Adding or changing a KBLI code is not merely an administrative edit. It can change what an Indonesian company is legally described as doing, which risk profile applies in OSS, which business licence is generated, whether foreign ownership is permitted, and which location, product, environmental or sector approvals must be satisfied. The safest route is to define the real activity first, align the company documents where required, and then update the licensing record in the correct sequence.
Key Takeaways
- Choose a KBLI code from the activity the company will actually perform, not from a convenient label or a competitor’s NIB.
- Distinguish a KBLI 2020-to-2025 conversion from a genuine change or expansion of business activity. The official conversion tool is a reference, not a project-specific legal conclusion.
- If the company’s purposes and activities do not cover the proposed activity, corporate records may need to be amended through the applicable AHU process before OSS is updated.
- Adding a KBLI activity can create a new OSS project record and new licensing obligations; it does not automatically make the activity operational.
- Review foreign ownership, risk classification, location, facilities, products, sector rules and supporting licences for every added activity.
- Do not remove an existing KBLI until contracts, licences, reporting duties and the status of the underlying operation have been checked.
Can an Indonesian Company Add or Change a KBLI Code?
Yes, an Indonesian company can generally update its business activities, but the required route depends on what is actually changing. If the company is only moving an existing activity from KBLI 2020 to its corresponding KBLI 2025 classification without changing the nature of the business, the current government implementation framework may allow a system-supported conversion. The Ministry of Law’s KBLI 2025 implementation guidance distinguishes this code-only conversion from an expansion or change of activity. If the company is adding a new line of business, replacing an activity, or changing the operational scope, it should first assess whether its articles of association and AHU record need amendment.
The licensing step follows the corporate step. In OSS, each activity is assessed using its own KBLI, location and project data. The result may be an updated NIB entry together with a Standard Certificate, licence, supporting business licence, or other requirements determined by the risk-based framework. An NIB showing a new KBLI should therefore be treated as identification and registration, not as universal proof that every requirement for the new activity has been completed.

First Decide: Is This a Conversion or a Business Change?
This distinction prevents unnecessary amendments and, just as importantly, prevents a real business expansion from being treated as a simple code migration.
| Situation | What it usually means | Planning response |
|---|---|---|
| The activity is unchanged, but its KBLI 2020 code has a KBLI 2025 successor. | A classification conversion may be involved. | Use the official OSS KBLI conversion reference, then verify the new title, description and scope. |
| A former code splits into several new codes. | The company may need to identify which successor activity reflects its actual operations. | Review the 1:N conversion result and test each candidate against products, customers, process and revenue model. |
| The company will sell, manufacture or provide something it did not previously offer. | This is a substantive addition or change of activity. | Assess corporate-purpose amendments, ownership eligibility and a new OSS licensing pathway. |
| The code was selected incorrectly, while operations never changed. | A data correction may be required, but it can still affect licences and records. | Document the error, verify the correct code and obtain procedural guidance before overwriting or removing data. |
The official OSS conversion guide explains that mappings can remain one-to-one, change one-to-one, split, merge or be reorganized. It also expressly treats the conversion information as a reference rather than a legal decision. A company should therefore read the complete KBLI 2025 description instead of relying on the old title or the first result returned by a keyword search.
What to Check Before Adding a KBLI Activity
1. The commercial substance
Write a plain-language description of the proposed activity: what the company will make or provide, who buys it, how revenue is earned, what happens at the Indonesian location, and which party imports, stores, distributes or installs the product. The correct classification is driven by the activity itself. A broad business-plan phrase such as “technology services” or “general trading” is rarely precise enough.
2. The full KBLI 2025 scope
Review the title, description, inclusions and exclusions in the official KBLI material. KBLI 2025 is the official classification standard established through BPS Regulation No. 7 of 2025. Do not assume that a familiar code retained the same wording or scope.
3. Corporate-document alignment
Compare the proposed activity with the company’s stated purposes and activities in its deed and AHU record. The Ministry of Law’s AHU company guidance treats a change to a limited liability company’s purposes and activities as an articles-of-association matter. If the new activity is not already covered, coordinate the corporate approval, notarial deed and AHU filing before treating the OSS update as a standalone task.
4. Foreign-ownership eligibility
For a PT PMA, a commercially accurate code may still be unsuitable if the activity is reserved, limited, subject to a special licence or governed by sector-specific ownership rules. Screen every proposed activity individually. Never infer an ownership percentage from another company’s structure or from a generic summary of Indonesia’s investment list.
5. Risk and supporting approvals
The OSS system applies risk-based licensing at the activity and project level. The new activity’s risk tier influences the main licensing instrument, but actual readiness may also depend on spatial-use compatibility, environmental approvals, buildings, sector standards, products, imports, professional qualifications or other supporting permissions.

