KBLI 51102 caps foreign ownership at 49% under Pres. Reg. 10/2021. The remaining 51% must be held by Indonesian nationals or Indonesian-owned entities. PT PMA can incorporate as a JV with the right cap-table structure.
OSS RBA classifies KBLI 51102 as Medium-High — NIB + Verified Standard Certificate at Large scale. 2 PB UMKU sector-specific permits apply depending on the exact activity. Licensing instruments follow the standard ladder; no sector-regulator override is on file for this code.
OSS lists 8 operational obligations at Large scale for this code. None are structural foreign-investor barriers, but they determine ongoing compliance: Conduct air transportation activities within a maximum of 12 (twelve) months…, Possess at least 1 (one) aircraft unit and other aircraft in the form of…, and others.
Worth confirming: BUPM imposes specific conditions for this activity, AND sector regulators (PSE, BPOM, OJK, Kemenkes, Permendag, ESDM) frequently add licensing and capital requirements on top. The practical structure depends on which sub-activities you actually plan to operate. Talk to our team
Non-Scheduled Domestic Commercial Air Transport for Passengers or Passengers and Cargo
Last updated · Sourced from OSS Indonesia
This group includes the transportation of passengers or passengers and cargo by aircraft from one airport to another within the territory of the Unitary State of the Republic of Indonesia on irregular and non-scheduled flight routes, with fares that are agreed upon between the service provider and the users of air transportation and are not published.
Ministry of Transportation reviews every operator — Emerhub handles the application.
Cabotage rules: domestic shipping reserved for Indonesian-flagged vessels.
Aviation operations require Air Operator Certificate (AOC) and aircraft registration.
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.
KBLI 51102 permits foreign equity participation, but the maximum foreign shareholding is capped at 49%. The remaining shares must be held by Indonesian nationals or Indonesian-owned entities. Specific conditions for each sub-activity are listed below.
Current status, what each regulation actually requires for this activity, and how it ties to the PB UMKU sector permits below. Click through for the plain-English summary.
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.
KBLI 51102 caps foreign equity at 49%. We design a shareholding split that respects this cap while preserving your operational control — typically through a combination of voting/non-voting shares and a binding shareholders' agreement.
We 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.
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).
Documents and capabilities you must demonstrate at registration
Compliance and reporting duties throughout operation
The authority that issues the license depends on your situation.
| Authority | Applies when |
|---|---|
| Minister/Head of Agency | The operational scope is national and/or international. |
| Minister/Head of Agency | Foreign Investment |
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 2 candidate permits across 1 regulator; most operations only need a handful. Emerhub maps your operation to the exact set, files them, and tracks renewals.
Ministry of Transportation. Applies to commercial passenger or freight transport — road, sea, air, rail, freight forwarding, port and airport operations. Each vehicle, route, or terminal often needs its own standard certificate; expansion triggers re-certification.

We file the OSS application with KBLI 51102 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.
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. We prepare the application bundle, liaise with the competent ministry, and chase issuance through to the certificate. Statutory turnaround: 7 business days — real-world timing typically runs longer when site inspections or additional clarifications are requested.
Post-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.
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.
All Business Fields within the Scope of KBLI"s Activities are open to a maximum of 49% foreign capital and national capital owners must remain larger than all foreign investors (single majority), as stipulated in the Regulation President No. 49 of 2021 concerning Amendments to Presidential Regulation No. 10 of 2021 concerning the Investment Business Sector.
A plain-English explanation of this classification and the businesses it covers.
KBLI 51102 (Non-Scheduled Domestic Commercial Air Transport for Passengers or Passengers and Cargo) is the 5-digit Indonesian Standard Industrial Classification code for domestic non-scheduled air transport for passengers or passengers and cargo. It sits within Transportation and Warehousing under the subgroup Air Passenger Transport (major group 51) in the official KBLI 2020 taxonomy maintained by Statistics Indonesia (BPS).
