Foreign Investor FeasibilityKBLI 20115
§ 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 20115 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.
Listed restrictions
Requires SME / cooperative partnership
1- Coconut charcoal/coconut briquette industrySector: Industry
Tax incentives
Foreign-investor tax benefits available for this KBLI under PMK 130/2020 (Tax Holiday) and PP 78/2019 (Tax Allowance). Both require approval — see the linked guide for the application path.
Eligible for Tax Holiday
100% corporate income tax exemption for 5-20 years, plus 2 additional years at 50%. Tier scales with capex (IDR 100b minimum). Pioneer industry: Organic basic chemicals.
§ 02
Chemicals & pharmaceuticals-specific guidance
Sector context that applies to KBLI 20115 beyond the generic OSS process. Verify with the relevant ministry before committing capital.
Lead regulator
Ministry of Industry (Kemenperin) / BPOM
- ·Hazardous chemicals (B3) require KLHK environmental permits in addition to OSS.
- ·Pharmaceutical manufacturing requires CPOB (Good Manufacturing Practice) certification from BPOM.
- ·Most basic and intermediate chemicals are open to 100% PMA.
§ 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 the same area
These siblings are usable by a foreign-owned PT PMA — they have a Large-scale licensing matrix and aren't on a restricted list. Each has its own context badge so you can pick by trade-off.
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§ 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 17 candidate permits across 3 regulators; most operations only need a handful. Emerhub maps your operation to the exact set, files them, and tracks renewals.
Pharmaceuticals
11 permitsBPOM (National Agency of Drug & Food Control). Applies to drugs, processed food, traditional medicine, cosmetics, and health supplements — produced, imported, repackaged, or distributed for human consumption. BPOM is the gating regulator; product registration is required before any commercial sale.
- Approval for the Implementation of Processed Food Clinical TrialsPersetujuan Pelaksanaan Uji Klinik Pangan Olahan2 requirements1 obligationFood and Drug Supervisory Agency
- Certificate of Approval for Major Variations in Processed Food Mandatory SNISertifikat Persetujuan Variasi Mayor Pangan Olahan Wajib SNI2 requirements1 obligationFood and Drug Supervisory Agency
- Certificate of Compliance with Major Processed Food Commitment VariationsSertifikat Pemenuhan Komitmen Variasi Mayor Pangan Olahan2 requirements3 obligationsFood and Drug Supervisory Agency
- Certificate of Good Manufacturing Practice for PharmaceuticalsSertifikat Cara Pembuatan Obat yang Baik3 requirements3 obligationsFood and Drug Supervisory Agency
Defence & Security
5 permitsMinistry of Defence. Applies when the operation produces, stores, or distributes weapons, ammunition, military vehicles, or explosives. The Ministry of Defence vets and re-vets the operator across the lifecycle.
- Business License for Research and Development of Explosives and Explosive AccessoriesIzin Usaha Penelitian dan Pengembangan Bahan Peledak dan Bahan Peledak Aksesoris11 requirements5 obligationsDefense
- License for Establishing an Explosive Material Business Entity FactoryIzin Pendirian Pabrik Badan Usaha Bahan Peledak13 requirements5 obligationsDefense
- Marketing LicenseIzin Pemasaran8 requirements3 obligationsDefense
- Production License for Explosive Material Business EntityIzin Produksi Badan Usaha Bahan Peledak11 requirements5 obligationsDefense
Veterinary & Animal Medicine
1 permitMinistry of Agriculture. Applies if you produce, import, distribute, or sell animal medicines, vaccines, or feed; if you breed livestock; or if you operate a veterinary practice. A "veterinary control number" (NKV) is the entry-point permit for animal-product processors.
Speak to Emerhub
KBLI 20115 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.