A KBLI amendment is the notarial and OSS process a PT PMA uses to add, remove, or replace the business activity codes registered under its NIB, required whenever a company starts doing something its current Articles of Association do not cover. Most foreign-owned companies in Indonesia outgrow their original KBLI code within a few years of operating. A software company starts selling hardware. A consulting firm starts importing goods. A restaurant adds catering. Each of these moves outside the original registration, and Indonesian law treats that as a licensing gap, not a grey area.
Key Takeaways
- Yes, a PT PMA can add or change KBLI codes after registration, but only through a notarial deed amendment, Kemenkumham approval, and an OSS data update, not a simple portal edit.
- Each new primary KBLI field can trigger its own IDR 10 billion investment plan commitment, even though paid-up capital was reduced to IDR 2.5 billion under BKPM Regulation No. 5 of 2025.
- Since the KBLI 2025 classification took effect, an amendment now has to account for the new code structure, not just the activity your company plans to add.
Can You Legally Add or Change a KBLI Code After PT PMA Registration?
Yes. A PT PMA can add, remove, or replace KBLI codes after incorporation, but the company cannot simply log into OSS and type in a new number. The KBLI codes registered in your NIB have to match the business purpose written into Article 3 of your Articles of Association. If the activity you want to add is not already described in that article, the deed has to be amended first.
This is where most first-time founders get the sequence backwards. They try to add the activity in OSS-RBA before the deed change is approved, and the system either rejects the code or leaves it invisible on the NIB dashboard. The correct order runs from the notary outward: shareholder resolution, deed amendment, Kemenkumham approval, then the OSS update.
If your new activity happens to fall under a KBLI already listed in your existing Articles of Association, the process is lighter. You can often complete it as a direct OSS data change without touching the deed at all.
How Do You Amend Your NIB to Add a New KBLI Code Through OSS?
The full sequence for adding a KBLI code that is not yet in your deed runs through five stages, each depending on the one before it.
Shareholders formally resolve to expand the company’s business purpose. This resolution becomes the legal basis for the notary to draft the amendment.
2. Draft and sign the notarial deed of amendment
A licensed Indonesian notary records the resolution and drafts the amended Article 3 with the new business activity described precisely enough to map to a specific KBLI code.
3. Submit for Kemenkumham approval through SABH
The notary files the amendment electronically through the Legal Entity Administration System within 30 days of the deed date. Since Permenkum 49/2025 tightened documentation standards, this stage typically takes one to three weeks.
4. Wait for the Ministerial Decree (SK)
The amendment only takes legal effect once Kemenkumham issues the SK. This decree number is what you enter into OSS to unlock the data change.
Log in with your company’s OSS credentials, select “Ubah Data” (Change Data), enter the SK number, and add the new KBLI code. Low-risk activities generate an updated NIB immediately. Medium and high-risk activities trigger additional licensing steps described below.
Notes from InvestinAsia Consultants
The step clients underestimate most is the 30-day SABH filing window after the deed is signed. Miss it and the notary has to redo parts of the paperwork. We advise scheduling the OSS update meeting with your team before the notary appointment, not after, so nothing sits idle once the SK arrives.
Not Sure Whether Your Business Activity Needs a Deed Amendment?
InvestinAsia’s team of 380+ in-house specialists reviews your current Articles of Association against the activity you want to add before you spend on a notary.
Does Adding a Restricted KBLI Require Extra Approval?
Some KBLI codes carry conditions beyond the standard OSS-RBA path. Under the Positive Investment List, certain business fields cap foreign ownership, require a local partner, or sit in regulated sectors that involve a sector ministry review before the code activates.
Regional authorities can also restrict specific KBLI codes at the address level, separate from national rules. Bali’s provincial government requested the closure of nine low-risk KBLI codes for new PT PMA registrations in early 2026 after finding a pattern of companies using them mainly to obtain residency permits without real operations. An existing company adding one of those codes to a Bali address could face the same block a new registration would. Our detailed breakdown of the Bali KBLI restrictions covers which codes are affected and the workaround for companies with a Bali domicile.
If your new activity falls outside the Positive Investment List’s fully open category, expect a longer timeline. Ownership restructuring, an Indonesian co-shareholder, or a sector ministry’s technical review can add weeks to the standard amendment sequence.
How Does a KBLI Change Affect Your Existing Business Licenses?
Adding a KBLI code does not touch the licenses tied to your existing activities. Those stay valid. What changes is the risk classification the OSS system recalculates for the new code specifically. A risk-based licensing system assigns each KBLI its own tier, low, medium-low, medium-high, or high, and the new activity gets evaluated independently of your original one.
This matters when the new activity carries a higher risk tier than your existing business. A services company that adds a food-handling or import activity may suddenly need a Standard Certificate, facility verification, or a sectoral permit it never needed before, even though its original activity remained NIB-only. A new KBLI does not inherit your existing licensing status. It gets evaluated on its own.
Do You Need to Increase Your Capital When Adding a New KBLI?
