Foreign Investor FeasibilityKBLI 86103
§ 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 with carve-outs
Open to foreign investment, with carve-outs
KBLI 86103 is open as a class — a 100% foreign-owned PT PMA can be incorporated under this code — but Pres. Reg. 10/2021 carves out 1 specific sub-activity that are off-limits or restricted for foreign capital. The rest of the activity remains open to PMA. The carved-out items are listed below; any of them needs to be either avoided, served via an Indonesian operator, or structured around case-by-case.
Listed restrictions
Reserved for SMEs / cooperatives
1- Primary Clinic: Private maternity home, general medical clinic, general treatment services, residential health services, and basic health service facilities.Allocated for Cooperatives and UMKM.Sector: Health
Sector capital requirement
Higher minimum capital required by Kemenkes
Private hospitals (Type A/B/C/D)
Required paid-up
Activity-tiered (see classification ladder)
Regulation
Permenkes 3/2020 (Klasifikasi dan Perizinan Rumah Sakit)
Note. There is no flat paid-up rule. Kemenkes classifies every hospital on a four-tier ladder (Type A → D) based on bed count, specialist coverage and equipment depth — the assigned tier dictates the facility build needed, and capex follows from that. KARS accreditation is the operational gate before billing.
Investment momentum
Healthcare 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 3.9t≈ USD 0.24b
+56.3% YoY
Top investing countries
Singapore38%
Malaysia17%
Japan14%
Hospital JVs (KEK-resident facilities) and KARS-accredited clinic networks lead. Foreign equity capped at 67% in private hospitals (100% allowed in some KEKs). Singapore's IHH Healthcare and Malaysia's Columbia Asia are the largest existing operators.
§ 02
Regulations governing KBLI 86103
Current status, what each regulation actually requires for this activity, and how it ties to the PB UMKU sector permits below. Click through for the plain-English summary.
- Ministry of Investment / BKPM
- President of the Republic of Indonesia
Full PB UMKU permit list tied below.
§ 03
Common business profiles under KBLI 86103
Archetypal businesses operating under this code. Use these to recognize whether your venture maps to KBLI 86103 as primary or secondary activity.
What businesses register under KBLI 86103?
Real-world business archetypes — names omitted; profiles describe operational shape, not specific companies.
- 01Specialty private hospital (cardio, oncology, women's health)
Foreign-investor-backed specialty hospitals serving high-acuity care segments — typically partnerships between foreign healthcare groups and Indonesian medical foundations.
§ 04
How we handle your KBLI 86103 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 86103 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 86103, scoped to your specific business plan.
Request a quote§ 07
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 · 3
Sub-activity scope
Private Hospital with more than 250 beds
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
28Days
Statutory turnaround
Application requirements
5Documents and capabilities you must demonstrate at registration
- 01General administration, including: documents of non-profit or profit legal entities, hospital profile, and commitment to carry out accreditation.
- 02Technical requirements include: feasibility study documents, detailed engineering design documents, and hospital master plan.
- 03List of buildings, infrastructure, and equipment
- 04Plan for the organizational structure of human resources and a list of human resources
- 05Service documents
Ongoing obligations
4Compliance and reporting duties throughout operation
- 01Obtain hospital accreditation after operating for 2 years.
- 02Report through the Hospital Information System (SIMRS)
- 03Having a hospital registration number
- 04Conduct quality indicator measurements (internal) once a year.
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 |
§ 05
Auxiliary permits (PB UMKU)
These are CANDIDATE permits the OSS dataset attaches to this KBLI. Each one only becomes mandatory when your operation actually performs the activity it governs (e.g. distributing pharmaceuticals, handling food, operating radiology equipment). Many businesses operating under this code need none of them; some need a handful. This KBLI carries 40 candidate permits across 4 regulators. Emerhub maps your actual operating scope to the exact subset, files them, and tracks renewals.
Conditional list.Each sector card below names the operational trigger. If your business does not perform that activity, that sector’s permits do not apply to you.
Nuclear & Radiation Safety
23 candidate permitsBAPETEN (Nuclear Energy Regulatory Agency).
Required only ifApplies whenever ionizing radiation sources are involved (radiology, radiotherapy, industrial NDT, certain manufacturing inputs). BAPETEN licenses the operator, the facility, and each radiation source separately.
- Construction Permit for In Vivo Diagnostic Nuclear Medicine FacilityIzin Konstruksi Fasilitas Kedokteran Nuklir Diagnostik In Vivo11 requirements14 obligationsNuclear Energy
- Construction Permit for Nuclear Medicine Therapy FacilityIzin Konstruksi Fasilitas Kedokteran Nuklir Terapi11 requirements14 obligationsNuclear Energy
- Construction Permit for Radiofarmaceutical Production FacilityIzin Konstruksi Fasilitas Produksi Radiofarmaka11 requirements16 obligationsNuclear Energy
- Construction Permit for Radioisotope and Radiopharmaceutical Production FacilityIzin Konstruksi Fasilitas Produksi Radioisotop dan Radiofarmaka11 requirements15 obligationsNuclear Energy
Health & Medical Devices
12 candidate permitsMinistry of Health (Kemenkes / BPOM).
Required only ifApplies 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.
- Establishment of health examination procedures for Indonesian Migrant Worker Candidates (CPMI) at primary clinics.Penetapan penyelenggaraan pemeriksaan kesehatan Calon Pekerja Migran Indonesia (CPMI) di klinik utama19 requirements4 obligationsMinistry of Health
- Implementation of Eye Banks in HospitalsPenyelenggaraan Bank Mata di Rumah Sakit6 requirements1 obligation
- Implementation of nuclear medicine servicesPenyelenggaraan pelayanan kedokteran nuklir11 requirements4 obligationsMinistry of Health
- Letter of approval for the implementation of clinical trialsSurat persetujuan pelaksanaan uji klinikinactive2 requirements12 obligationsMinistry of Health
Pharmaceuticals
4 candidate permitsBPOM (National Agency of Drug & Food Control).
Required only ifApplies if the operation produces, imports, repackages, or distributes drugs, processed food, traditional medicine, cosmetics, or health supplements for human consumption. BPOM is the gating regulator; product registration is required before any commercial sale.
- Approval for the Implementation of Clinical Trials for DrugsPersetujuan Pelaksanaan Uji Klinik Obat2 requirements7 obligationsFood and Drug Supervisory Agency
- Approval for the Use of Pharmaceutical Manufacturing FacilitiesPersetujuan Penggunaan Fasilitas Pembuatan Obat3 requirements7 obligationsFood and Drug Supervisory Agency
- Certificate of Good Manufacturing Practice for PharmaceuticalsSertifikat Cara Pembuatan Obat yang Baik3 requirements3 obligationsFood and Drug Supervisory Agency
- Drug Distribution LicenseIzin Edar Obat4 requirements13 obligationsFood and Drug Supervisory Agency
Occupational Health & Safety
1 candidate permitMinistry of Manpower.
Required only ifApplies if the operation runs an in-house occupational health programme, employs workers in regulated risk roles, or hosts mandated worker health screenings (including for migrant-worker placement programmes).
Speak to Emerhub
Get your KBLI 86103 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.