KBLI 86104 is not on the closed, conditional, SME-reserved, or partnership schedules of Pres. Reg. 10/2021. That clears the ownership layer — PT PMA is structurally available. Sector regulators may still add overlays (see layer 02 below).
OSS issues the NIB and operating licence on the standard ladder, but Kemenkes sets a higher capital floor or additional requirements under Permenkes 3/2020. Plan separate sector-regulator review timelines on top of OSS.
OSS lists 7 operational obligations at Large scale for this code. None are structural foreign-investor barriers, but they determine ongoing compliance: Register the clinic in accordance with applicable regulations, Implement good clinic governance, including providing health services in…, and others.
Worth confirming: Openness here is based on BUPM (Pres. Reg. 10/2021). Sector regulators (PSE/Kominfo for digital platforms, BPOM for food and cosmetics, OJK for financial, Kemenkes for healthcare, Permendag for retail, ESDM for energy) often add licensing and capital requirements on top — the practical answer depends on your business model. Talk to our team
Aktivitas Klinik Pemerintah
Last updated · Sourced from OSS Indonesia
This group includes healthcare and physical treatment activities managed by the government, both outpatient and inpatient care.
Operating license routes through Ministry of Health, not OSS — Emerhub handles the application end-to-end.
Hospitals and clinics require an Izin Rumah Sakit / Klinik issued by Kemenkes after accreditation by KARS or similar bodies.
Foreign equity in private hospitals is capped at 67% in most cases; 100% allowed in some Special Economic Zones (KEKs).
Healthcare professionals must be Indonesian citizens or hold a foreign-practitioner license — there is no direct foreign-doctor practice permit outside specific arrangements.
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.
KBLI 86104 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.
Private hospitals (Type A/B/C/D)
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.
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.
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.
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.
We confirm KBLI 86104 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.
We 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.
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).
All Primary Clinics and Main Government Clinics
Documents and capabilities you must demonstrate at registration
Compliance and reporting duties throughout operation
The authority that issues the license depends on your situation.
| Authority | Applies when |
|---|---|
| Regent/Mayor | BLU/BLUD |
| Minister/Head of Agency | Foreign Investment |
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 7 candidate permits across 3 regulators; most operations only need a handful. Emerhub maps your operation to the exact set, files them, and tracks renewals.
Ministry 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.
BAPETEN (Nuclear Energy Regulatory Agency). Applies whenever ionizing radiation sources are involved — radiology, radiotherapy, industrial NDT, certain manufacturing inputs. BAPETEN licenses the operator, the facility, and each radiation source separately.
Ministry of Manpower. Applies 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).

We file the OSS application with KBLI 86104 as your primary business activity, complete the risk-based assessment, and collect the NIB (Business Identification Number) for you — typically within hours of submission. You don't need to touch the OSS portal.
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. We prepare the application bundle, liaise with the competent ministry, and chase issuance through to the certificate. Statutory turnaround: 25 business days — real-world timing typically runs longer when site inspections or additional clarifications are requested.
Post-launch we run your monthly tax filings, quarterly LKPM (Investment Activity Reports), annual general meeting (RUPS), and any sector-specific reporting. You get a single point of contact and a monthly compliance digest — no Indonesian-language paperwork on your desk.
Class-level prerequisites that apply to every operator under this KBLI, independent of business scale. These commonly include minimum capital rules for PMA entities and spatial-planning (KKPR) conformance.
The required capex tracks the tier the regulator assigns at audit. Each tier has its own bed/branch capacity, service scope and equipment depth — Emerhub scopes the build to the tier you intend to operate.
Top-tier reference hospital — provincial / national. Full sub-specialist coverage across every major medical field; usually a teaching hospital with an academic affiliation.
Comprehensive specialist hospital — regional / provincial. Sub-specialist coverage in the four main groups; common for province-level private chains.
Basic specialist hospital — district / city level. The most common foreign-investor entry tier for new-build private hospitals.
Limited specialist hospital — basic district services; functions partly as a step-up referral facility from puskesmas.
Capex figures are industry-typical estimates for greenfield foreign-investor entry — the regulator publishes the classification rules, not the rupiah number.
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.
Source: BKPM (2026-04-29). Updated quarterly.
View original on data.bkpm.go.id →A plain-English explanation of this classification and the businesses it covers.
