- Adding business fields to a PT PMA requires more than adding a KBLI code in OSS.
- The company needs to check foreign ownership limits before selecting a new business field.
- The business risk level can affect the type of permit required.
- Sectoral licenses and PB UMKU need review according to the business activities.
- Company documents, OSS, and investment plans must remain consistent.
KBLI is often considered the main step when a PT PMA wants to add a business field. However, adding a KBLI code involves more than selecting a new code in the system. The company also needs to check whether foreign capital may engage in the field, whether foreign ownership limits apply, what the risk level is, and whether additional sectoral licenses are required.
A PT PMA is a company with an element of foreign investment. Every addition to its business fields therefore needs to be considered from the perspective of corporate law, investment, OSS licensing, and technical permits. Adding a KBLI code without this review can create obstacles when applying for permits, receiving new investors, or conducting actual business activities.
JHY Legal often recommends treating the addition of business fields as a legal and licensing process, beyond data entry alone. This allows risks relating to inconsistent data, incomplete permits, or unsuitable business activities to be identified earlier.
Why Is Adding a KBLI Code Alone Insufficient?
KBLI is the Indonesian Standard Industrial Classification. Its codes group business activities. In OSS, KBLI helps determine the type of activity, risk level, and permits that may be required.
However, KBLI is only one part of the process. After selecting a code, the company still needs to determine whether the business field is open to foreign investment. Presidential Regulation No. 10 of 2021 governs investment business fields, including priority fields, fields allocated to or requiring partnerships with cooperatives and micro, small, and medium enterprises (MSMEs), fields with specific requirements, and other fields open to all investors. Source: peraturan.bpk.go.id
A new business field can change the company’s risk
When a PT PMA adds a business field, its risk can change. For example, it may previously have provided only consultancy services and now want to enter trading, distribution, industry, healthcare, education, or a particular technology field. Each sector can have different permits and requirements.
Before adding a KBLI code, the company therefore needs to assess whether the new activity remains consistent with its share structure, existing permits, and long-term business plan.
Check Foreign Ownership Limits First
A foreign ownership limit is the maximum shareholding permitted for foreign investors in a particular business field. Not every field has the same limit. Some are fully open to foreign investors. Others have partnership requirements, percentage restrictions, or special provisions.
Presidential Regulation No. 49 of 2021 amends several provisions in Presidential Regulation No. 10 of 2021 and confirms that all commercial business fields are open to investment, except fields declared closed or activities that may only be carried out by the central government. Source: peraturan.bpk.go.id
Example of the risk if limits are not checked
For example, a PT PMA has been established with 100 percent foreign ownership and wants to add a new business field. If that field has foreign ownership restrictions or partnership requirements, the company’s share structure needs review first.
Without this check, the company might successfully add certain data but later encounter obstacles in sectoral licensing, OSS updates, or compliance inspections. Problems may also arise when it plans a share transfer, restructuring, or capital increase.
Business Risk Levels in OSS Need Review
OSS is an electronically integrated business licensing system. In this system, risk-based business licensing means that the type of permit is determined by the risk level of the business activity.
Government Regulation No. 28 of 2025 governs risk-based business licensing, including basic requirements, business licensing, PB UMKU, OSS services, supervision, and sanctions. Source: peraturan.bpk.go.id
What effect does the risk level have?
For a low-risk business field, the company may need only an NIB. NIB is the Business Identification Number, identifying a business operator in OSS. For medium- or high-risk business fields, however, the company may need a standard certificate, verification, a business permit, or PB UMKU.
PB UMKU means Business Licensing to Support Business Activities. Examples vary by sector. In some fields, an NIB alone is insufficient. Further permits need to be fulfilled before activities begin.
Comparison of Matters to Review
To make the process easier to understand, the following table can serve as an initial map before a PT PMA adds business fields. It shows that adding a KBLI code is one part of a broader process.
| Review Area | What to Check | Risk If Overlooked |
|---|---|---|
| KBLI | Whether the code matches the business activities that will actually be carried out. | Business activities do not match OSS data and company documents. |
| Foreign ownership | Whether the field is fully open to foreign investors or has specific limits. | The PT PMA’s share structure does not fit the new business field. |
| Risk level | Whether the business risk is low, medium, or high in OSS. | The company misunderstands the permits it must obtain. |
| Sectoral licensing | Whether the sector requires technical permits, standards, or additional approvals. | Business activities begin before supporting permits are ready. |
| Company documents | Whether the deed, purposes and objectives, OSS, and internal documents align. | Company data differs between the deed, OSS, and other permits. |
Check the Deed and the Company’s Purposes and Objectives
Before adding a business field in OSS, the company needs to review its deed. The deed includes a section on purposes, objectives, and business activities. If the new field is not listed, the company may need to amend the deed first.