How to Add or Change KBLI Codes: A Practical Sequence
- Define the target operating model. Record activities, locations, products, facilities, customers, supply chain, workforce and expected start date.
- Shortlist the applicable KBLI 2025 codes. Read the official scope of each candidate and document why it matches.
- Run the investment and sector screen. Check whether the activity is open to the intended ownership structure and whether a sector regulator imposes additional conditions.
- Compare the shortlist with the deed and AHU record. Identify whether the purposes and activities already cover the target business.
- Complete the corporate amendment when required. For a PT, this can involve shareholder approval, a notarial deed and the applicable AHU approval or notification process. The precise formalities should be confirmed for the entity and amendment.
- Prepare the OSS project data. Confirm the address, scale, investment data, land or building details, workforce and other fields required for the activity.
- Add or update the activity in OSS. Use the current change or business-development workflow applicable to the company’s record. Follow the live system prompts because forms differ by entity, project and activity.
- Review the generated licensing output. Check the updated NIB attachment, risk level, Standard Certificate or licence status, prerequisites and supporting approvals.
- Complete outstanding requirements before operating. A displayed code or issued NIB does not override a pending verified Standard Certificate, licence or activity-specific approval.
- Reconcile connected records. Update internal compliance registers, contracts, invoices, tax and customs configurations, product registrations, lease or facility documents, and periodic reporting where relevant.
Companies can use IndoGateway’s Indonesia licence checker for an initial view of possible licensing workstreams, then arrange project-specific verification before implementation.
What an Updated NIB Does Not Automatically Solve
An updated NIB can show that the business actor and activity are registered in OSS, but the NIB should not be read in isolation. The activity entry may show another licensing instrument as pending or may lead to prerequisites and supporting approvals outside the core NIB document.
- Location: A new warehouse, office, shop or factory can create spatial, land, environmental, building or local operational dependencies.
- Products: Food, cosmetics, medical devices, telecom equipment and other regulated products may require separate market-access work.
- Import and distribution: Adding wholesale or manufacturing scope does not by itself settle importer status, product restrictions or distribution arrangements.
- Workforce: A new technical or operational function may affect manpower planning, professional certification and foreign-personnel approvals.
- Reporting: Additional investment projects and licences can expand the company’s ongoing reporting and compliance calendar.
This is why an activity-level licensing review is more useful than asking only whether the NIB has been reissued. IndoGateway’s NIB and OSS business licensing service is designed around the wider operating pathway.

Be Careful When Removing or Replacing an Existing KBLI
Removing an activity can be more sensitive than adding one. The code may be linked to an active licence, a location, a product approval, a customer contract, a tax or customs configuration, an investment report or an unresolved compliance obligation. Deleting or replacing the OSS entry before those connections are mapped can leave the company’s legal and operational records inconsistent.
Before removal, confirm that the company has genuinely stopped the activity and identify whether any licence needs amendment, surrender, closure reporting or continued record retention. Review open projects, applications, inspections and contractual commitments. Where OSS offers more than one action, such as changing data, developing an activity, converting a legacy project or revoking a licence, select the route that matches the real legal event rather than the route that merely removes the visible code.
Common KBLI Change Mistakes
- Choosing by title alone. Similar titles can have materially different inclusions, exclusions and regulatory consequences.
- Updating OSS before AHU alignment. The licensing record can conflict with the company’s corporate purposes.
- Treating a conversion as an expansion. Selecting every successor of a split code can accidentally add activities the company does not perform.
- Treating an expansion as a conversion. A genuinely new activity may require shareholder and notarial steps that a simple code migration does not address.
- Ignoring foreign-ownership rules. A PT PMA structure that works for one activity may not work for another.
- Assuming issuance equals readiness. A new NIB attachment may coexist with an unverified certificate, pending licence or incomplete supporting approval.
- Using one project address for convenience. Project location can influence spatial, environmental and sector licensing results.
- Removing the old code too early. Existing licences, contracts and reports may still depend on it.
KBLI Change Readiness Checklist
- A written description of the current and proposed activities
- The selected KBLI 2025 title, code, description and rationale
- The applicable 2020-to-2025 conversion result, if relevant
- A copy of the latest deed, amendment deeds and AHU outputs
- A foreign-ownership and sector eligibility review
- Project address, facilities, land or lease information and operating model
- Expected OSS risk tier and main licensing instrument, subject to system confirmation
- A list of product, import, environmental, building, workforce and supporting licences
- A transition plan for existing licences, contracts and reporting
- A post-update review of the NIB attachment and every activity status
For a broader company-level review, see the Indonesia compliance solution and the build and operate in Indonesia pathway.
