Foreign Investor FeasibilityKBLI 64121
§ 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 64121 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.
Sector capital requirement
Higher minimum capital required by OJK
Sharia commercial banks
Required paid-up
IDR 1 trillion
Regulation
POJK 11/2023 (Bank Umum Syariah)
BKPM Reg. 5/2025's default is IDR 2.5 billion paid-up + IDR 10 billion commitment per KBLI. The figure above is the binding override for this activity — the higher number wins.
Investment momentum
Financial services 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 11.2t≈ USD 0.70b
+7.8% YoY
Top investing countries
Singapore32%
Japan22%
Malaysia16%
Reported separately from financial services figures in the headline BKPM realisation total. OJK approval is the binding gate. Multi-finance (consumer + commercial) attracted more inbound FDI than banking in 2025.
§ 02
Activities included under KBLI 64121
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 64121
From the official OSS scope definition for this KBLI class. Each item is a distinct sub-activity that falls under this code.
- 01Margin Deposit Bank/Customer Fund Bank, Compensation Fund Deposit Bank, Central Time Deposit Custodian Bank, and Guarantee Fund Deposit Bank.
- 02Conventional banking activities, excluding Margin Depository Banks, Compensation Fund Depository Banks, Central Time Deposit Custody Banks, and Guarantee Fund Depository Banks.
§ 03
How we handle your KBLI 64121 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 64121 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 64121, 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
Margin Deposit Bank/Customer Fund Bank, Compensation Fund Deposit Bank, Central Time Deposit Custodian Bank, and Guarantee Fund Deposit Bank.
What's required to operate
NIB
Preparation only — additional permit needed below
Operating License (Izin)
Important: NIB is issued for the preparation stage. Commercial operation requires a full Operating License (Izin) issued by the competent ministry after a substantive review of the operator's capability, facility, and compliance. Operating with NIB alone exposes the entity to penalties, blacklisting, and contract invalidation.
Processing time
3Days
Statutory turnaround
Application requirements
11Documents and capabilities you must demonstrate at registration
- 01Letter of Application for Approval as a Margin/Compensation Fund/Guarantee Fund Bank;
- 02Form Number VII.BP.2 (Appendix to the Regulation of the Head of Bappebti Number 17 of 2000);
- 03The Articles of Association of the Bank and its amendments have been approved by the Minister of Law and Human Rights;
- 04Copy of the Company's Tax Identification Number (NPWP);
- 05Copy of the Business License for a General Bank classified as a Foreign Exchange Bank.
- 06Audited financial statements for the last 3 years from a registered public accounting firm;
- 07Operational guideline book on fund storage activities in separate accounts conducted by banks according to user needs (segregated account and unsegregated account);
- 08Recommendation Letter from Bank Indonesia;
- 09Manual for the internet banking system owned (including in USD);
- 10Cooperation with the Futures Clearing Institution;
- 11Statement of readiness for connectivity with the MT940 e-reporting system of Bappebti (for supervision purposes).
Ongoing obligations
1Compliance and reporting duties throughout operation
- 01
Issuing authority
The authority that issues the license depends on your situation.
| Authority | Applies when |
|---|---|
| Minister/Head of Agency | All |
| Minister/Head of Agency | Foreign Investment |
Speak to Emerhub
Get your KBLI 64121 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.