only investment, foreign ownership limitations and special licensing, with the relevant fields and conditions set out in Annex III.

The practical problem in 2026 is that KBLI 2025 is newer than that investment list. Investors therefore need to identify the current business activity first and then trace how it corresponds to the activity governed by the investment restriction.

Step 1: Identify the Exact Current KBLI 2025 Activity

Start with what the company will actually do, not with the ownership percentage the founders want.

The legal basis for KBLI 2025 is Statistics Indonesia Regulation No. 7 of 2025, promulgated on 18 December 2025 and subsequently amended in September 2026.

Investors should use the current classification rather than an archived code list because Statistics Indonesia Regulation No. 6 of 2026 amended KBLI 2025 and took effect on 10 September 2026.

This recent change is a useful reminder that ownership due diligence should begin with the current activity description in the live classification, especially for a new PT PMA, share acquisition or expansion into another business line.

Define the Revenue-Generating Activity

Write each planned activity in operational language. What will the company manufacture, sell, operate or provide to customers? Then select the KBLI that describes that activity rather than choosing a broad code because its title appears convenient.

Separate Multiple Activities

A company with several business lines should screen each material activity separately. Foreign ownership treatment should not be inferred from the most favorable KBLI in the company’s deed when another revenue-generating activity may have different investment conditions.

Step 2: Crosswalk KBLI 2025 to the Earlier Classification Where Needed

Because the investment-list regulations predate KBLI 2025, the official BPS KBLI 2020-2025 conversion table is an important screening tool and recognizes one-to-one, one-to-many and many-to-one conversion patterns.

That distinction matters. A one-to-one conversion can be relatively straightforward, but a legacy code that split into several 2025 activities requires an activity-level review. Likewise, several old codes may have been consolidated into one newer code even though the investment conditions historically attached to the underlying activities were not identical.

The crosswalk should therefore answer two questions:

Which earlier activity corresponds to the current KBLI 2025 activity?
Is the substantive business field the same as the field named in the investment restriction?

Do not convert only the number and ignore the activity description.

Step 3: Apply the Current Investment Business-Field Rules

After identifying the relevant activity, classify the investment result rather than jumping directly to a percentage.

Screening result	What it means for the next review
Open business field	Continue to sector-specific and PT PMA requirements
Foreign ownership limitation	Apply the stated cap to the specific business field and confirm the correct KBLI/activity mapping
Domestic-only condition	Foreign shareholding is not available under that listed condition
Special licensing condition	Ownership may be possible, but the specified licensing condition must also be satisfied
MSME allocation or partnership requirement	Review whether the activity is reserved or subject to partnership requirements
Closed or government-only activity	The ordinary foreign-investment route is unavailable

The table is a screening framework, not a substitute for the official annex. The exact ownership position must be read against the current activity and any sector-specific rule that applies to the project.

Step 4: Read the Restriction at the Business-Activity Level

A common screening error is to see one restricted activity under a KBLI and assume that every business field within the same code inherits the restriction.

A critical scope rule appears in Article 6 paragraph (3): where one KBLI contains more than one business field, the Annex III condition applies only to the business field specifically stated in that annex.

This rule is especially important during the transition to KBLI 2025. Code conversion is useful evidence of correspondence, but the substantive description of the regulated activity remains decisive.

For due diligence, record the analysis in four columns: current KBLI 2025, corresponding legacy activity, exact investment-list business field, and the resulting ownership condition.

Existing Investments, Treaties and Acquisitions Need Separate Checks

Not every existing investor should be screened as though the company were being incorporated today.

The ownership screen also has exceptions: Article 6 paragraph (4) protects specified investments approved before the regulation and qualifying treaty privileges, subject to the regulation’s more-favorable-rule conditions.

For an acquisition, Article 6 paragraph (5) provides that the foreign ownership limitation for the acquired company follows the limitation stated in that company’s existing Business Licensing.

Those provisions mean a new incorporation, an existing PT PMA, an acquisition and a treaty-protected investor can require different analyses even when the underlying commercial activity looks similar.

For transactions, review the target’s existing Business Licensing and historical approval position rather than relying only on a current public KBLI search.

Foreign Ownership Percentage Is Not the Same as PMA Investment Value

Even where a business field allows 100% foreign ownership, the investor still needs to satisfy the separate PT PMA investment framework.

Ownership percentage should also be separated from investment value because Article 26 of Minister of Investment and Downstream Industry/Head of BKPM Regulation No. 5 of 2025 generally requires a PT PMA, as a large business, to have total investment greater than IDR 10 billion excluding land and buildings per five-digit KBLI per project location, subject to stated exceptions.

The same Article 26 sets a minimum issued and paid-up capital of at least IDR 2.5 billion per PT PMA unless another law provides otherwise.

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.

