Foreign Ownership in Indonesia: What to Review Before Incorporation

Start with the activity, not the share percentage

Foreign ownership analysis should begin with what the Indonesian entity will actually do. A company may plan to trade, manufacture, provide services, import products or combine several activities, and each activity should be mapped before the shareholder structure is finalised. This avoids designing an ownership structure around an incomplete or outdated description of the business.

Map the operating model to current KBLI classifications

The business description should be translated into current KBLI classifications and reviewed together with the intended location, sector and operating model. The goal is not to collect the largest possible number of codes, but to create a licensing profile that genuinely supports the planned revenue-generating activities.

Review the whole group structure

Corporate shareholders, ultimate beneficial owners, directors, commissioners, funding arrangements and intercompany relationships should be considered together. A structure that is legally possible may still create practical tax, banking, governance or licensing consequences that are better identified before incorporation documents are signed.

Treat ownership review as an early project gate

Once the proposed activities and ownership have been aligned, the company can move into incorporation, NIB and business-licensing workstreams with fewer structural surprises. Where a sector-specific rule or unusual ownership question remains unresolved, it should be flagged for specialist review rather than treated as a generic assumption.

Official references

Use current official information alongside any project-specific review, as requirements and system implementation can change.

• OSS RBA — English Home / NIB and 4 risk levels
• OSS — KBLI 2025 Search