KBLI 69104 (Aktivitas notaris dan pejabat pembuat akta tanah) is the 5-digit Indonesian Standard Industrial Classification code for notary and land deed officer activities. It sits within the Professional, Scientific and Technical Activities category in the official KBLI 2020 taxonomy maintained by Badan Pusat Statistik (BPS).

Can foreign investors operate under KBLI 69104?

Not in practice. KBLI 69104 is not on Pres. Reg. 10/2021's closed list, but OSS RBA only defines licensing rules at the Micro and Small business scales for this activity — there is no Large-scale matrix. Foreign-owned PT PMA must register at the Large scale, so this code isn't structurally available to foreign investors. PT lokal (100% Indonesian-owned) at the Micro / Small scale can operate freely.

What is the risk level of KBLI 69104?

KBLI 69104 has no Large-scale licensing matrix in OSS — it's structured for Micro and Small business scales only. PT PMA cannot register under this code as a result.

What licenses does KBLI 69104 require?

Not applicable to PT PMA — KBLI 69104 is not viable for foreign-owned entities (closed, SME-reserved, domestic-only, or no Large-scale licensing matrix in OSS RBA, depending on the case). Foreign investors should pick a related KBLI that is open at the Large scale.

What is the minimum capital for a PT PMA under KBLI 69104?

Not applicable to PT PMA — KBLI 69104 is not viable for foreign-owned entities, so neither BKPM Reg. 5/2025's paid-up minimum nor any sector-specific capital floor enters the picture. The structural barrier comes first.

How long does it take to register a business under KBLI 69104?

Not applicable to PT PMA — KBLI 69104 is not viable for foreign-owned entities, so the 4-8 week PT PMA setup timeline doesn't apply. Move to a sibling code with a Large-scale matrix or a different structure.

Is KBLI 69104 eligible for Indonesian tax incentives?

Not on the Tax Holiday or Tax Allowance priority lists. KBLI 69104 businesses pay the standard 22% PPh Badan; Super Tax Deduction (300% R&D / 200% vocational training) may still apply for qualifying expenses.

Which authority issues the KBLI 69104 license?

Not applicable to PT PMA — KBLI 69104 is not viable for foreign-owned entities, so OSS doesn't designate a PMA issuing authority. Smaller-scale registrations (Micro / Small) for Indonesian operators are typically issued at the Regency / City level.

What other permits beyond the NIB does KBLI 69104 need?

Beyond the NIB, no specific auxiliary permits (PB UMKU) are recorded for KBLI 69104. Sector-specific obligations may still apply — verify with the relevant ministry.

What KBLI codes are similar to 69104?

KBLIs in the same subgroup 6910: 69101 (Legal Activities); 69102 (Legal Consultancy Activities); 69103 (Intellectual Property Consultancy Activities); 69109 (Other Legal Activities). These are closely related activities — see the related-codes section below for full list.

KBLI 2020 · 5-digit class

69104Notary and Land Deed Officer Activities

Aktivitas notaris dan pejabat pembuat akta tanah

Last updated April 24, 2026 · Sourced from OSS Indonesia

This group includes notary activities, and other activities of general notaries, civil law notaries, and other activities of bailiffs, arbitrators, examiners, and registrars. Included in this group are activities related to the sale and purchase agreements of land and buildings by land deed officials.

KBLI 69104 at a glance

Citation-ready summary

KBLI code: 69104
Taxonomy version: KBLI 2020
Activity (English): Notary and Land Deed Officer Activities
Activity (Indonesian): Aktivitas notaris dan pejabat pembuat akta tanah
Category: Professional, Scientific and Technical Activities
Risk level (Large scale, PMA): None recorded
Foreign ownership status

§ 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 · No foreign ownership

Reserved for small Indonesian operators

KBLI 69104 is set up for warungs, smallholders, individual practitioners and similar small businesses — Indonesia's licensing rules only define micro and small business sizes for it. Foreign-owned companies have to register at the Large business size, so even though this code isn't on the official "closed" list, foreign ownership isn't possible in practice. Pick a related KBLI that covers larger operations, or set up a partnership with an Indonesian operator who already holds the licence.

This activity is reserved for small Indonesian operators — think warungs, food stalls, smallholders, individual practitioners. KBLI 69104 only has licensing rules defined for micro and small business sizes. Foreign-owned companies have to register at the Large business size, so this code isn't available to them even though it's not on the "closed" list. Pick a related KBLI that covers larger operations, or ask us about partnering with an Indonesian operator who already holds the licence.

§ 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 69104 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.

Discuss your structure

69104Notary and Land Deed Officer Activities

KBLI 69104 at a glance

Foreign investment rules

Reserved for small Indonesian operators

What this means for foreign investors

Move to a different value-chain step

Special Economic Zone (KEK) or Free Trade Zone (Batam)

Indonesian-owned operating company + commercial agreement

KBLI 69104 needs a tailored structure. Let's design it.

Foreign investment rules

Reserved for small Indonesian operators

What this means for foreign investors

Move to a different value-chain step

Special Economic Zone (KEK) or Free Trade Zone (Batam)

Indonesian-owned operating company + commercial agreement

KBLI 69104 needs a tailored structure. Let's design it.

What is KBLI 69104?

Who needs KBLI 69104?

Why does the code matter?

Under the upcoming KBLI 2025

Carried forward into KBLI 2025

Common questions about KBLI 69104

What is KBLI 69104?

Can foreign investors operate under KBLI 69104?

What is the risk level of KBLI 69104?

What licenses does KBLI 69104 require?

What is the minimum capital for a PT PMA under KBLI 69104?

How long does it take to register a business under KBLI 69104?

Is KBLI 69104 eligible for Indonesian tax incentives?

Which authority issues the KBLI 69104 license?

What other permits beyond the NIB does KBLI 69104 need?

What KBLI codes are similar to 69104?

KBLI 69104 at a glance

Foreign investment rules

Reserved for small Indonesian operators

What this means for foreign investors

Move to a different value-chain step

Special Economic Zone (KEK) or Free Trade Zone (Batam)

Indonesian-owned operating company + commercial agreement

Related codes in Legal Activities

KBLI 69104 needs a tailored structure. Let's design it.

Foreign investment rules

Reserved for small Indonesian operators

What this means for foreign investors

Move to a different value-chain step

Special Economic Zone (KEK) or Free Trade Zone (Batam)

Indonesian-owned operating company + commercial agreement

Related codes in Legal Activities

KBLI 69104 needs a tailored structure. Let's design it.

What is KBLI 69104?

Who needs KBLI 69104?

Why does the code matter?

Under the upcoming KBLI 2025

Carried forward into KBLI 2025

Common questions about KBLI 69104

What is KBLI 69104?

Can foreign investors operate under KBLI 69104?

What is the risk level of KBLI 69104?

What licenses does KBLI 69104 require?

What is the minimum capital for a PT PMA under KBLI 69104?

How long does it take to register a business under KBLI 69104?

Is KBLI 69104 eligible for Indonesian tax incentives?

Which authority issues the KBLI 69104 license?

What other permits beyond the NIB does KBLI 69104 need?

What KBLI codes are similar to 69104?