Foreign Investor FeasibilityKBLI 51109
§ 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 · conditional
Foreign capital allowed up to 49%
49%
max foreign
KBLI 51109 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.
Listed restrictions
Conditional sub-activities
1- Air transportation activities49% max foreignForeign capital is a maximum of 49%, and the national capital owner must remain greater than the total foreign capital owners (single majority).
§ 02
Transportation & Warehousing-specific guidance
Sector context that applies to KBLI 51109 beyond the generic OSS process. Verify with the relevant ministry before committing capital.
Lead regulator
Ministry of Transportation (Kemenhub)
- ·Cabotage rules: domestic shipping reserved for Indonesian-flagged vessels.
- ·Aviation operations require Air Operator Certificate (AOC) and aircraft registration.
§ 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
Speak to Emerhub
KBLI 51109 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.