Are the investment regulations you studied two years ago still applicable today? Has the minimum PT PMA capital requirement you know changed? Have updates to the business classification system affected how you choose licensing codes? And are policy revisions underway that you need to monitor before making a major investment decision?
Business regulations in Indonesia change quite actively. For investors, both new entrants and those already operating, updating their understanding of applicable rules is more than a good habit. It is a real necessity affecting the validity of corporate structures, completeness of licensing, and operational efficiency. This article summarizes the most significant regulatory changes applicable and requiring investors’ attention in 2026.
The Biggest Change: Reduced Minimum Capital for PT PMA
This change has the most direct impact on foreign investors planning to establish a PT PMA. Through BKPM Regulation Number 5 of 2025, effective from October 2025, the minimum paid-up capital for PT PMA was reduced from IDR 10 billion to IDR 2.5 billion.
This reduction is significant because it lowers one of the entry barriers foreign investors most frequently complain about, particularly for medium-sized businesses that are commercially viable but burdened by large initial capital requirements.
However, an important point must be understood to avoid misinterpretation. The reduction in minimum paid-up capital does not mean the minimum total investment value has also fallen. The minimum investment requirement remains more than IDR 10 billion, excluding land and buildings, per KBLI code per project location. The change concerns the paid-up capital component stated in the deed of establishment, rather than the overall investment value that must be realized.
One new provision needs attention: paid-up capital must remain in the company’s account and may not be transferred for at least 12 months from the deposit date. This obligation is recorded in a self-declaration when applying for licensing through OSS.
JHY Legal helps clients understand the practical implications of this change, including for existing PT PMA companies seeking to adapt their capital structures to the new requirements.
KBLI 2025: The New Business Classification System Applicable in 2026
The second major change applicable to companies established in 2026 is the implementation of KBLI 2025, the latest Indonesian Standard Industrial Classification issued by Statistics Indonesia in December 2025, replacing KBLI 2020.
This change appears technical, but its effects are very concrete. KBLI is the code used in OSS to determine the business sector, licensing risk level, tax classification, and, for PT PMA companies, whether foreign ownership is permitted and under what conditions. KBLI 2025 introduces more detailed classifications, so some old codes may no longer apply or may need adjustment.
Companies already established using KBLI 2020 codes need to check whether their codes remain relevant under KBLI 2025 and whether risk levels or licensing obligations have changed with the replacement of this classification system.
Summary of Regulatory Changes in 2025–2026 You Need to Know
The following table summarizes the main regulatory changes relevant to foreign investors and business operators operating through PT PMA companies in Indonesia, together with their context and practical implications.
| Regulatory Area | Previous Provision | New Provision (2025–2026) | Practical Implication |
|---|---|---|---|
| Minimum paid-up capital for PT PMA | IDR 10 billion | IDR 2.5 billion (BKPM Regulation 5/2025) | Easier access for medium-sized investors; capital must still remain deposited for 12 months |
| Minimum investment value for PT PMA | More than IDR 10 billion | Remains more than IDR 10 billion (excluding land and buildings, per KBLI code per location) | No change to the total investment obligation that must be realized |
| Business classification system (KBLI) | KBLI 2020 | KBLI 2025 (effective in 2026) | Old KBLI codes require reverification; some codes change risk classification |
| Revision of the Presidential Regulation on business sectors (DPI) | Presidential Regulation 10/2021 and its amendments | Revision underway, targeted for completion in the second half of 2026 | Some previously closed or restricted sectors may be opened more widely |
| OSS system update | Previous OSS system | System update as of October 2025 integrated with BKPM Regulation 5/2025 | Faster licensing processes; updated interface and data workflows |
Two points in this table need the most urgent attention: first, adjustment of KBLI codes from 2020 to 2025 for existing companies; and second, monitoring the revision of the Presidential Regulation on business sectors scheduled for completion in the second half of 2026, because it may open new investment opportunities in sectors previously closed or heavily restricted for foreigners. (Source: bisnis.com)
Revision of the Presidential Regulation on Business Sectors: What Is Changing?
The Indonesian government is currently revising the Presidential Regulation on investment business sectors, which directly affects the Positive Investment List (DPI). This revision is not driven by external pressure but forms part of a strategy to encourage private investment growth in sectors previously closed or tightly restricted.
The revision process is scheduled for completion in the second half of 2026. Investors planning to enter sectors that remain restricted would be wise to monitor its progress before finalizing an ownership structure or making investment commitments that are difficult to change.
What Existing PT PMA Companies Need to Do
For companies already operating, these regulatory changes do not necessarily require immediate action in every area, but several matters need to be checked:
- Verify whether the KBLI codes currently recorded in OSS comply with KBLI 2025 or still use old codes whose classifications may have changed.
- Check whether sectoral permits or Standard Certificates need updating following risk classification changes under KBLI 2025.
- For PT PMA companies wishing to adjust their paid-up capital to the new requirements, changes must follow a formal process: amendment of the deed, approval by the Ministry of Law and Human Rights, and an OSS data update. They cannot be made unilaterally.
- Monitor progress on the revision of the DPI Presidential Regulation if the company plans to expand into new business sectors currently restricted for foreign ownership.
JHY Legal’s Role in Helping Clients Navigate Regulatory Changes
JHY Legal is a legal advisory firm focused on corporate actions, immigration, and regulatory licensing in Indonesia. When regulations change, as with PT PMA capital requirements and the KBLI system, we help clients evaluate whether adjustments to their corporate structure, OSS data, or corporate documents are needed. We also monitor regulations undergoing revision so clients can make investment decisions based on the most current information.
Stay Updated, Stay Compliant
Changes to Indonesia’s business regulations do not end in 2026. Licensing systems, business classifications, and foreign investment provisions continue to evolve with government policy. For investors, the wisest response is a regular monitoring system and the ability to adjust their business structure when relevant changes occur, rather than panic.
The most concrete step you can take now is to verify your company’s KBLI codes in OSS and ensure they comply with KBLI 2025. If there is a mismatch, or the company plans to add a new business sector, this is the right time for a comprehensive data update before the discrepancy becomes an obstacle when applying for further licensing. JHY Legal is ready to support the process from beginning to end.