Foreign Investor FeasibilityKBLI 52109
§ 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 · open
Open under BUPM (subject to sector rules)
KBLI 52109 is not on Indonesia's closed, conditional, SME-reserved, or partnership-required schedules under BUPM (Pres. Reg. 10/2021). A foreign investor can incorporate a PT PMA under this code, but sector regulators (PSE/Kominfo, BPOM, OJK, Kemenkes, Permendag, ESDM) almost always add licensing and capital requirements on top — the practical answer depends on your specific business model.
This KBLI is open under BUPM (Pres. Reg. 10/2021) — it's not on any restricted, closed, SME-reserved, or partnership-required schedule. That's the BUPM verdict only, not a complete sector-readiness check: sector regulators almost always add requirements on top (PSE/Kominfo for digital platforms, BPOM for food and cosmetics, OJK for financial, Kemenkes for healthcare, Permendag for retail, ESDM for energy). BKPM's default capital floor is IDR 2.5 billion paid-up with IDR 10 billion+ total investment commitment per KBLI, but sector regulators frequently set higher minimums for specific activities. The practical answer depends on your business model — confirm with our team before committing capital.
§ 02
Activities included under KBLI 52109
Sub-activities recorded under this KBLI in the OSS regulatory database. The classification covers any business operating in one or more of these areas.
Sub-activities under KBLI 52109
From the official OSS scope definition for this KBLI class. Each item is a distinct sub-activity that falls under this code.
- 01Container depot
- 02Other warehousing not included in KBLI 52101 to 52108
§ 03
How we handle your KBLI 52109 setup
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.
- 1
Confirm the optimal structure for your business
2–3 business daysWe confirm KBLI 52109 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.
What we need from you- Founders' passport copies and proof of residence
- Intended share split and board composition
- 2
Incorporate your PT PMA
7–10 business daysWe 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.
Get an exact quote and timeline for KBLI 52109, scoped to your specific business plan.
Request a quote§ 06
Licensing requirements in detail
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).
Sub-activity scopes · 2
Sub-activity scope
Container depot
What's required to operate
NIB
Preparation only — additional permit needed below
Standard Certificate (Verified)
Important: 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.
Processing time
3Days
Statutory turnaround
Application requirements
12Documents and capabilities you must demonstrate at registration
- 01Have proof of ownership or lease of the business premises for a minimum of 2 (two) years, office equipment, internet facilities and infrastructure, as well as safety equipment.
- 02- Have at least 1 (one) expert who is an Indonesian citizen with a qualification of Nautical Expert Level III, or - 2 (two) experts in shipping management or maritime transportation with a Diploma III degree, or - 2 (two) experts with equivalent qualifications and a minimum of 5 (five) years of work experience in managing Container Depots and surveyors of containers who possess competency certificates and/or training.
- 03Have 1 (one) operational staff with a minimum of 1 (one) year of experience in the shipping field and possess competencies and/or skills in the container depot sector, evidenced by a certificate.
- 04Have a quality management system issued by a national or international certification body or have a business management system that has received approval from the Director General of Sea Transportation or the Governor according to the authority for issuing business licenses.
- 05Approval of environmental studies from the district/village and provincial government agencies for DKI Jakarta, including traffic studies.
- 06In the case of the container depot plan in the domestic area, it must be accompanied by a recommendation from the local port authority.
- 07In the case of a container depot plan outside the port's DLKr, it must be accompanied by a recommendation from the government agency responsible for transportation affairs at the local provincial government.
- 08Control land for at least 3 (three) years or own land for the business location with an area of at least 5000m², evidenced by land rights or ownership for a container depot business located outside the port area, issued by the National Defense Agency, and control land in accordance with cooperation with the Port Business Entity or operator for a container depot business located within the port area.
- 09Have or control stacking land used with construction capability to support loads as follows: a. Minimum of 4 (four) tiers of empty containers with a size of 20 (twenty) feet b. Minimum of 2 (two) tiers of empty containers with a size of 20 (twenty) feet
- 10The construction of a depot area can use: Paving Asphalt Concrete
- 11Have equipment including: a. 1 (one) unit reach stacker b. 1 (one) unit top loader c. 1 (one) unit side loader d. 1 (one) unit forklift and/or e. Repair and maintenance facilities for containers that meet the requirements. The type, quantity, and capacity of the equipment should be adjusted to the activities of the container depot business.
- 12If expanding the business/opening an operational branch, it must be accompanied by: a. the appointment of a person in charge at each business location; b. a recommendation from the local port authority.
Ongoing obligations
7Compliance and reporting duties throughout operation
- 01Carry out operational activities continuously in accordance with the standards of container depot businesses.
- 02Submit a report on the planned implementation of container depot activities to the local port authority and the governor if within the regional area or to the governor if outside the regional area.
- 03Submit a container depot activity report every 6 (six) months to the governor and the local port authority.
- 04Implement the provisions established in the container depot business standards.
- 05Update business licensing data every 2 (two) years.
- 06Update the quality management system in accordance with the regulations or business management system every 2 (two) years.
- 07Comply with the provisions of legislation in the field of shipping and other relevant regulations.
Issuing authority
The authority that issues the license depends on your situation.
| Authority | Applies when |
|---|---|
| Minister/Head of Agency | Foreign Investment |
| Governor | Province. |
§ 05
Auxiliary permits (PB UMKU)
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 1 candidate permit across 1 regulator; most operations only need a handful. Emerhub maps your operation to the exact set, files them, and tracks renewals.
Defence & Security
1 permitMinistry of Defence. Applies when the operation produces, stores, or distributes weapons, ammunition, military vehicles, or explosives. The Ministry of Defence vets and re-vets the operator across the lifecycle.
Speak to Emerhub
Get your KBLI 52109 setup handled end-to-end.
Emerhub is a corporate-services provider in Indonesia. We handle PT PMA incorporation, licensing, tax registration and monthly compliance — so you focus on operating the business.