KBLI 86104 (Aktivitas Klinik Pemerintah) is the 5-digit Indonesian Standard Industrial Classification code for government clinic activities. It sits within Human Health and Social Work Activities under the subgroup Hospital Activities (major group 86) in the official KBLI 2020 taxonomy maintained by Statistics Indonesia (BPS).
Any Indonesian or foreign-owned entity that intends to operate in government clinic activities as a primary or secondary business activity must select this code on its NIB (Business Identification Number). The selected code determines the licensing instruments required, the issuing authority, and the ongoing compliance obligations.
Indonesia's OSS Risk-Based Approach uses the KBLI code to determine three things: (1) whether foreign investment is permitted and at what cap, (2) the risk-based licensing instruments required, and (3) the authority that issues each instrument. Choosing the wrong code can delay or invalidate your license.
Indonesia's BPS published the new KBLI 2025 taxonomy in early 2025. OSS, BKPM and the operating ministries have not yet adopted it — KBLI 2020 remains the active standard for business registration. This is what's coming for this specific code.
KBLI 86104 retains the same code number and scope in the new taxonomy. The activity description, hierarchy, and intended use of the code are preserved.
When OSS adopts KBLI 2025, we'll migrate your existing entity to the appropriate successor code as part of ongoing compliance — no action needed on your end now.
Talk to a specialistIndonesia's OSS Risk-Based Approach assigns a separate risk level for each of the four business scales. The licensing instruments required (NIB, Standard Certificate, Operating License) are determined by the risk level. Foreign-owned entities (PT PMA) must register at the Large scale, so the rightmost column applies to most foreign investors.
KBLI 86104 (Aktivitas Klinik Pemerintah) is the 5-digit Indonesian Standard Industrial Classification code for government clinic activities. It sits within the Human Health and Social Work Activities category in the official KBLI 2020 taxonomy maintained by Badan Pusat Statistik (BPS).
KBLI 86104 is open to PT PMA under BUPM (Pres. Reg. 10/2021) — it is not on the closed, conditional, SME-reserved, or partnership-required schedules. That is the BUPM verdict only: sector regulators (PSE/Kominfo for digital platforms, BPOM for food and cosmetics, OJK for financial, Kemenkes for healthcare, Permendag for retail, ESDM for energy) commonly add licensing and capital requirements on top depending on the specific business model. Confirm the practical setup with our team before committing capital.
KBLI 86104's risk levels per business scale: Micro Medium-High, Small Medium-High, Medium Medium-High, Large Medium-High. Foreign-owned entities (PT PMA) must register at the Large scale.
NIB + verified Standard Certificate (Sertifikat Standar Terverifikasi). KBLI 86104 is Medium-High risk at Large scale, so NIB is issued first, but the Standard Certificate becomes effective only after the issuing ministry verifies compliance (typically through a document review or site audit). 7 sector-specific PB UMKU permits also apply depending on the exact activity. See the requirements summary at the top of the page. Plus one basic requirement (KKPR) at the class level.
Sector regulator override: Activity-tiered (see classification ladder) required by Kemenkes under Permenkes 3/2020 (Klasifikasi dan Perizinan Rumah Sakit). This is higher than BKPM Reg. 5/2025's default IDR 2.5 billion paid-up; the higher number wins.
PT PMA setup typically takes 4-8 weeks: AHU registration (1-2 weeks), NIB issuance via OSS (immediate to 1 week), bank account opening (2-4 weeks). The licensing cycle for KBLI 86104 specifically takes 25 days at the Large business scale.
Not on the Tax Holiday or Tax Allowance priority lists. KBLI 86104 businesses pay the standard 22% PPh Badan; Super Tax Deduction (300% R&D / 200% vocational training) may still apply for qualifying expenses.
Authority depends on the investor profile. For PMA: Regent/Mayor. For domestic SME scale: typically Governor (for Provincial scope) or Regent/Mayor (Regency/City scope). Specific mapping is in §1 of this page.
Beyond the NIB, KBLI 86104 carries 7 PB UMKU permits across 3 sector regulators: Health & Medical Devices (3), Nuclear & Radiation Safety (3), Occupational Health & Safety (1). Most operations only need 2-4 of these — the relevant set depends on which specific activities you actually perform; Emerhub maps the right subset before filing.
KBLIs in the same subgroup 8610: 86101 (Government Hospital Activities); 86102 (Community Health Center (Puskesmas) Activities); 86103 (Private Hospital Activities); 86105 (Private Clinic Activities); 86109 (Other Hospital Activities). These are closely related activities — see the related-codes section below for full list.