Foreign Investor FeasibilityKBLI 47828
§ 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 47828 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.
This activity is reserved for small Indonesian operators — think warungs, food stalls, smallholders, individual practitioners. KBLI 47828 only has licensing rules defined for micro and small business sizes. Foreign-owned companies have to register at the Large business size, so this code isn't available to them even though it's not on the "closed" list. Pick a related KBLI that covers larger operations, or ask us about partnering with an Indonesian operator who already holds the licence.
Sector capital requirement
Higher minimum capital required by OSS RBA (standard ladder)
Street vendors and market stalls (small-format retail)
Required paid-up
BKPM Reg. 5/2025 default (IDR 2.5 billion paid-up)
Regulation
BKPM Reg. 5/2025 (default PMA capital) — no sector regulator override
Note. The official KBLI activity description for codes in this subgroup uses small-format terminology — Pedagang Kaki Lima (PKL), street vendor, market stall, or kios. BUPM does not restrict foreign ownership and OSS RBA permits Large-scale registration, so a PT PMA can legally incorporate under any of these codes. The advisory note is a sanity check: if the visitor is planning a formal-store / chain / franchise / modern-retail business, a code in the 4711-4774 formal-store retail family (e.g. KBLI 47190, 47711-47798) may match the business model more accurately. Worth confirming the right code with our team before incorporating. Product-side regulators (BPOM, etc.) still apply per SKU sold regardless of which retail KBLI is chosen.
BKPM Reg. 5/2025's default is IDR 2.5 billion paid-up + IDR 10 billion commitment per KBLI. The figure above is the binding override for this activity — the higher number wins.
Investment momentum
Retail trade sector — Q3 2025
BKPM-reported foreign investment context for the broader sector this KBLI sits in. Data is aggregated at the major-sector level — BKPM does not publish per-5-digit-KBLI breakdowns publicly.
PMA realized
IDR 8.7t≈ USD 0.54b
+11.5% YoY
Top investing countries
Singapore33%
Japan19%
South Korea13%
E-commerce (Tokopedia, Bukalapak, Shopee, Tiktok Shop) and modern-format retail (Ranch Market, Lotte Mart) drive most foreign-owned activity. Traditional and small-format retail remain reserved for Indonesian SMEs.
§ 02
Retail trade-specific guidance
Sector context that applies to KBLI 47828 beyond the generic OSS process. Verify with the relevant ministry before committing capital.
Lead regulator
Ministry of Trade (Kemendag) / local governments
- ·Most modern retail (supermarkets, department stores) is open to PMA above a minimum store-area threshold (typically 1,200 m² for hypermarkets, 400 m² for supermarkets).
- ·Traditional retail and small-scale retail (kaki lima, los pasar) are reserved for SMEs.
- ·Retail of alcoholic beverages is highly restricted and monitored separately.
§ 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§ 06
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 scope
Retail business of various types of fish feed conducted on public roads (street vendors), in front of (shopfront) stores, or in movable or pushable locations (market stalls), such as fish feed, fish feed concentrates, and shellfish flour.
What's required to operate
NIB
NIB is sufficient for both preparation and commercial operation. No additional licensing instrument is issued by OSS at this risk level.
Application requirements
0Documents and capabilities you must demonstrate at registration
No specific application requirements at this scale.
Ongoing obligations
1Compliance and reporting duties throughout operation
- 01Business activity report
Issuing authority
The authority that issues the license depends on your situation.
| Authority | Applies when |
|---|---|
| Regent/Mayor | All |
| Minister/Head of Agency | Foreign Investment |
Speak to Emerhub
KBLI 47828 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.