46333Wholesale Trade of Alcoholic Beverages
Perdagangan Besar Minuman Beralkohol
This group includes large-scale trade in alcoholic beverages, such as spirits, wine, malt, beer, and others.
Key facts for KBLI 46333
The essentials a foreign investor needs to know before reading the rest of this page.
100% foreign ownership permitted at class level — with sub-activity carve-outs KBLI 46333 is open to PT PMA, but Pres. Reg. 10/2021 carves out 1 specific sub-activity that is restricted, capped, or reserved for Indonesian capital. For example, "Wholesale trade of alcoholic beverages (importers, distributors, and sub-distrib" is restricted. Scope your business plan to the open portion before incorporation.
Default minimum paid-up capital: IDR 2.5 billion (~USD 160K) under BKPM Reg. 5/2025 (effective Oct 2025) — applies unless a sector regulator sets a higher figure for this activity. The often-cited IDR 10 billion is the total investment commitment per KBLI realised over time via quarterly LKPM reports, not required upfront.
High-risk activity — requires NIB + full Operating License (Izin) to operate commercially. NIB alone enables only the preparation stage; an Operating License must be obtained before invoicing or production starts.
Statutory licensing turnaround: 5 days once we submit the application — on top of the 2–3 weeks for PT PMA incorporation. We coordinate the full sequence end-to-end.
Issuing authority for PMA: Menteri/Kepala Badan — specific to foreign-owned entities under this KBLI.
Ongoing reporting: quarterly LKPM (Investment Activity Report) to BKPM plus 5 sector-specific obligations. We file these on your behalf as part of monthly compliance — you stay out of the OSS portal entirely.
- Risk level
- HighNIB + full Operating License
- Primary license
- NIB + full Operating License (Izin)NIB enables preparation only — additional permit needed to operate
- Setup timeline
- 5 DaysStatutory turnaround at OSS
- Issuing authority
- Minister / Agency HeadFor foreign-owned (PMA) entities
- Min. paid-up capital
- IDR 2.5 BBKPM default paid-up — sector rules may set a higher figure
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.
Open to foreign investment, with carve-outs
KBLI 46333 is open as a class — a 100% foreign-owned PT PMA can be incorporated under this code — but Pres. Reg. 10/2021 carves out 1 specific sub-activity that are off-limits or restricted for foreign capital. The rest of the activity remains open to PMA. The carved-out items are listed below; any of them needs to be either avoided, served via an Indonesian operator, or structured around case-by-case.
Conditional sub-activities
1- Wholesale trade of alcoholic beverages (importers, distributors, and sub-distributors)Restricted and closely monitored, regulated under specific legislation in the field of control and supervision of alcoholic beverages.
How we handle your KBLI 46333 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 46333 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.
What we need from you- Powers of attorney (we prepare; you sign and notarize)
- Director / commissioner appointment letters
- Initial capital deposit confirmation
- 3
We obtain your NIB
1–2 business daysWe file the OSS application with KBLI 46333 as your primary business activity, complete the risk-based assessment, and collect the NIB (Business Identification Number) for you — typically within hours of submission. You don't need to touch the OSS portal.
What we need from you- Office address (virtual office acceptable for many KBLIs; we can arrange one)
- 4
Secure your full Operating License (Izin)
5+ business daysNIB is issued for the preparation stage. Commercial operation requires a full Operating License (Izin) issued by the competent ministry after a substantive review of the operator's capability, facility, and compliance. Operating with NIB alone exposes the entity to penalties, blacklisting, and contract invalidation. We prepare the application bundle, liaise with the competent ministry, and chase issuance through to the certificate. Statutory turnaround: 5 business days — real-world timing typically runs longer when site inspections or additional clarifications are requested.
What we need from you- Technical documentation specific to your operation
- Appointment of a Penanggung Jawab Teknis (PJT — technical responsible person)
- 5
Hand-off to ongoing compliance
OngoingPost-launch we run your monthly tax filings, quarterly LKPM (Investment Activity Reports), annual general meeting (RUPS), and any sector-specific reporting. You get a single point of contact and a monthly compliance digest — no Indonesian-language paperwork on your desk.
What is KBLI 46333?
A plain-English explanation of this classification and the businesses it covers.
KBLI 46333 (Perdagangan Besar Minuman Beralkohol) is the 5-digit Indonesian Standard Industrial Classification code for wholesale trade of alcoholic beverages. It sits within Wholesale and Retail Trade; Repair and Maintenance of Cars and Motorcycles under the subgroup Wholesale Trade of Other Food and Beverages and Tobacco in the official KBLI 2020 taxonomy maintained by Statistics Indonesia (BPS).
Who needs KBLI 46333?
Any Indonesian or foreign-owned entity that intends to operate in wholesale trade of alcoholic beverages 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.
Wholesale trade-specific guidance
Sector context that applies to KBLI 46333 beyond the generic OSS process. Verify with the relevant ministry before committing capital.
