Regulatory update - KBLI 2025 Implementation
Regulatory update - KBLI 2025 Implementation
Indonesia’s business regulatory framework continues to evolve with the recent issuance of a Joint Circular Letter by the Minister of Investment and Downstreaming, the Minister of Law and the Head of the Central Bureau of Statistics (BPS). The letter formally introduces the implementation of KBLI 2025 (Klasifikasi Baku Lapangan Usaha Indonesia 2025) across the Risk-based business licencing system (Perizinan Berusaha Berbasis Risiko / PBBR).
At its core, KBLI is more than a classification tool, it is the foundation of how businesses are regulated in Indonesia. Each KBLI code determines the risk level assigned to a business activity, which in turn defines the type of licences required, the extent of compliance obligations and the level of regulatory oversight. With the introduction of KBLI 2025, the government has refined and updated these classifications to better reflect current economic activities, including emerging and evolving sectors. This update ensures that these changes are applied consistently across all relevant government systems, including OSS and the AHU Online system.
For business owners, this development carries both practical and legal implications. Existing companies will be required to align their current KBLI classifications with the updated KBLI 2025 structure, while new businesses will automatically adopt the new classification system. Although this may appear to be a technical adjustment, it has the potential to affect several aspects of business operations. Importantly, the letter also clarifies that all existing licences issued prior to the implementation of KBLI 2025, including Business Identification Numbers (NIB), Business Licences (Perizinan Berusaha) and sectoral licences (PB UMKU), remain valid and legally binding. This provides reassurance that businesses can continue operating while undertaking the necessary alignment with the updated classification system.
With respect to timing, BPS Regulation No. 7 of 2025 provides that all existing KBLI users are required to adjust their classifications in accordance with KBLI 2025 no later than six (6) months from the date the regulation came into force. The regulation was enacted on 18 December 2025 thus effectively setting a compliance deadline of 18 June 2026. Businesses should therefore treat this six-month window as a formal transition period within which alignment must be completed.
One of the most immediate considerations is whether a company’s current business activities are still accurately reflected under the new classifications. In some cases, the updated KBLI may introduce more specific categories or reclassify certain activities altogether. As a result, businesses may need to revise their existing codes or adopt additional ones to ensure accuracy. This is particularly important because any change in classification may also lead to a change in the business’s risk level under the PBBR framework. A shift in risk level could alter the licencing requirements applicable to the business, including the need for additional approvals, certifications or increased regulatory supervision.
The transition will also require updates within the OSS system, where KBLI codes are directly tied to licencing data. Businesses should be prepared for possible adjustments to their Business Identification Number (NIB) records and, where applicable, the reissuance or modification of licences. At the same time, alignment between licencing data and corporate documentation will become increasingly important. If a company’s Articles of Association do not reflect the updated KBLI classification, amendments may be required through the AHU system to ensure consistency across all records.
Beyond day-to-day compliance, KBLI 2025 may also have broader implications for corporate strategy. Business expansions, new lines of activity and corporate transactions such as mergers and acquisitions will need to take the updated classifications into account. In particular, investors and companies engaging in transactions should pay close attention to whether KBLI changes affect sectoral restrictions, licencing thresholds or regulatory approvals. During the transition period, there is also a possibility of temporary inconsistencies between systems or delays in processing, making early preparation all the more important.
In light of these developments, businesses are encouraged to be proactive. A careful review of existing KBLI classifications, followed by timely updates in OSS and, where necessary, amendments to corporate documents, will help mitigate potential disruptions to business activities. Ensuring that business activities are properly classified under KBLI 2025 will provide greater legal certainty and support smoother interactions with regulatory authorities going forward.
How we can support your organisation
BDO Legal provides a full suite of advisory services to help your organisation navigate Indonesia’s complex and evolving regulatory landscape. From corporate secretarial support and licencing to intricate mergers and acquisitions, our team ensures your business remains compliant and strategically positioned. We act as your proactive partner, translating legal requirements into practical solutions that safeguard your operations and support sustainable growth in the Indonesian market.
At its core, KBLI is more than a classification tool, it is the foundation of how businesses are regulated in Indonesia. Each KBLI code determines the risk level assigned to a business activity, which in turn defines the type of licences required, the extent of compliance obligations and the level of regulatory oversight. With the introduction of KBLI 2025, the government has refined and updated these classifications to better reflect current economic activities, including emerging and evolving sectors. This update ensures that these changes are applied consistently across all relevant government systems, including OSS and the AHU Online system.
For business owners, this development carries both practical and legal implications. Existing companies will be required to align their current KBLI classifications with the updated KBLI 2025 structure, while new businesses will automatically adopt the new classification system. Although this may appear to be a technical adjustment, it has the potential to affect several aspects of business operations. Importantly, the letter also clarifies that all existing licences issued prior to the implementation of KBLI 2025, including Business Identification Numbers (NIB), Business Licences (Perizinan Berusaha) and sectoral licences (PB UMKU), remain valid and legally binding. This provides reassurance that businesses can continue operating while undertaking the necessary alignment with the updated classification system.
With respect to timing, BPS Regulation No. 7 of 2025 provides that all existing KBLI users are required to adjust their classifications in accordance with KBLI 2025 no later than six (6) months from the date the regulation came into force. The regulation was enacted on 18 December 2025 thus effectively setting a compliance deadline of 18 June 2026. Businesses should therefore treat this six-month window as a formal transition period within which alignment must be completed.
One of the most immediate considerations is whether a company’s current business activities are still accurately reflected under the new classifications. In some cases, the updated KBLI may introduce more specific categories or reclassify certain activities altogether. As a result, businesses may need to revise their existing codes or adopt additional ones to ensure accuracy. This is particularly important because any change in classification may also lead to a change in the business’s risk level under the PBBR framework. A shift in risk level could alter the licencing requirements applicable to the business, including the need for additional approvals, certifications or increased regulatory supervision.
The transition will also require updates within the OSS system, where KBLI codes are directly tied to licencing data. Businesses should be prepared for possible adjustments to their Business Identification Number (NIB) records and, where applicable, the reissuance or modification of licences. At the same time, alignment between licencing data and corporate documentation will become increasingly important. If a company’s Articles of Association do not reflect the updated KBLI classification, amendments may be required through the AHU system to ensure consistency across all records.
Beyond day-to-day compliance, KBLI 2025 may also have broader implications for corporate strategy. Business expansions, new lines of activity and corporate transactions such as mergers and acquisitions will need to take the updated classifications into account. In particular, investors and companies engaging in transactions should pay close attention to whether KBLI changes affect sectoral restrictions, licencing thresholds or regulatory approvals. During the transition period, there is also a possibility of temporary inconsistencies between systems or delays in processing, making early preparation all the more important.
In light of these developments, businesses are encouraged to be proactive. A careful review of existing KBLI classifications, followed by timely updates in OSS and, where necessary, amendments to corporate documents, will help mitigate potential disruptions to business activities. Ensuring that business activities are properly classified under KBLI 2025 will provide greater legal certainty and support smoother interactions with regulatory authorities going forward.
How we can support your organisation
BDO Legal provides a full suite of advisory services to help your organisation navigate Indonesia’s complex and evolving regulatory landscape. From corporate secretarial support and licencing to intricate mergers and acquisitions, our team ensures your business remains compliant and strategically positioned. We act as your proactive partner, translating legal requirements into practical solutions that safeguard your operations and support sustainable growth in the Indonesian market.