Foreign Investor FeasibilityKBLI 55120
§ 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 · sme reserved
Reserved for cooperatives & micro/small enterprises
KBLI 55120 is allocated to cooperatives and Indonesian micro, small and medium enterprises (UMKM) under the BUPM allocation list. Foreign investment via PT PMA is not permitted for the listed sub-activities below.
Listed restrictions
Reserved for SMEs / cooperatives
1- Accommodation Services: Budget HotelAllocated for Cooperatives and UMKM.Sector: Tourism
Investment momentum
Hotels & accommodation sector — Q3 2025
BKPM-reported foreign investment context for the broader sector this KBLI sits in. Data is aggregated at the major-sector level — BKPM does not publish per-5-digit-KBLI breakdowns publicly.
PMA realized
IDR 6.3t≈ USD 0.39b
+24.8% YoY
Top investing countries
Singapore26%
Hong Kong17%
Japan14%
Bali, Lombok and KEK Mandalika lead. Post-pandemic recovery continued through 2025; international hotel brands (Marriott, Accor, IHG) expanded mid-market and resort footprints. Tourism KEK incentives layer on top of TDUP licensing.
§ 02
Accommodation-specific guidance
Sector context that applies to KBLI 55120 beyond the generic OSS process. Verify with the relevant ministry before committing capital.
Lead regulator
Ministry of Tourism & Creative Economy (Kemenparekraf)
- ·Star-rated hotels are open to PMA up to 100%; non-rated lodging often reserved for SMEs.
- ·Tourism Business License (TDUP) needed in addition to OSS NIB.
- ·KEK Mandalika and KEK Tanjung Lesung offer specific tourism incentives.
§ 03
Activities included under KBLI 55120
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 55120
From the official OSS scope definition for this KBLI class. Each item is a distinct sub-activity that falls under this code.
- 01With a building area > 6,000 m²
- 02With a building area of ≤ 6,000 m²
§ 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.
This activity is allocated to Indonesian SMEs and cooperatives.
PT PMA is not permitted for this KBLI. The activity is reserved for cooperatives and Indonesian micro/small/medium enterprises (UMKM). The pathway for foreign investors is to operate a different value-chain step (e.g. processing or distribution rather than the reserved primary activity), or to support local SMEs as an off-taker / brand owner / financier.
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.
SME partnership / off-take model
You can't hold the SME licence yourself, but you can build a contractual ecosystem with cooperatives or UMKM partners — supplying them with capital, IP, brand, distribution, or technology. We structure these arrangements so they stay defensible and commercially aligned.
PMA-viable codes in adjacent industries
These KBLIs solve a related business problem and are open to foreign ownership. None are a perfect substitute for the activity above — but they often unlock 80% of the commercial outcome. Talk to us about which fits your plan.
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§ 07
Reference data: how this KBLI is regulated
The data below is the official OSS regulatory profile for this code. It applies to qualifying Indonesian operators (or to your operating partner). Foreign investors won't file these directly, but it's useful context when structuring a partnership or commercial arrangement.
Foreign investors:the licensing matrix below is for context only — direct PMA registration isn't possible for this code. See pathways above for what actually works.
Sub-activity scopes · 2
Sub-activity scope
With a building area > 6,000 m²
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
14Days
Statutory turnaround
Application requirements
1Documents and capabilities you must demonstrate at registration
- 01$4a
Ongoing obligations
3Compliance and reporting duties throughout operation
- 01Possess a tourism business standard certificate from LSPr.
- 02Having a Health Feasibility Certificate
- 03In the case of employing foreign workers, it is mandatory to have a document of approval for the Plan for the Use of Foreign Workers (RPTKA).
Issuing authority
The authority that issues the license depends on your situation.
| Authority | Applies when |
|---|---|
| Minister/Head of Agency | Foreign Investment |
| Governor | All |
§ 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 3 candidate permits across 2 regulators; most operations only need a handful. Emerhub maps your operation to the exact set, files them, and tracks renewals.
Trade & Metrology
2 permitsMinistry of Trade. Applies to wholesale and retail commerce, fuel stations, online marketplaces, and warehouses. Distributor / agent registration (STP) is the most common; importers, alcoholic-beverage sellers, and franchisors carry their own permits on top.
- Certificate of Direct Seller of Alcoholic Beverages Category B and C (SKPL-B and SKPL-C)Surat Keterangan Penjual Langsung Minuman Beralkohol Golongan B dan C (SKPL-B dan SKPL-C)8 requirements9 obligations
- Direct Seller Certificate for Alcoholic Beverages Class A (SKPL-A)Surat Keterangan Penjual Langsung Minuman Beralkohol Golongan A (SKPL-A)5 requirements8 obligations
Health & Medical Devices
1 permitMinistry of Health (Kemenkes / BPOM). Applies to manufacturing, importing, distributing, or operating medical devices, hospitals, clinics, diagnostic services, and pharmacies. Most device permits are class-based (Class A/B/C/D); facility permits attach to the specific site.
Speak to Emerhub
KBLI 55120 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.