Foreign Investor FeasibilityKBLI 28191
§ 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 · open
Open under BUPM (subject to sector rules)
KBLI 28191 is not on Indonesia's closed, conditional, SME-reserved, or partnership-required schedules under BUPM (Pres. Reg. 10/2021). A foreign investor can incorporate a PT PMA under this code, but sector regulators (PSE/Kominfo, BPOM, OJK, Kemenkes, Permendag, ESDM) almost always add licensing and capital requirements on top — the practical answer depends on your specific business model.
This KBLI is open under BUPM (Pres. Reg. 10/2021) — it's not on any restricted, closed, SME-reserved, or partnership-required schedule. That's the BUPM verdict only, not a complete sector-readiness check: sector regulators almost always add requirements on top (PSE/Kominfo for digital platforms, BPOM for food and cosmetics, OJK for financial, Kemenkes for healthcare, Permendag for retail, ESDM for energy). BKPM's default capital floor is IDR 2.5 billion paid-up with IDR 10 billion+ total investment commitment per KBLI, but sector regulators frequently set higher minimums for specific activities. The practical answer depends on your business model — confirm with our team before committing capital.
§ 02
How we handle your KBLI 28191 setup
Emerhub is a corporate-services provider in Indonesia. We do the legal and regulatory legwork for foreign investors so you can focus on the business itself. Here's what the engagement looks like.
- 1
Confirm the optimal structure for your business
2–3 business daysWe confirm KBLI 28191 is the right primary code for your business, advise on secondary codes you may also need, and finalize the holding structure with you before any filing.
What we need from you- Founders' passport copies and proof of residence
- Intended share split and board composition
- 2
Incorporate your PT PMA
7–10 business daysWe draft the Articles of Association before a notary, register the entity with the Ministry of Law & Human Rights (Kemenkumham), and obtain the company's tax ID (NPWP). Under BKPM Reg. 5/2025, paid-up capital is IDR 2.5 billion (~USD 160K) — the cash actually deposited at incorporation. The IDR 10 billion+ figure many sources still cite is the total investment commitment per KBLI, realised over time via your LKPM reports.
Get an exact quote and timeline for KBLI 28191, scoped to your specific business plan.
Request a quote§ 05
Licensing requirements in detail
Specific permits, application requirements and ongoing obligations vary by business scale and the sub-activity within this KBLI. We file these on your behalf — this section is for transparency on what we'll be handling. Switch between scales below; by default we show Large (the PMA scale).
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
7Compliance and reporting duties throughout operation
- 01Have proof of submission of mandatory validated Industrial Data every 6 (six) months in accordance with the laws and regulations in the industrial sector.
- 02Ensure the safety and security of equipment, processes, production results, storage, and transportation, in accordance with applicable laws and regulations.
- 03Have: a. A user manual for the produced goods (including maintenance and troubleshooting handling) b. A card/letter/electronic code for the warranty of malfunctioning produced goods that proves the minimum service commitment to customers.
- 04Possess periodic calibration documents for quality control equipment or periodic results from independent laboratory tests on the produced products.
- 05Have a document for the SOP of the periodic calibration process for quality control equipment.
- 06Have a document in the form of a disaster evacuation SOP, including the arrangement of workplace safety signs.
- 07Possess a Quality Management System certificate (ISO 9001).
Issuing authority
The authority that issues the license depends on your situation.
| Authority | Applies when |
|---|---|
| Minister/Head of Agency | The industrial location is situated within a cross-border area between provinces. |
| Minister/Head of Agency | Foreign Investment |
| Governor | The industrial location is in the relevant province. |
Speak to Emerhub
Get your KBLI 28191 setup handled end-to-end.
Emerhub is a corporate-services provider in Indonesia. We handle PT PMA incorporation, licensing, tax registration and monthly compliance — so you focus on operating the business.