Any Indonesian or foreign-owned entity that intends to operate in domestic non-scheduled air transport for passengers or passengers and cargo 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.
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.
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.
KBLI 51102 retains the same code number and scope in the new taxonomy. The activity description, hierarchy, and intended use of the code are preserved.
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 specialistIndonesia'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.
KBLI 51102 (Non-Scheduled Domestic Commercial Air Transport for Passengers or Passengers and Cargo) is the 5-digit Indonesian Standard Industrial Classification code for domestic non-scheduled air transport for passengers or passengers and cargo. It sits within the Transportation and Warehousing category in the official KBLI 2020 taxonomy maintained by Badan Pusat Statistik (BPS).
Foreign ownership is capped at 49% under Pres. Reg. 10/2021. The remaining 51% must be held by Indonesian nationals or Indonesian-owned entities. Sector regulators may add licensing or capital requirements on top depending on the specific activity — our team structures the JV and confirms the licensing stack.
KBLI 51102's risk levels per business scale: Micro Medium-High, Small Medium-High, Medium Medium-High, Large Medium-High. Foreign-owned entities (PT PMA) must register at the Large scale.
NIB + verified Standard Certificate (Sertifikat Standar Terverifikasi). KBLI 51102 is Medium-High risk at Large scale, so NIB is issued first, but the Standard Certificate becomes effective only after the issuing ministry verifies compliance (typically through a document review or site audit). To obtain the licensing instrument, OSS lists 5 application requirements (persyaratan). The first few: A business plan document for a minimum period of 5 years ahead must at least include:; Type and number of aircraft to be operated (characteristics and specifications of the aircraft, acquisition…; Plan for the central aviation operation base and plan for the regional aviation operation, and 2 more — see the full list with supporting documents in the Licensing detail section. 2 sector-specific PB UMKU permits also apply depending on the exact activity. See the requirements summary at the top of the page. Plus one basic requirement (KKPR) at the class level.
BKPM Reg. 5/2025's default floor is IDR 2.5 billion paid-up capital at incorporation + IDR 10 billion+ total investment commitment per KBLI registered (realised over time and reported quarterly via LKPM). Sector regulators (OJK for financial, ESDM for energy, Kemenkes for healthcare, BPOM for food and cosmetics, Permendag for retail, Kominfo for digital platforms) often set higher minimums for specific activities. The binding figure depends on what you actually plan to operate, so confirm with our team before committing capital. See the investment status block for the BUPM verdict and ownership context.
PT PMA setup typically takes 4-8 weeks: AHU registration (1-2 weeks), NIB issuance via OSS (immediate to 1 week), bank account opening (2-4 weeks). The licensing cycle for KBLI 51102 specifically takes 7 days at the Large business scale.
Not on the Tax Holiday or Tax Allowance priority lists. KBLI 51102 businesses pay the standard 22% PPh Badan; Super Tax Deduction (300% R&D / 200% vocational training) may still apply for qualifying expenses.
Authority depends on the investor profile. For PMA: Minister/Head of Agency. For domestic SME scale: typically Governor (for Provincial scope) or Regent/Mayor (Regency/City scope). See the licensing detail section for the full per-permit authority routing.
Beyond the NIB, KBLI 51102 carries 2 PB UMKU permits across 1 sector regulator: Transportation (2). Most operations only need 2-4 of these. The relevant set depends on which specific activities you actually perform; Emerhub maps the right subset before filing. See the full PB UMKU list for per-permit detail and regulator routing.
KBLIs in the same subgroup 5110: 51101 (Scheduled Domestic Air Transport for Passengers or Passengers and Cargo); 51103 (Scheduled Foreign Air Transport for Passengers or Passengers and Cargo); 51104 (Non-Scheduled International Air Transport for Passengers or Passengers and Cargo); 51105 (Other Non-Scheduled Air Transport); 51106 (Air Transportation for Sports). These are closely related activities — see the related-codes section below for full list.