Often, yes. Every main KBLI field a PT PMA registers and intends to generate revenue from carries its own investment plan commitment of at least IDR 10 billion, excluding land and buildings. Add a genuinely separate business line, and that line typically triggers its own IDR 10 billion threshold on top of what your company already committed for its original activity.
Paid-up capital is a separate figure. Since BKPM Regulation No. 5 of 2025 took effect in October 2025, the minimum paid-up capital requirement for a PT PMA dropped from IDR 10 billion to IDR 2.5 billion, which lowers the cash a company needs on hand at the point of registration or amendment. This lowers the entry cost of adding a new business line, but the underlying investment plan obligation per KBLI field has not disappeared.
Supporting KBLI codes tied to your existing operational domain generally do not trigger a new capital threshold on their own. Whether a code counts as primary or supporting is determined by BKPM and OSS, not by how your company chooses to label it, so confirm the classification before assuming you are exempt.
What Changes in Your LKPM Reporting After a Scope Change?
Every KBLI code listed under your NIB has to be reported in your quarterly or biannual LKPM submission, including the new one, starting from the first reporting window after the amendment takes effect. This applies even if the new activity has not generated revenue yet. An inactive line still needs a zero-activity entry rather than being left out.
Because BKPM cross-references LKPM data against your investment realization figures, adding a KBLI with its own IDR 10 billion investment plan means your reporting now needs to show progress against that new commitment separately from your original activity. Our quarterly LKPM guide walks through the submission mechanics in detail.
Notes from InvestinAsia Consultants
Companies frequently forget to update their LKPM PIC contact and reporting template right after an amendment, then get flagged for a mismatch between the new KBLI and the older report format. Building the LKPM update into the same task list as the OSS amendment avoids that gap entirely.
What Happens If You Operate Outside Your Registered KBLI?
Running revenue-generating activity that falls outside your registered KBLI codes is treated as unlicensed operation, not a minor paperwork oversight. The practical consequences build in stages: an administrative warning from BKPM, restrictions on new facilities or license renewals, and in persistent cases, suspension or revocation of your NIB. Banks and B2B partners doing due diligence also cross-check your registered activities, so a mismatch can stall a loan application or a new contract well before any government agency gets involved.
The safer approach for a company that has already started a new activity informally is to treat the amendment as urgent, not optional, and file it before the next LKPM reporting window rather than after.
How Does the KBLI 2025 Transition Affect an Existing Amendment?
Indonesia replaced its 2020 classification system with KBLI 2025 under BPS Regulation No. 7 of 2025, effective December 18, 2025, with a system-wide transition deadline of June 18, 2026. That deadline has now passed, and OSS and the Ministry of Law’s AHU system operate on KBLI 2025 codes going forward.
For a company amending its business scope now, this means the new activity has to be classified under a current KBLI 2025 code from the start, not the 2020 code a competitor’s older article might still reference. If your existing codes converted automatically because the change was a straight renumbering, no deed amendment was needed for that part. But where a 2020 code was split into several more specific 2025 codes, or removed entirely, your notary needs to select the correct replacement before drafting the amendment for your new activity, so the deed does not end up mixing an outdated code with a current one.
| Situation | Deed amendment needed? | OSS update needed? |
|---|---|---|
| New activity already described in your Articles of Association | No | Yes, direct data change |
| New activity not yet in your Articles of Association | Yes, via RUPS and notary | Yes, after Kemenkumham SK is issued |
| Existing KBLI code converts cleanly under KBLI 2025 | No | Automatic in OSS |
| Existing KBLI code was split or removed under KBLI 2025 | Yes, to select the correct replacement code | Yes, after the amendment |
Ready to Formalize Your PT PMA’s New Business Scope?
InvestinAsia handles the notary, Kemenkumham filing, and OSS update as one coordinated process, active in Jakarta and Bali.
References
1. Kementerian Investasi dan Hilirisasi/BKPM. (2026). Surat Edaran Bersama tentang Implementasi Penyesuaian KBLI. Retrieved from
https://www.bkpm.go.id/id/info/pengumuman/seb-kementerian-investasi-dan-hilirisasi-kepala-bkpm-tentang-implementasi-penyesuaian-kbli
2. Badan Pusat Statistik. (2026, April 27). Pemerintah Memastikan KBLI 2025 Tidak Memerlukan Perizinan Baru. Retrieved from
https://www.bps.go.id/id/news/2026/04/27/898/pemerintah-memastikan-kbli-2025-tidak-memerlukan-perizinan-baru.html
3. Kementerian Investasi dan Hilirisasi/BKPM. (2026). Sosialisasi Penerapan KBLI 2025 pada Sistem OSS dan Sistem AHU. Retrieved from
https://bkpm.go.id/id/info/pengumuman/sosialisasi-penerapan-kbli-2025-pada-sistem-oss-dan-sistem-ahu
4. Online Single Submission (OSS) System. (2026). Sistem Perizinan Berusaha Terintegrasi Secara Elektronik. Retrieved from
https://oss.go.id/
