Country：印尼 · Licensing & Market Access
Indonesia · Licensing & Market Access
Indonesia's sector-access system centres on the Positive Investment List (old DNI): 27 sub-sectors prohibit foreign investment, restricted sectors require a local partner. All foreign companies must obtain NIB via OSS-RBA and a risk-based licence; food, pharma, finance, construction and telecom need sector-regulator approval. Special Economic Zones (SEZ) and bonded zones offer extra facilitation.
Key points
- Access system: Positive Investment List sets foreign-ownership per KBLI; 27 sectors prohibit foreign entry (traditional fishing, public education, radioactive processing, etc.).
- Restricted: retail local ≥30%, some construction 67%, pharma distribution 33% — must be JV.
- General licence: NIB integrates business licence, import ID and export ID, auto-issued via OSS-RBA.
- Sector licence: food/pharma (BPOM), finance (OJK), construction, telecom/media need separate ministry approval.
- SEZ: income-tax reduction, import-duty exemption, attracts manufacturing & logistics.
Procedure
- Verify sector foreign-ownership against Positive Investment List.
- Apply NIB via OSS-RBA and match risk-based licence (low-risk auto, high-risk needs docs).
- If regulated sector, apply sector licence from BPOM/OJK/Ministry of Industry etc.
- Evaluate SEZ/bonded-zone for tax & customs facilitation.
Hard requirements
- Sector licence; restricted sectors need local partner; special business qualifications (food/pharma/finance etc.).
Costs
Licence & approval fees; local-partner or advisor cost.⏱ ⏱ Timeline：NIB days; sector licence weeks to months by sector.⚠ Common risks
- Failing local-ownership requirement → forced equity adjustment.
- High-risk sector licence lag → delayed production.
- KBLI & licence mismatch → OSS rejection.
Handbook
📘 Step-by-Step Handbook (with owner / timeline / cost / penalties)
Applies to：Foreign investors entering regulated sectors (food/pharma, finance, construction, telecom/media, retail) needing sector licences and investment coordination.
Prerequisites
- Selected KBLI and verified foreign-ownership against Positive Investment List.
- Confirmed whether high-risk or restricted sector.
- Evaluated SEZ/bonded-zone suitability.
- Planned local-partner arrangement for restricted sectors.
| Step | Action | Owner | Timeline | Cost | Official form / system | Notes & penalties |
|---|---|---|---|---|---|---|
| 1 | Verify sector foreign-ownership vs Positive Investment List By KBLI, check list: fully open, capped (retail local ≥30%, construction 67%, media 20%), local-partner required (106 sector lines), fully prohibited (gambling, certain fishing). | BKPM / licensed advisor | 1 week | Advisor fee | Positive Investment List (Perpres 10/2021 amd 49/2021) | Penalty：Ownership violation → licence rejected or post-setup adjustment |
| 2 | Apply NIB via OSS-RBA & match risk-based licence NIB auto-integrates business licence & import/export IDs; risk level decides附加 licence depth (low=self-declaration, high=AMDAL/UKL-UPL EIA + operational licence). | OSS / BKPM | Low-risk instant; mid/high-risk days to weeks | Free | NIB + risk-based licence | Penalty：Operating without NIB illegal; high-risk operating before EIA → penalty |
| 3 | Sector licence from BPOM/OJK/Ministry of Industry etc. Food/pharma apply circulation licence (izin edar) to BPOM; finance apply licence to OJK; construction/engineering, telecom/media to respective ministries. | Relevant ministries | Weeks to months by sector | Licence & approval fees | Sector business licence | Penalty：Missing sector licence → cannot operate that line |
| 4 | Evaluate SEZ / bonded-zone landing KEK, KPBPB bonded zones and industrial estates offer income-tax reduction, import-duty exemption and accelerated licensing; manufacturing & logistics prioritise. | Company / BKPM | Planning stage | By park | SEZ/bonded-zone access application | Penalty：Not evaluating → miss tax & customs facilitation |
| 5 | KBLI 2025 adaptation (OSS/AHU rollout from 2026) BKPM promotes KBLI 2025 in OSS & AHU from 2026; confirm KBLI version used at registration/change to avoid mixing old/new codes. | BKPM / AHU | Watch switch from 2026 | None | OSS KBLI 2025 mapping | 2026 switch per official announcement (medium) Penalty：KBLI mismatch in switch period → ownership/licence misjudgment (medium uncertainty) |
| 6 | Local-partner arrangement for restricted sectors For the 106 sector lines requiring local partner, use JV, subcontracting, supply-chain integration or cooperative-MSME partnership per compliance. | Company / legal advisor | Pre-setup | JV/partnership cost | JV agreement / cooperative-MSME partnership | Penalty：Failing local-ownership/partnership → forced structure adjustment |
✅ Self-check list
⚠ Common pitfalls
Failing local-ownership → forced equity adjustment影响：High post-setup rectification cost, operational delay规避：Set equity & partnership per Positive Investment List pre-registration
High-risk sector licence lag delays production影响：Operating before EIA/operational licence → penalty规避：Schedule sector licence upfront, link with OSS risk level
KBLI & licence mismatch → OSS rejection影响：Returned for correction, extended cycle规避：Match business substance to correct KBLI, don't pick wrong code to lower risk level
Assume fully 100% open across all sectors影响：Old negative-list thinking, miss partnership/cap requirements规避：Verify item-by-item via Positive Investment List, not by broad sector
Missing sector licence (food/pharma/finance)影响：Cannot legally operate that business line规避：Enumerate regulator list, pre-communicate with BPOM/OJK
KBLI 2025 switch-period mismatch影响：Old/new code mix → ownership/licence misjudgment (medium)规避：Confirm KBLI version per BKPM announcement, advisor review if needed
📅 Ongoing post-incorporation obligations
- NIB & risk-based licence kept valid.
- Sector licence annual inspection/renewal (BPOM/OJK etc.).
- LKPM quarterly/semi-annual reports.
- KBLI or scope change → update OSS promptly.
- Local-partner performance & partnership reporting.
🔗 Official portals
📎 Source：https://www.bkpm.go.id ; https://www.ojk.go.id ; https://www.pom.go.id ; https://peraturan.bpk.go.id
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