51109Air Transportation for Other Passengers
Other Passenger Air Transport
This group includes air transport businesses for passengers that are not classified elsewhere. It also includes air transport rental businesses with their operators.
Key facts for KBLI 51109
The essentials a foreign investor needs to know before reading the rest of this page.
Foreign capital capped at 49% — requires 51% Indonesian partner for any PT PMA registered under this KBLI. The Indonesian portion can be held by individuals or by an Indonesian-owned entity.
- Risk level
- —No data at Large scale
- Primary license
- NIBBusiness Identification Number
- Setup timeline
- InstantNIB issued immediately on application
- Issuing authority
- OSS / BKPMOnline Single Submission portal
- Min. paid-up capital
- N/A for PMAPMA cannot register under this code
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.
Foreign capital allowed up to 49%
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.
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).
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.
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) carve-outs
Several restricted codes — notably healthcare, education, and certain manufacturing — have higher or full PMA caps inside designated KEK zones (e.g. Sanur Health KEK, Lido KEK). We assess whether your operation can benefit and walk you through the KEK admission process.
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.
These KBLIs sit in the same subgroup and are open to PT PMA. They may achieve a similar business goal through a different value-chain step.
- 51101Scheduled Domestic Air Transport for Passengers or Passengers and Cargo
- 51102Domestic Non-Scheduled Air Transport for Passengers or Passengers and Cargo
- 51103Scheduled Foreign Air Transport for Passengers or Passengers and Cargo
- 51104Non-Scheduled International Air Transport for Passengers or Passengers and Cargo
- 51105Other Non-Scheduled Air Transport
- 51106Air Transportation for Sports
What is KBLI 51109?
A plain-English explanation of this classification and the businesses it covers.
KBLI 51109 (Other Passenger Air Transport) is the 5-digit Indonesian Standard Industrial Classification code for air transportation for other passengers. It sits within Transportation and Warehousing under the subgroup Air Passenger Transport in the official KBLI 2020 taxonomy maintained by Statistics Indonesia (BPS).
Who needs KBLI 51109?
Any Indonesian or foreign-owned entity that intends to operate in air transportation for other passengers 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.
Transportation & Warehousing-specific guidance
Sector context that applies to KBLI 51109 beyond the generic OSS process. Verify with the relevant ministry before committing capital.
- ·Cabotage rules: domestic shipping reserved for Indonesian-flagged vessels.
- ·Aviation operations require Air Operator Certificate (AOC) and aircraft registration.
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.
Reorganised in KBLI 2025
KBLI 51109 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.
- ·For current operations, KBLI 51109 remains valid — OSS still uses KBLI 2020 for all business registrations.
- ·The KBLI 2025 successor codes are listed in the official BPS transition document below; check for the activity-specific mapping when planning future structures.
- ·Once OSS announces the KBLI 2025 cutover, existing entities will need to update their primary KBLI to the relevant successor — typically straightforward.
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 specialist