Foreign Investor FeasibilityKBLI 79122
§ 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 · domestic only
Open only to Indonesian capital
100%
domestic capital
KBLI 79122 is restricted to 100% domestic ownership. Foreign investors cannot hold shares in entities operating under this code. This restriction commonly applies to traditional industries, broadcasting, and culturally significant activities.
Listed restrictions
Conditional sub-activities
1- Activities of pilgrimage travel agencies for Umrah and special Hajj.Domestic only100% Domestic capital and Muslim.
§ 02
Activities included under KBLI 79122
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 79122
From the official OSS scope definition for this KBLI class. Each item is a distinct sub-activity that falls under this code.
- 01Activities of the Special Hajj Organizing Bureau
- 02Activities of Umrah Pilgrimage Travel Bureau
§ 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.
You can't hold equity in this activity directly.
This KBLI is reserved to 100% Indonesian capital under Pres. Reg. 10/2021. Foreign investors cannot own shares in an entity registered for this code. The honest paths forward are: (1) operate a different but related KBLI that's open to PMA, (2) partner with a fully Indonesian-owned licensee under a commercial / IP / supply agreement (not equity), or (3) explore a Special Economic Zone where the rule may be relaxed.
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§ 06
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
Activities of the Special Hajj Organizing Bureau
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
14Days
Statutory turnaround
Application requirements
7Documents and capabilities you must demonstrate at registration
- 01Has been a PPIU (Organizer of Umrah Pilgrimage) for at least 3 (three) years or has dispatched at least 1,000 (one thousand) umrah pilgrims.
- 02PPIU Certificate (Organizer of Umrah Pilgrimage Trips)
- 03Statement Letter with Stamp from shareholders, Commissioners, and Directors, stating that: a. They have never committed legal violations related to the organization of Umrah pilgrimage and special Hajj pilgrimage that have permanent legal force within the last 5 (five) years b. They have never been or are currently subject to sanctions for legal violations related to the organization of Umrah pilgrimage and special Hajj pilgrimage that have permanent legal force c. They are willing to fulfill obligations as Organizers of Special Hajj and are willing to improve the quality of the organization of special Hajj in accordance with the provisions of laws and regulations.
- 04Copy of the certificate of ownership (shareholders, commissioners, directors, or in the name of the company) or a lease agreement for office space that is valid for at least 5 (five) years into the future, evidenced by notarization or legalization from a Notary.
- 05Financial report documents of the Company for the last 1 (one) year, audited by a Public Accountant registered with the Ministry of Finance with an Unqualified Opinion (WTP).
- 06Copy of the fiscal statement in the name of the Company
- 07Bank guarantee in the form of a deposit/bank guarantee in the name of the Travel Agency issued by a sharia bank and/or a national commercial bank with sharia services with a validity period of 6 (six) years.
Ongoing obligations
14Compliance and reporting duties throughout operation
- 01Facilitating the processing of special pilgrimage travel documents for Hajj.
- 02Providing guidance and coaching for special Hajj worship.
- 03Providing health services, transportation, accommodation, consumption, and protection.
- 04Organizing, serving, and returning Special Hajj Pilgrims in accordance with the agreement.
- 05Send the person in charge of the Special Hajj Organizer (PIHK), health officers, and special Hajj worship guides in accordance with the provisions of special Hajj services.
- 06Facilitating the transfer of prospective Special Hajj Pilgrims to another Special Hajj Organizing Institution (PIHK) at the request of the pilgrims.
- 07Send at least 45 (forty-five) special Hajj pilgrims.
- 08Deploy 1 (one) person as the responsible officer for the Special Hajj Organizer (PIHK), 1 (one) health officer, and 1 (one) guide for special Hajj worship for at least 45 (forty-five) special Hajj pilgrims being sent to Saudi Arabia.
- 09Obtain accreditation every 5 (five) years.
- 10Report changes in shareholders, commissioners, directors, and the address of the Special Hajj Organizing Company (PIHK) within a maximum of 3 (three) months from the occurrence of the change.
- 11Report if there is an opening of a Branch Office.
- 12Report the progress of the implementation of special hajj services.
- 13Report the departure of Indonesian citizens who receive an invitation for the hajj mujamalah visa.
- 14Report the number of special hajj pilgrims to be represented in hajj before the implementation of wukuf to the hajj organizing officials in Saudi Arabia.
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
KBLI 79122 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.