This creates two separate questions:

Ownership test: What percentage, if any, may foreign shareholders hold in this specific business field?
Investment test: Does the PT PMA satisfy the applicable investment-value and capital requirements?

Passing one test does not automatically answer the other.

Foreign Ownership Screening Checklist

Before agreeing shareholder percentages or filing a PT PMA, run the following sequence.

Check	What to verify
Current business activity	Describe the real revenue-generating activity
KBLI 2025	Confirm the current code and description
September 2026 amendment	Confirm the current version of any affected classification
KBLI conversion	Trace the activity to KBLI 2020 where the investment rule uses the earlier structure
Investment-list status	Determine whether the field is open, restricted, domestic-only or subject to another condition
Exact activity scope	Confirm that the restriction actually names the business field being conducted
Sector regulation	Check for a more specific ownership or licensing rule
Existing approval	For an existing company or acquisition, review its Business Licensing and historical position
Treaty position	Check any applicable treaty privilege before relying on it
PMA investment value	Apply the current investment calculation and exceptions
Paid-up capital	Confirm the current PT PMA minimum and any sector-specific override
OSS filing	Ensure the final KBLI, investment data and shareholder structure are consistent

The objective is not to find the highest possible foreign percentage first and build the business around it. The correct sequence is activity, classification, legal restriction, exceptions and then shareholding structure.

Jakarta Legal ID’s NIB and OSS registration guide provides broader context on how KBLI and shareholder information enter the OSS licensing process.

For investors who need implementation support after completing the ownership screen, Jakarta Legal ID currently lists PT PMA/PMDN setup, NIB OSS and business licensing among its services.

Conclusion

Foreign ownership limits by KBLI 2025 cannot be determined reliably from the KBLI number alone. KBLI 2025 identifies the current economic activity, while the investment-business-field framework and applicable sector rules determine whether that activity is open, restricted or subject to another investment condition.

Because the investment list predates KBLI 2025, use the official BPS conversion table where necessary and compare the substantive business-field descriptions rather than performing a mechanical code substitution. The September 2026 KBLI amendment also makes current classification verification essential.

Finally, keep ownership percentage separate from PT PMA investment and capital requirements. A business can be open to foreign ownership and still have significant investment, licensing or sector-specific conditions that must be satisfied before the shareholding structure is finalized.

Verify the KBLI and Ownership Structure Before PT PMA Filing

If you are preparing a foreign-owned company or restructuring an existing investment, Jakarta Legal ID provides PT PMA/PMDN setup, NIB OSS and business licensing services within its current service scope.

Request a consultation to review the proposed KBLI, foreign shareholding structure and current investment requirements before the corporate and OSS filings are finalized.

FAQ – Foreign Ownership Limits by KBLI 2025

Does KBLI 2025 itself state the foreign ownership percentage?

Not by itself. KBLI classifies the business activity. The foreign ownership analysis must then apply the current investment-business-field framework and any sector-specific ownership rule to that activity.

Can a PT PMA be 100% foreign owned in Indonesia?

Some business fields can permit full foreign ownership, but there is no universal 100% rule. The exact activity must be checked against the investment list and any applicable sector legislation.

Why do investors still need a KBLI 2020-to-2025 conversion?

The principal investment-list framework predates KBLI 2025. BPS therefore provides an official conversion table that helps trace correspondence between the two classifications, including one-to-one, one-to-many and many-to-one mappings.

If one KBLI contains a restricted activity, is the whole KBLI restricted?

Not automatically. Article 6 paragraph (3) of the amended investment regulation states that where a KBLI contains more than one business field, the condition applies only to the business field specifically stated in Annex III.

Is a foreign ownership cap the same as the PT PMA investment requirement?

No. The ownership cap determines the permitted foreign shareholder percentage, while PT PMA investment-value and paid-up-capital rules are separate requirements.

Do acquisitions use the same ownership analysis as a new PT PMA?

Not always. Presidential Regulation No. 49 of 2021 contains a specific rule for acquisitions that refers to the foreign ownership limitation stated in the acquired company’s existing Business Licensing, so transaction-specific review is required.

References & Sources

Presidential Regulation No. 49 of 2021 Amending the Investment Business-Field Regulation — jdih.bkpm.go.id
Presidential Regulation No. 49 of 2021 — Official Full Text — jdih-storage.bkpm.go.id
Statistics Indonesia Regulation No. 7 of 2025 on the Indonesian Standard Industrial Classification — peraturan.go.id
Statistics Indonesia Regulation No. 6 of 2026 Amending KBLI 2025 — jdih.bps.go.id
BPS KBLI 2020-2025 Conversion Guidance — bps.go.id
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
Jakarta Legal ID NIB and OSS Registration Guide — jakartalegalid.com
Jakarta Legal ID Company Setup and Licensing Services — jakartalegalid.com

Foreign Ownership Limits by KBLI 2025 in Indonesia