Frequently Asked Questions
1. Can I add a KBLI code directly in OSS without changing the company deed?
You should not assume that OSS is the only step. If the proposed activity is already covered by the purposes and activities in the company’s latest deed and AHU record, a separate articles amendment may not be necessary for that reason alone. If the activity falls outside that scope, corporate alignment can be required before or alongside the OSS update. Review the exact deed wording, AHU data, entity type and proposed activity with the notary or qualified adviser. A successful data entry in OSS does not by itself cure a mismatch in the company’s constitutional documents.
2. Does changing a KBLI code create a new NIB?
A company normally operates under its business identity in OSS, while the NIB attachment can be updated to reflect registered activities and projects. The practical output depends on the type of transaction performed in the current OSS workflow, including conversion, data change, activity development or another permitted action. Do not plan around a universal promise that a completely new number will or will not be issued. Instead, verify the saved activity list, download the latest NIB documentation, compare it with the prior version and check the licence status shown for every affected project.
3. How long does it take to add or change a KBLI in Indonesia?
There is no responsible universal timeline because a KBLI change can range from a system-supported classification conversion to a corporate amendment followed by location, environmental, sector and risk-based licensing steps. Timing can depend on shareholder approvals, notarial preparation, AHU processing, data synchronization, the selected activity, project location, regulator verification and the completeness of supporting documents. Companies should build a dependency-based schedule rather than relying on a single advertised turnaround. The activity should not start merely because one system step has finished if another required licence or verification remains outstanding.
4. Can a PT PMA add any KBLI activity it wants?
No. A PT PMA should screen every proposed activity for foreign-investment eligibility, sector restrictions, business-scale requirements and special licensing conditions before adding it. A code that accurately describes the commercial plan may still be unavailable to the intended ownership structure or may require a different operating arrangement. The result can also depend on the company’s products, customers and role in the supply chain. Avoid using another PT PMA’s NIB as a precedent because its ownership, approvals, grandfathering position, project details or actual activity may differ from yours.
5. What happens if the wrong KBLI code is selected?
An incorrect code can produce the wrong risk assessment, licence pathway, reporting obligations or ownership analysis. It can also create inconsistencies among the deed, AHU data, NIB, contracts, tax records and actual operations. The appropriate correction depends on whether the issue is a data error, an outdated classification, or a genuine change of business. Document the facts, identify the correct KBLI 2025 scope, and review affected licences before changing the record. Avoid deleting an activity impulsively if active approvals, applications, transactions or compliance duties are connected to it.
6. Do I need a new business licence after adding a KBLI?
Possibly. The added activity is assessed through Indonesia’s risk-based licensing framework using the KBLI and project information. A low-risk activity may have a different primary output from a medium- or high-risk activity, and supporting approvals may still apply. The exact result can depend on scale, location, facilities, products, environmental impact and sector rules. After the update, examine the activity-specific OSS status rather than looking only at the NIB. Confirm whether a Standard Certificate requires verification, a licence remains pending, or supporting business licences and prerequisites must be completed before operations begin.
7. Should a company delete an old KBLI after changing its business model?
Only after it has reviewed the consequences. An old activity may remain connected to a valid licence, a facility, an investment report, a tax or customs setup, product registrations, customer contracts or residual obligations from discontinued operations. First decide whether the activity has truly ceased, whether the company needs a transition period, and whether any approval requires amendment, surrender or closure reporting. Map these dependencies and preserve the necessary records. The correct OSS action should reflect the underlying legal event; simply hiding an obsolete-looking code can leave other official and commercial records unresolved.
8. How should a company prepare for the KBLI 2020-to-2025 transition?
Start with the official OSS conversion tool and classify each existing code as unchanged, changed, split, merged or reorganized. Then read the full KBLI 2025 descriptions and compare them with the company’s actual activities, deed, AHU record and OSS projects. Do not automatically accept every successor where one old code splits into several new ones. The official government guidance distinguishes code-only conversion from a real expansion or change in activity. Maintain a conversion log, record the chosen rationale, check all regenerated licences and obtain professional review where ownership or regulated-sector consequences are material.
Conclusion
The right way to change KBLI in Indonesia is to treat classification, corporate authority and business licensing as one connected exercise. Begin with the real operating model, select the precise KBLI 2025 scope, determine whether the change is only a conversion or a substantive expansion, align the deed and AHU record where necessary, and then complete the activity-specific OSS pathway. The final check is not whether a code appears on an NIB; it is whether the company has every approval required to carry out that activity at the intended location and scale.
Regulatory note: Indonesian investment, licensing, tax, immigration, product, environmental and operating requirements may change and may depend on the business activity, ownership structure, location, products and project circumstances. This article provides general information and is not project-specific legal, tax or regulatory advice. Applicable requirements should be verified before implementation.
Plan Your KBLI Change Before Editing OSS
IndoGateway can help map the proposed activity, check KBLI and ownership fit, coordinate corporate-document alignment, and identify the linked OSS and operating approvals. Contact IndoGateway for a project-specific licensing review before adding, replacing or removing a KBLI activity.




