Foreign Investor FeasibilityKBLI 43303
§ 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 · sme reserved
Reserved for cooperatives & micro/small enterprises
KBLI 43303 is allocated to cooperatives and Indonesian micro, small and medium enterprises (UMKM) under the BUPM allocation list. Foreign investment via PT PMA is not permitted for the listed sub-activities below.
Listed restrictions
Reserved for SMEs / cooperatives
1- Activities that use simple and medium technology: PaintingAllocated for Cooperatives and UMKM.Sector: Public Works and Housing
§ 02
Construction-specific guidance
Sector context that applies to KBLI 43303 beyond the generic OSS process. Verify with the relevant ministry before committing capital.
Lead regulator
Ministry of Public Works (PUPR) / LPJK
- ·Sertifikat Badan Usaha (SBU) classification required from LPJK.
- ·PBG (Building Approval) issued per project by local government.
§ 03
Activities included under KBLI 43303
Sub-activities recorded under this KBLI in the OSS regulatory database. The classification covers any business operating in one or more of these areas.
Sub-activities under KBLI 43303
From the official OSS scope definition for this KBLI class. Each item is a distinct sub-activity that falls under this code.
- 01Subclassification Code for Painting: PB007
- 02Subclassification Code for Painting: PB008
§ 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.
This activity is allocated to Indonesian SMEs and cooperatives.
PT PMA is not permitted for this KBLI. The activity is reserved for cooperatives and Indonesian micro/small/medium enterprises (UMKM). The pathway for foreign investors is to operate a different value-chain step (e.g. processing or distribution rather than the reserved primary activity), or to support local SMEs as an off-taker / brand owner / financier.
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.
SME partnership / off-take model
You can't hold the SME licence yourself, but you can build a contractual ecosystem with cooperatives or UMKM partners — supplying them with capital, IP, brand, distribution, or technology. We structure these arrangements so they stay defensible and commercially aligned.
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§ 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 scopes · 2
Sub-activity scope
Subclassification Code for Painting: PB007
What's required to operate
NIB
Preparation only — additional permit needed below
Standard Certificate (Verified)
Important: NIB is issued for the preparation stage. To begin commercial operations, the operator must obtain a Sertifikat Standar that has been verified by the competent ministry. The verification step typically requires a site or document inspection. Operating with NIB alone is not legally compliant.
Processing time
15Days
Statutory turnaround
Application requirements
3Documents and capabilities you must demonstrate at registration
- 01Standard Number for Determining the Competence of Construction Service Business Entities (SBU PB-UMKU Number)
- 02For the Representative Office of a Foreign Construction Company: a. It must be a legal entity engaged in construction services in the country of origin. b. Pay the administrative licensing fees per type of business in accordance with applicable regulations.
- 03For PMA Construction Companies: a. Foreign investors/shareholders must be a legal entity in the construction services sector in their home country, evidenced by: 1) A legalized deed of establishment 2) A licensed construction services business certificate of large qualification in the home country or a similar document that is legalized b. Domestic investors/domestic shareholders must be a national construction services entity of large qualification, evidenced by: 1) Business license for the construction services sub-sector 2) Business entity certificate for the construction services sub-sector
Ongoing obligations
4Compliance and reporting duties throughout operation
- 01Submit the Annual Business Activity Report.
- 02The SBU is still valid.
- 03Implement the provisions of the legislation in the field of construction services.
- 04For the Representative Office of BUJKA: a. Extend the Standard Certificate according to the sub-classification every 3 years. b. Establish a Joint Operation (KSO) with a large qualified BUJKN that has a similar classification/sub-classification registered with the construction service development agency before participating in the selection process. c. KSO for the implementation of Construction Work or Integrated Construction Work shall be carried out under the following technical criteria: 1) At least 50% (fifty percent) of the construction work cost must be executed domestically. 2) At least 30% (thirty percent) of the construction implementation cost must be executed by the KSO partner BUJKN.
Issuing authority
The authority that issues the license depends on your situation.
| Authority | Applies when |
|---|---|
| Minister/Head of Agency | Construction Services Business Entities (BUJK) and Representative Offices of Construction Services Business Entities (BUJKA) |
| Minister/Head of Agency | Foreign Investment |
Speak to Emerhub
KBLI 43303 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.