- ·Wholesale activities open to 100% PMA; importer registration (API-U for general or API-P for own-use) is needed for cross-border trade.
- ·Distribution agreements with overseas principals must be registered with Kemendag.
- ·Specific products (alcohol, pharmaceuticals, hazardous chemicals) carry additional licensing.
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.
Carried forward into KBLI 2025
KBLI 46333 retains the same code number and scope in the new taxonomy. The activity description, hierarchy, and intended use of the code are preserved.
- ·Continue using 46333 for current registrations under KBLI 2020.
- ·When OSS adopts KBLI 2025 (timing not yet announced), no migration is required for this code.
- ·Risk level, permits, and authority routing shown above remain in effect under both taxonomies.
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 specialistRisk level by business scale
Indonesia's OSS Risk-Based Approach assigns a separate risk level for each of the four business scales. The licensing instruments required (NIB, Standard Certificate, Operating License) are determined by the risk level. Foreign-owned entities (PT PMA) must register at the Large scale, so the rightmost column applies to most foreign investors.
Micro
Small
Medium
Large
PMA scaleWhat does each risk level require to operate? ›
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).
Sub Distributor Minuman Beralkohol
Application requirements
4Documents and capabilities you must demonstrate at registration
- 01Badan Usaha berbentuk CV, Firma, Koperasi atau Perseroan Terbatas (PT), kecuali PT Perorangan
- 02Letter of Appointment of Sub Distributor from Registered Alcoholic Beverage Distributor
- 03Warehouse Registration Certificate for each Warehouse controlled.
- 04Field Research Report from the District/City or Provincial Office for the Special Region of Jakarta according to the address of the company's headquarters for Alcoholic Beverages Group B and/or C.
Ongoing obligations
6Compliance and reporting duties throughout operation
- 01Implementing K3L standards
- 02Distributing alcoholic beverages only to retailers or direct sellers designated according to their marketing area.
- 03The sale of alcoholic beverages for immediate consumption may only be sold in hotels, bars, restaurants, and other places designated by the local government.
- 04The retail sale of alcoholic beverages can only be sold in supermarkets, hypermarkets, TBB, and other specific places designated by the local government.
- 05Submit a change to the SKMB if there is a change in data or information on the SKMB.
- 06Submit reports to the Ministry of Trade every quarter regarding: a. Appointment of Retailers and/or Direct Sellers b. Procurement and realization of the circulation of Alcoholic Beverages
Issuing authority
The authority that issues the license depends on your situation. Foreign investors typically fall under Minister/Head of Agency · PMA.
| Authority | Applies when |
|---|---|
| Menteri/Kepala Badan | Seluruh |
| Menteri/Kepala Badan | PMA |
Basic requirements (KKPR)
Class-level prerequisites that apply to every operator under this KBLI, independent of business scale. These commonly include minimum capital rules for PMA entities and spatial-planning (KKPR) conformance.
- 01All Business Fields within the Scope of Activities of the KBLI are limited and closely monitored and regulated in separate laws and regulations in the field of control and supervision of alcoholic beverages, as regulated in Presidential Regulation No. 49 of 2021 concerning Amendments to Presidential Regulation No. 10 of 2021 concerning the Investment Business Sector.
- 02
Scope of Activities Distributor of Alcoholic Beverages Class A, Class B, and Class C, based on Government Regulation Number 5 of 2021 concerning Implementation of Risk-Based Business Licensing in Attachment II to the Trading Sector, it is required:
- A legal entity in the form of a Limited Liability Company (PT); and
- Letter of appointment as Distributor of Alcoholic Beverages.
- 03
Scope of Activities Sub-Distributor of Alcoholic Beverages Class A, Class B, and Class C, based on Government Regulation Number 5 of 2021 concerning Implementation of Risk-Based Business Licensing in Attachment II to the Trading Sector, it is required:
- Legal entity in the form of a Limited Liability Company (PT);
- Letter of appointment as Sub Distributor from Distributor of Alcoholic Beverages.
Auxiliary permits (PB UMKU)
This KBLI commonly carries 14 additional permits attached to specific operational activities. PB UMKU permits are issued separately from the main business license — apply only for the ones relevant to your operation.
- Approval for the Implementation of Processed Food Clinical Trials.approval-for-the-implementation-of-processed-food-
- Compliance Certificate for Standard Processed Food Safety Management System in Distribution Facilitiescompliance-certificate-for-standard-processed-food
- Compulsory SNI (National Standardization Indonesia) Major Variation Approval Certificate for Processed Foodcompulsory-sni-national-standardization-indonesi-2
- Compulsory SNI (National Standardization Indonesia) Approval Certificate for Processed Foodcompulsory-sni-national-standardization-indonesia-
- Major Processed Food Variation Licensemajor-processed-food-variation-license
- Permit for the Assessment of Safety, Quality, Nutrition, Benefits, and Labeling of Processed Foodpermit-for-the-assessment-of-safety-quality-nutrit
