Foreign Investor FeasibilityKBLI 03121
§ 01
Foreign investment rules
Indonesia's BUPM (Investment Business Fields) regulation places this code into one of five tracks. The track determines whether a foreign investor (PMA) can operate in this activity at all, and under what conditions.
Status · No foreign ownership
Reserved for small Indonesian operators
KBLI 03121 is set up for warungs, smallholders, individual practitioners and similar small businesses — Indonesia's licensing rules only define micro and small business sizes for it. Foreign-owned companies have to register at the Large business size, so even though this code isn't on the official "closed" list, foreign ownership isn't possible in practice. Pick a related KBLI that covers larger operations, or set up a partnership with an Indonesian operator who already holds the licence.
This activity is reserved for small Indonesian operators — think warungs, food stalls, smallholders, individual practitioners. KBLI 03121 only has licensing rules defined for micro and small business sizes. Foreign-owned companies have to register at the Large business size, so this code isn't available to them even though it's not on the "closed" list. Pick a related KBLI that covers larger operations, or ask us about partnering with an Indonesian operator who already holds the licence.
§ 02
Fisheries & aquaculture-specific guidance
Sector context that applies to KBLI 03121 beyond the generic OSS process. Verify with the relevant ministry before committing capital.
Lead regulator
Ministry of Marine Affairs & Fisheries (KKP)
- ·Capture fisheries beyond 12 nautical miles require SIPI/SIKPI permits.
- ·Foreign-flagged vessels are restricted from Indonesian fishing waters.
- ·Aquaculture (KBLI 0321/0322) is more open to PMA, especially seaweed and shrimp farming.
§ 03
Regulations governing KBLI 03121
Current status, what each regulation actually requires for this activity, and how it ties to the PB UMKU sector permits below. Click through for the plain-English summary.
- House of Representatives of the Republic of Indonesia
- President of the Republic of Indonesia
- President of the Republic of Indonesia
§ 02
What this means for foreign investors
An honest read of the situation, plus the structures that work in practice. We've handled all of these — book a call to walk through your specific plan.
Pathways that work
Move to a different value-chain step
The cleanest path: operate a related but open KBLI. For example, foreign investors blocked from primary commodity production frequently succeed with the processing, distribution, branding, or export-trade codes upstream or downstream of the restricted activity.
Special Economic Zone (KEK) or Free Trade Zone (Batam)
Several restricted codes have higher or full PMA caps inside designated KEK zones (Sanur Health, Lido, Mandalika) or the Batam Free Trade Zone — manufacturing, logistics, and IT services especially. The IUK regime under BP Batam relaxes ownership rules selectively in exchange for export orientation. We assess whether your operation can benefit. See the for the requirements.
Indonesian-owned operating company + commercial agreement
A 100% Indonesian-owned operating entity can hold the restricted licence while you contract with it commercially. We structure these arrangements deliberately — without nominee shareholding, which is unenforceable and increasingly scrutinised.
PMA-viable codes in adjacent industries
These KBLIs solve a related business problem and are open to foreign ownership. None are a perfect substitute for the activity above — but they often unlock 80% of the commercial outcome. Talk to us about which fits your plan.
Restricted KBLIs need a tailored structure. Book a call and we'll map the right entity, partner, and licensing path for your specific business.
Talk to a corporate-services specialist§ 07
Reference data: how this KBLI is regulated
The data below is the official OSS regulatory profile for this code. It applies to qualifying Indonesian operators (or to your operating partner). Foreign investors won't file these directly, but it's useful context when structuring a partnership or commercial arrangement.
Foreign investors:the licensing matrix below is for context only — direct PMA registration isn't possible for this code. See pathways above for what actually works.
Sub-activity scope
This group includes businesses or activities related to the capture of freshwater fish species such as betok, sepat, bilih, depik, genggehek, kancera, kendia, lalang, mas, lukas, repang, lampan, tawes, seren, tontong tebu, tambakan, tempe, sumpit, sepat rawa, berukung, jelawat, parang, teri, bentilak, lais, sepat siam, betutu, gurame, sidat, baung, keting, gabus, toman, lele, hampal, lalawak, nilem, semah, silih, belida, siluk/arwana, patin, lempuk, mujair, nila, finned fish, beunteur, koan, in inland waters, such as lakes, rivers, reservoirs, swamps, and other water bodies.
What's required to operate
NIB
Preparation only — additional permit needed below
Standard Certificate (Self-declared)
Important: NIB is issued for the preparation stage. To begin commercial operations, the operator must self-declare compliance with applicable standards via OSS, which generates the Sertifikat Standar. Operating commercially with NIB alone is not legally compliant at this risk level.
Application requirements
0Documents and capabilities you must demonstrate at registration
No specific application requirements at this scale.
Ongoing obligations
5Compliance and reporting duties throughout operation
- 01For those using fishing vessels:
- 02Possess a Fishing Vessel Book
- 03Reporting caught fish for those not using fishing vessels:
- 04Reporting caught fish and
- 05Provide information: a. Fishing areas and b. Fishing gear.
Issuing authority
The authority that issues the license depends on your situation.
| Authority | Applies when |
|---|---|
| Regent/Mayor | Business actors are domiciled in the administrative area of the respective district/city. |
| Minister/Head of Agency | Foreign Investment |
§ 05
Auxiliary permits (PB UMKU)
PB UMKU permits sit on top of the main NIB and Sertifikat Standar — each is issued by a different ministry, and only when a specific operational activity is performed. This KBLI carries 1 candidate permit across 1 regulator; most operations only need a handful. Emerhub maps your operation to the exact set, files them, and tracks renewals.
Marine & Fisheries
1 permitMinistry of Marine Affairs & Fisheries (KKP). Applies to capture fishing, aquaculture, fish processing, fish-feed production, and live-fish trade. The Processing Feasibility Certificate (SKP) is the gating quality permit for fish processors.
Speak to Emerhub
KBLI 03121 needs a tailored structure. Let's design it.
Restricted KBLIs need a structure designed around the restriction — partnership, alternative code, KEK, or commercial arrangement. We've handled all of these. One conversation tells you what works for your plan.