How To Amend KBLI Codes When Expanding into New Business Lines in Indonesia

Posted by Written by Ayman Falak Medina Reading Time: 3 minutes

Foreign investors expanding into new activities in Indonesia often find that their existing KBLI (Indonesian Standard Industrial Classification; Klasifikasi Baku Lapangan Usaha Indonesia) no longer reflects the company’s operational scope. Because KBLI codes determine what a business is legally permitted to conduct under its NIB (Business Identification Number; Nomor Induk Berusaha), they directly shape licensing requirements, sectoral approvals, and tax treatment.

Related Reading
Business Intelligence in Indonesia: Reducing Investor Risks with Data-Driven Decisions

Accurate KBLI alignment is essential for maintaining compliance within Indonesia’s OSS-RBA (Online Single Submission – Risk-Based Approach) system.

When A KBLI amendment becomes necessary

A KBLI amendment becomes necessary when the company intends to carry out activities that fall outside the business lines listed in its NIB. This typically occurs when a service-based foreign-owned limited liability company (PT PMA) adds goods trading or importing, when a distributor expands into manufacturing, or when the company enters regulated sectors such as healthcare, pharmaceuticals, food distribution, logistics, or fintech.

Even operational shifts that appear modest, such as adding technical support functions requiring in-country personnel, can require new KBLI coverage.

The determining question is whether the new activity introduces regulatory, facility-based, or licensing obligations that differ from the company’s current structure. If it does, the KBLI must be updated before the activity can be lawfully undertaken.

How risk reclassification determines licensing obligations in OSS-RBA

OSS-RBA assigns each KBLI a risk level that governs the type of business license required and the regulatory scrutiny applied to the activity. When a company amends its KBLI codes, the system recalculates its overall risk profile. 

A shift into a higher-risk category can require facility verification, technical standards, or sectoral approvals that did not apply previously. If the revised activity involves goods distribution, food or pharmaceutical handling, or regulated digital services, OSS-RBA will link the company to authorities such as the National Food and Drug Authority, or licensing frameworks such as the pharmaceutical wholesaler license.

Find Business Support
For guidance on KBLI amendments and OSS-RBA compliance, contact Dezan Shira & Associates for tailored support.

In essence, risk reclassification determines which licensing pathways activate. Once OSS-RBA recalculates the risk, the system automatically identifies the specific licenses and approvals required to support the expanded scope of business.

Preparing internally before updating KBLI codes

Before submitting a KBLI amendment, foreign investors should map the new business line thoroughly. This includes identifying the precise activities to be added, the facilities required to support them, and the associated operational workflows. Proper mapping ensures accurate KBLI selection and prevents licensing mismatches.

If the new activity requires facilities such as warehouses, production spaces, or laboratories, the company must confirm that these locations can be declared within OSS-RBA and meet technical standards for regulated activities.

Companies expanding into goods-related business lines should ensure they can support the necessary supply chain, warehousing, or product-handling requirements. This internal readiness forms the foundation for a compliant and efficient amendment process.

Operational and tax implications after updating KBLI codes

Once the KBLI amendment is complete, the company’s operational and tax landscape may change significantly. Goods-related activities can require adjustments to VAT treatment, invoicing formats, and import registrations such as API-U, or Angka Pengenal Importir Umum (General Importer Identification Number), and NIK, or Nomor Induk Kepabeanan (Customs Identification Number). Service lines expanding into technical or on-site activities may require updates to the RPTKA, or Rencana Penggunaan Tenaga Kerja Asing (Foreign Manpower Utilization Plan), before deploying foreign workers.

Find Business Support
Speak with Dezan Shira & Associates to ensure your expansion plans align with Indonesia’s licensing and regulatory requirements

A KBLI change may also require updating the company’s LKPM, or Laporan Kegiatan Penanaman Modal (Investment Activity Report). If the expanded activity involves capital expenditure, facility investment, or equipment procurement, the investment plan must be revised to ensure consistency between the licensed business scope and the company’s reported investment commitments. This alignment prevents compliance issues during periodic reviews.

Common missteps foreign investors should avoid

Foreign companies often encounter predictable issues when amending KBLI codes.

Missteps include selecting codes that do not accurately reflect intended operations, underestimating the regulatory obligations generated by the new risk classification, or failing to adjust investment plans and reporting structures to match the expanded business scope.

How the KBLI amendment process typically progresses

The amendment process begins with internal scoping and operational mapping, followed by updating the NIB through OSS-RBA. Once the system recalculates risk, it identifies the business licenses and sectoral approvals required. Facilities are declared or verified where necessary.

After fulfilling licensing obligations, the company updates its investment plan, foreign manpower approvals, and periodic reporting to reflect the expanded business model. This sequence allows the expansion to proceed without rework or regulatory inconsistency.

About Us

ASEAN Briefing is one of five regional publications under the Asia Briefing brand. It is supported by Dezan Shira & Associates, a pan-Asia, multi-disciplinary professional services firm that assists foreign investors throughout Asia, including through offices in Jakarta, Indonesia; Singapore; Hanoi, Ho Chi Minh City, and Da Nang in Vietnam; and Kuala Lumpur in Malaysia. Dezan Shira & Associates also maintains offices or has alliance partners assisting foreign investors in China, Hong Kong SAR, Mongolia, Dubai (UAE), Japan, South Korea, Nepal, The Philippines, Sri Lanka, Thailand, Italy, Germany, Bangladesh, Australia, United States, and United Kingdom and Ireland.

For a complimentary subscription to ASEAN Briefing’s content products, please click here. For support with establishing a business in ASEAN or for assistance in analyzing and entering markets, please contact the firm at asean@dezshira.com or visit our website at www.dezshira.com.