Non-Scheduled International 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 within the territory of the Republic of Indonesia to another airport outside the territory or vice versa on routes and flight schedules that are irregular and not fixed, with fares that are agreed upon between the service provider and the users of air transportation and are not published.
Operating license routes through Ministry of Transportation, not OSS — Emerhub handles the application end-to-end.
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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 51104 is not on Indonesia's closed, conditional, SME-reserved or partnership-required schedules. A foreign investor may incorporate a PT PMA with up to 100% foreign ownership and operate in this activity directly.
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.
We confirm KBLI 51104 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.
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 51104 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.
A plain-English explanation of this classification and the businesses it covers.
KBLI 51104 (Non-Scheduled International Commercial Air Transport for Passengers or Passengers and Cargo) is the 5-digit Indonesian Standard Industrial Classification code for non-scheduled international 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 non-scheduled international 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 51104 does not carry the same number forward into KBLI 2025 — the activity has been reclassified, but the precise mapping isn't recorded in our database yet.
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 51104 (Non-Scheduled International Commercial Air Transport for Passengers or Passengers and Cargo) is the 5-digit Indonesian Standard Industrial Classification code for non-scheduled international 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).
Yes — KBLI 51104 is fully open to foreign investment. A PT PMA may operate with up to 100% foreign ownership, subject to BKPM Reg. 5/2025 capital requirements (IDR 2.5 billion paid-up + IDR 10 billion+ commitment per KBLI).
KBLI 51104'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 51104 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). 2 sector-specific PB UMKU permits also apply depending on the exact activity. See the requirements summary at the top of the page.
BKPM Reg. 5/2025 default applies: IDR 2.5 billion paid-up capital at incorporation + IDR 10 billion+ total investment commitment per KBLI registered, realized over time and reported quarterly via LKPM.
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 51104 specifically takes 7 days at the Large business scale.
Not on the Tax Holiday or Tax Allowance priority lists. KBLI 51104 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). Specific mapping is in §1 of this page.
Beyond the NIB, KBLI 51104 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.
KBLIs in the same subgroup 5110: 51101 (Scheduled Domestic Air Transport for Passengers or Passengers and Cargo); 51102 (Domestic Non-Scheduled Air Transport for Passengers or Passengers and Cargo); 51103 (Scheduled Foreign 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.