Foreign Investor FeasibilityKBLI 86104
§ 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 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.
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 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
How we handle your KBLI 86104 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 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.
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 86104, scoped to your specific business plan.
Request a quote§ 05
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 scope
All Primary Clinics and Main Government Clinics
What's required to operate
NIB
Preparation only — additional permit needed below
Standard Certificate (Verified)
Important: 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.
Processing time
25Days
Statutory turnaround
Application requirements
7Documents and capabilities you must demonstrate at registration
- 01Clinic profile
- 02Self-assessment clinic
- 03List of medicines and Health-Related Products
- 04List of Human Resources for Clinics
- 05Supporting documents for medical personnel/health worker practice license
- 06Cooperation agreement for the management of hazardous waste (B3)
- 07Supporting data (if required): Documents for employing foreign workers Documents for license extension (previous licenses, internal clinic regulations/other policies regarding clinic operations, registration proof, other clinic obligations) Documents for license changes (previous licenses, letter of explanation for changes from the clinic owner, other clinic obligations)
Ongoing obligations
7Compliance and reporting duties throughout operation
- 01Register the clinic in accordance with applicable regulations.
- 02Implement good clinic governance, including providing health services in accordance with service standards, standard operating procedures, and professional standards for each medical/healthcare personnel.
- 03Input/update data in the information system owned by the Ministry of Health in accordance with applicable regulations (ASPAK, INM, DFO, etc.).
- 04Conduct electronic medical records at the clinic in accordance with applicable regulations.
- 05Ensure the quality and safety of patients and conduct clinic accreditation in accordance with applicable regulations.
- 06Report the results of clinic activities in accordance with applicable regulations.
- 07Support the implementation of national programs.
Issuing authority
The authority that issues the license depends on your situation.
| Authority | Applies when |
|---|---|
| Regent/Mayor | BLU/BLUD |
| Minister/Head of Agency | Foreign Investment |
§ 05
Auxiliary permits (PB UMKU)
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.
Health & Medical Devices
3 permitsMinistry 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.
- 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
- License/establishment for dialysis service provisionIzin/penetapan penyelenggaraan pelayanan dialisis9 requirements5 obligationsMinistry of Health
- License/establishment of hyperbaric medical services in hospitals.Izin/penetapan pelayanan medis hiperbarik di RS9 requirements3 obligationsMinistry of Health
Nuclear & Radiation Safety
3 permitsBAPETEN (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.
- Diagnostic and/or Interventional Radiology LicenseIzin Radiologi Diagnostik dan/atau Intervensional12 requirements10 obligationsNuclear Energy
- Use for In Vitro Diagnostic Nuclear MedicinePenggunaan untuk Kedokteran Nuklir Diagnostik In Vitro7 requirements9 obligationsNuclear Energy
- Use that includes Diagnostic Radiology for Bone Density Measurement and/or Intraoral Dental Equipment.Penggunaan yang Meliputi Radiologi Diagnostik untuk Pengukuran Densitas Tulang dan/atau Pesawat Gigi Intra Oral7 requirements9 obligationsNuclear Energy
Occupational Health & Safety
1 permitMinistry 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).
Speak to Emerhub
Get your KBLI 86104 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.