A deed amendment usually needs to be prepared through a shareholders’ resolution or General Meeting of Shareholders (RUPS), depending on the articles of association. RUPS is the forum in which shareholders take important company decisions.
Documents to prepare
The company can start with the following simple list:
- The deed of establishment and latest amendment.
- The company’s articles of association.
- The list of existing KBLI codes.
- The new KBLI codes to be added.
- Shareholder data and foreign ownership percentages.
- The latest NIB and OSS data.
- Addresses and project locations for the new business field.
- The investment plan for the new business field.
- Sectoral licenses that may be required.
This list helps determine whether the change can be made in OSS alone or needs to begin with amendments to company documents.
Investment Value and Project Locations Also Need Checking
For a PT PMA, new business fields often relate to investment plans. The company needs to check whether the investment value complies with the provisions and whether the project location is clear. In some cases, the same KBLI code can have different implications when used in different locations.
Minister of Investment and Downstream Industry/Head of BKPM Regulation No. 5 of 2025 governs guidelines and procedures for implementing risk-based business licensing and investment facilities through OSS. It is also relevant to reviewing licensing, investment data, and investment facilities. Source: peraturan.bpk.go.id
Do not overlook the operational plan
The new business field must match the operational plan. For example, will the company open a warehouse, factory, clinic, outlet, branch office, or production facility? Each form of activity can require additional documents.
If the new activity will take place elsewhere, the company also needs to check address suitability, zoning, building permits, environmental permits, or other basic requirements relevant to the field.
JHY Legal’s Experience Adding PT PMA Business Fields
JHY Legal handles corporate actions, immigration, and regulatory licensing through an approach connecting changes to company documents with their licensing effects. When adding PT PMA business fields, a review may involve company establishment (PT PMA / local PT), share transfers & restructuring, changes to directors & commissioners, capital increases, due diligence, corporate compliance audits, NIB & OSS compliance, sectoral licensing, operational permits, and business risk classification. In practice, risks often arise when companies add KBLI codes without checking foreign ownership limits, technical permits, or changes to deed data. An initial review helps the company determine whether the new business field is ready to be added or requires document adjustments first.
Checklist Before Adding Business Fields
Before adding a business field to a PT PMA, you can use the following checklist to give the process clearer direction.
- Ensure the new business activities are clearly described.
- Select the KBLI code most suited to the actual activities.
- Check whether that KBLI code is open to foreign capital.
- Check for foreign ownership limits or partnership requirements.
- Check the business risk level in OSS.
- Check sectoral licensing or PB UMKU requirements.
- Check whether the deed needs amendment.
- Check whether the investment value and project location are ready.
- Check whether OSS, NIB, and company document data will remain consistent.
- Retain all approval evidence and amendment documents.
This checklist does not replace a legal review. However, it can help internal teams identify important matters before taking administrative steps.
Common Mistakes
The first mistake is selecting a KBLI code based on a similar-looking word without reading the scope of activities. This can leave the company with a KBLI code that does not match its actual activities.
The second mistake is forgetting to check foreign ownership. This matters because a PT PMA must ensure that its share structure fits the business fields it operates.
The third mistake is assuming an NIB is sufficient for every activity. Under risk-based licensing, certain fields may require a permit, standard certificate, verification, or PB UMKU.
JHY Legal usually recommends creating a licensing map before adding a business field. It should include KBLI codes, foreign ownership limits, risk levels, sectoral licenses, project locations, and documents that need updating.
Closing
Adding a business field to a PT PMA involves more than adding a KBLI code. The company needs to ensure that the new field fits foreign ownership limits, OSS risk levels, sectoral licensing, deed documents, and investment plans.
Preparing this process early helps avoid inconsistent data and reduces licensing risks. It also makes the company better prepared to conduct new activities without unnecessary administrative obstacles.
A practical step you can take now is to list the new business fields, selected KBLI codes, foreign ownership percentages, risk levels, project locations, and required permits. If any element is unclear, JHY Legal can help review the addition of PT PMA business fields so that the OSS process and company documents are more orderly.
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