A KBLI code is the five-digit Indonesian business classification registered against your company’s business number (NIB) in the government’s OSS licensing system, and it decides what your company is legally allowed to do, whether foreigners may own it, and which licences it needs. If the code does not match the business — for example, a general real-estate code used for nightly villa rentals — the business can be operating outside its licence, cannot obtain the right tourism permits, and will be flagged in any due diligence. Information only.
So what exactly is a KBLI code?
KBLI stands for Klasifikasi Baku Lapangan Usaha Indonesia — Indonesia’s standard business classification, published by the national statistics agency (BPS) and modelled on the UN’s international industry codes. Each activity has a five-digit code: one for star-rated hotels, one for real estate owned or leased, one for restaurants, and so on.
When a company is set up, its articles of association list its purposes and activities, and those activities are registered as KBLI codes on OSS (the Online Single Submission system, Indonesia’s licensing portal), alongside the NIB (Nomor Induk Berusaha, the business identification number). Every later licence is issued against a specific code.
Why does the code matter so much for a villa or hotel?
Because each code carries its own rules. Three in particular:
- Who can own it. Some codes are open to 100% foreign ownership through a PT PMA (a foreign-owned Indonesian company); others are reserved for Indonesian owners, cooperatives or small businesses. Advisers report that small-scale villa and homestay (pondok wisata) accommodation codes are among those reserved, so a foreign-owned company cannot simply pick them.
- Risk level. Indonesia licenses by risk. A low-risk activity may need only the NIB; higher-risk activities, which include most hotels, need a verified standard certificate or a full business licence before operating.
- Which permits follow. The tourism and accommodation licences an operator needs — and that booking platforms increasingly check — are tied to an accommodation code, not a general property code.
The commonest mismatch in Bali is the code for real estate that is owned or leased (KBLI 68111) used for nightly villa rentals. Indonesia’s investment ministry has publicly singled out that misuse in Bali. Information only.
What changed with KBLI 2025?
BPS issued a new version, KBLI 2025, in December 2025 (BPS Regulation No. 7 of 2025), replacing KBLI 2020. The number of five-digit codes falls from 1,789 to 1,559, so some codes are merged, renumbered or split.
| What | As reported, 2026 |
|---|---|
| New version in force on OSS | 15 June 2026 |
| New companies | Must register under KBLI 2025 |
| Existing companies, no change of business | Codes converted automatically |
| Any amendment to articles or activities | Must move to KBLI 2025 codes at the same time |
| Old code splits into several new ones | Company must choose the right one |
Existing licences stay valid. The trouble spots are a one-to-many split, where the system cannot know which new code fits, and companies still carrying pre-2020 codes, which officials have said must update their data. It is worth logging into OSS after the conversion and checking what your company now shows. Information only.
What actually happens if the code is wrong?
- You cannot get the licence you need. A tourism or accommodation permit cannot be issued against a code that does not cover accommodation.
- You are operating outside scope. Running nightly rentals under a property-leasing code is an activity the company is not licensed for. Sanctions under risk-based licensing run from written warnings to suspension and revocation, and Bali’s provincial investment office has been carrying out field inspections. Listings can also come down if a platform cannot verify the licence.
- Due diligence stalls. A buyer of the company, a capital provider or a bank will check that the KBLI matches what the business really does. A mismatch is one of the first findings, and it usually has to be fixed before money moves.
- Knock-on rules change. The code affects the minimum investment, import access and whether a local partner is required — some of which are hard to unwind after the NIB is issued.
How do I fix it?
Through an amendment, usually handled by a notary and a licensing consultant:
- Check first. Confirm the correct code under KBLI 2025, its risk level, and whether a foreign-owned company may hold it — in Bali, also whether new PT PMA registrations under it are currently blocked (see what foreigners can still open in Bali).
- Amend the articles. The notary prepares a deed changing the company’s purposes and activities, which is recorded with the Ministry of Law (the AHU system).
- Update OSS. The new code is added to the NIB, and the licences that go with it are applied for.
- Check the money. A new code can bring a new minimum investment plan — see what a PT PMA costs to set up.
If the correct code is closed to foreign ownership, the fix is structural rather than administrative — and nominee arrangements are not a fix. Take advice from Indonesian counsel before changing anything.
Why does a capital provider care?
Because the licence is part of what makes the asset worth backing. A villa or hotel that cannot legally take guests under its current code is worth less, and is harder to sell, than one that can. Capital providers check the KBLI alongside the NIB, PBG and SLF (the building permit and certificate of fitness for use). See what capital providers ask and how foreigners hold property in Bali.
Sources: BPS Regulation No. 7 of 2025 (KBLI 2025); Joint Circular of the Minister of Investment/BKPM, Minister of Law and Head of BPS, 25 March 2026, as reported by Emerhub and ASEAN Briefing (2026); Emerhub on Bali OSS closure (May 2026) and pondok wisata licensing; Bali Villa Realty on Investment Ministry comments re KBLI 68111 (2026); xpnd.co.id, Bali foreign investment FAQ (2026). Rules move: verify current codes and status with Indonesian counsel. Not legal advice. General information about the Indonesian market, not legal, tax or financial advice.
Have a project in Bali, Lombok, Labuan Bajo, Sumba or elsewhere in Indonesia that needs completion or expansion capital?
Tell us about the project