OSS has not published a regulatory profile for KBLI 19204 yet
This is a new KBLI 2025 code. Indonesia's OSS portal still operates on KBLI 2020 and there is no automatic mapping to a 2020 predecessor for this activity. The risk level, permits, and obligations have not been finalised in the public OSS database.
The absence of data is not evidence the activity is unregulated.
Many of Indonesia's most heavily regulated activities — including construction of military facilities, airports, defence equipment, banking infrastructure, hospital facilities, and critical utilities — are subject to substantial extra-OSS licensing through sector ministries (Defence, Transport, Health, OJK, Bank Indonesia). The OSS Standard Certificate or Operating License is just one layer.
- ·NIB registration (we obtain through OSS — universal, instant)
- ·Sector-specific operating license — see industry guidance below
- ·PT PMA paid-up capital IDR 2.5 billion (~USD 160K) at incorporation, plus IDR 10 billion+ total investment commitment per KBLI realised over time (BKPM Reg. 5/2025)
- ·Quarterly LKPM reporting to BKPM (we file on your behalf as part of compliance)
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.
Foreign investment status not yet verifiable
Indonesia's BUPM Investment Business Fields list (Pres. Reg. 10/2021) is published against KBLI 2020 codes. KBLI 19204 is a new KBLI 2025 entry without a recorded 2020 predecessor, so the absence of this code from the closed / conditional / SME-reserved / partnership lists does not prove the activity is open to foreign investment. We can secure written confirmation from BKPM and the sector ministry on your specific business plan before any incorporation step.
Manufacturing-specific guidance
Sector context that applies to KBLI 19204 beyond the generic OSS process. Verify with the relevant ministry before committing capital.
- ·Industry data reporting via SIINas every 6 months.
- ·BPOM registration required for any food, drug, cosmetic, or medical device produced.
- ·Halal certification mandatory for most consumable products.
What is KBLI 19204?
A plain-English explanation of this classification and the businesses it covers.
KBLI 19204 (INDUSTRI MINYAK PELUMAS DASAR (BAHAN BAKU PELUMAS)) is the 5-digit Indonesian Standard Industrial Classification code for base lubricant oil industry (lubricant raw materials). It sits within under the subgroup (major group ) in the official KBLI 2025 taxonomy maintained by Statistics Indonesia (BPS).
Who needs KBLI 19204?
Any Indonesian or foreign-owned entity that intends to operate in base lubricant oil industry (lubricant raw materials) as a primary or secondary business activity must select this code on its NIB (Business Identification Number). The selected code determines the licensing instruments required, the issuing authority, and the ongoing compliance obligations.
Why does the code matter?
Indonesia's OSS Risk-Based Approach uses the KBLI code to determine three things: (1) whether foreign investment is permitted and at what cap, (2) the risk-based licensing instruments required, and (3) the authority that issues each instrument. Choosing the wrong code can delay or invalidate your license.
Under the upcoming KBLI 2025
Indonesia's BPS published the new KBLI 2025 taxonomy in early 2025. OSS, BKPM and the operating ministries have not yet adopted it — KBLI 2020 remains the active standard for business registration. This is what's coming for this specific code.
New code introduced in KBLI 2025
KBLI 19204 did not exist in the previous (KBLI 2020) taxonomy — it was added in the 2025 release to capture an activity that was previously bundled with another code or had no dedicated classification.
- ·Not yet usable for OSS registration. OSS, BKPM and operating ministries still operate on KBLI 2020 — this code isn't selectable in OSS until the cutover.
- ·For current registrations covering this activity, we identify the closest KBLI 2020 code that matches your business and register under that. When KBLI 2025 goes live we'll migrate your entity to 19204.
- ·The migration is a procedural update — no re-registration, no operational interruption. We handle it as part of ongoing compliance.
When OSS adopts KBLI 2025, we'll migrate your existing entity to the appropriate successor code as part of ongoing compliance — no action needed on your end now.
Talk to a specialistCommon questions about KBLI 19204
What is KBLI 19204?
KBLI 19204 (INDUSTRI MINYAK PELUMAS DASAR (BAHAN BAKU PELUMAS)) is the 5-digit Indonesian Standard Industrial Classification code for base lubricant oil industry (lubricant raw materials). It sits within the Industry category in the official KBLI 2025 taxonomy maintained by Badan Pusat Statistik (BPS).
Can foreign investors operate under KBLI 19204?
Not in practice. KBLI 19204 is not on Pres. Reg. 10/2021's closed list, but OSS RBA only defines licensing rules at the Micro and Small business scales for this activity — there is no Large-scale matrix. Foreign-owned PT PMA must register at the Large scale, so this code isn't structurally available to foreign investors. PT lokal (100% Indonesian-owned) at the Micro / Small scale can operate freely.
What is the risk level of KBLI 19204?
KBLI 19204 has no Large-scale licensing matrix in OSS — it's structured for Micro and Small business scales only. PT PMA cannot register under this code as a result.
