KBLI 2020 · 5-digit class

86104Government Clinic Activities

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.


For foreign investors · KBLI 86104
100% PMA

Yes — open to PMA up to 100%.

Operating license routes through Ministry of Health, not OSS — Emerhub handles the application end-to-end.


Foreign ownership
100% PMA
Sector regulator
Ministry of Health (Kemenkes)
Min. paid-up capital
IDR 2.5B paid-up · BKPM Reg. 5/2025
Issuing authority for PMA
Minister/Head of Agency
Ministry-issued
Domestic registrants route through Regent/Mayor instead.
Risk + license type
Medium-High·NIB + Verified Standard Cert.
Setup timeline
PT PMA 4–8 weeks; Emerhub files the verified Standard Certificate (1–2 months ministry review).

What's specific to this sector

  • 01

    Hospitals and clinics require an Izin Rumah Sakit / Klinik issued by Kemenkes after accreditation by KARS or similar bodies.

  • 02

    Foreign equity in private hospitals is capped at 67% in most cases; 100% allowed in some Special Economic Zones (KEKs).

  • 03

    Healthcare professionals must be Indonesian citizens or hold a foreign-practitioner license — there is no direct foreign-doctor practice permit outside specific arrangements.


KBLI 86104 at a glance

KBLI code
86104
Taxonomy version
KBLI 2020
Activity (English)
Government Clinic Activities
Activity (Indonesian)
Aktivitas Klinik Pemerintah
Category
Human Health and Social Work Activities
Risk level (Large scale, PMA)
Medium-High
Foreign ownership status
Fully open to PMA (100%)
Minimum capital (PT PMA)
Activity-tiered (see classification ladder) (Kemenkes)
Primary licensing instrument
NIB
Issuing authority (PMA)
Regent/Mayor
Tax incentive eligibility
None recorded
Last verified
April 24, 2026
Source: OSS Indonesia + BPS Peraturan 7/2025 + BKPM
§ 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

Fully open to foreign investment

KBLI 86104 is not on Indonesia's closed, conditional, SME-reserved or partnership-required schedules. A foreign investor may incorporate a PT PMA with up to 100% foreign ownership and operate in this activity directly.


This KBLI is not listed in any restricted, closed, SME-reserved or partnership-required schedule under Pres. Reg. 10/2021 (as amended). A 100% foreign-owned PT PMA may operate in this activity, subject to the licensing requirements shown below. BKPM's default minimum capital is IDR 2.5 billion paid-up with IDR 10 billion+ total investment commitment per KBLI realised over time, but sector regulators (OJK, ESDM, BPOM, Kominfo, etc.) can set higher minimums for specific activities — we confirm the actual figure before incorporation.
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.

Classification ladder

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.

  • Type AIDR 200B+

    Top-tier reference hospital — provincial / national. Full sub-specialist coverage across every major medical field; usually a teaching hospital with an academic affiliation.

    Capacity
    ≥ 250 beds
    Scope
    Comprehensive specialist + sub-specialist services in 4 main groups (internal medicine, surgery, paediatrics, OB/GYN) plus full sub-specialist coverage in supporting fields
  • Type BIDR 100–200B

    Comprehensive specialist hospital — regional / provincial. Sub-specialist coverage in the four main groups; common for province-level private chains.

    Capacity
    ≥ 200 beds
    Scope
    Specialist + limited sub-specialist services across the four main groups, plus the supporting medical specialties required by Permenkes
  • Type CIDR 50–100B

    Basic specialist hospital — district / city level. The most common foreign-investor entry tier for new-build private hospitals.

    Capacity
    ≥ 100 beds
    Scope
    Specialist services across the four main groups (internal, surgery, paediatrics, OB/GYN); limited supporting specialties
  • Type DIDR 20–50B

    Limited specialist hospital — basic district services; functions partly as a step-up referral facility from puskesmas.

    Capacity
    ≥ 50 beds
    Scope
    Limited specialist services; primarily basic medical specialties without sub-specialist coverage

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.

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.

Source: BKPM (2026-04-29). Updated quarterly.

View original on data.bkpm.go.id →
§ 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. 1

    Confirm the optimal structure for your business

    2–3 business days

    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.

    What we need from you
    • Founders' passport copies and proof of residence
    • Intended share split and board composition
  2. 2

    Incorporate your PT PMA

    7–10 business days

    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.

    What we need from you
    • Powers of attorney (we prepare; you sign and notarize)
    • Director / commissioner appointment letters
    • Initial capital deposit confirmation
  3. 3

    We obtain your NIB

    1–2 business days

    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.

    What we need from you
    • Office address (virtual office acceptable for many KBLIs; we can arrange one)
  4. 4

    Secure your Standard Certificate (Verified)

    25+ business days

    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.

    What we need from you
    • Technical documentation specific to your operation
    • Appointment of a Penanggung Jawab Teknis (PJT — technical responsible person)
  5. 5

    Hand-off to ongoing compliance

    Ongoing

    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.

Get an exact quote and timeline for KBLI 86104, scoped to your specific business plan.
Request a quote
§ 03

What is KBLI 86104?

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).

This group includes healthcare and physical treatment activities managed by the government, both outpatient and inpatient care.

Who needs KBLI 86104?

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.

Why does the code matter?

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.

§ 04

Under the upcoming KBLI 2025

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.

Carried forward into KBLI 2025

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.

  • ·Continue using 86104 for current registrations under KBLI 2020.
  • ·When OSS adopts KBLI 2025 (timing not yet announced), no migration is required for this code.
  • ·Risk level, permits, and authority routing shown above remain in effect under both taxonomies.

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 specialist
§ 02

Risk level by business scale

Indonesia'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.

01

Micro

Usaha Mikro
≤ IDR 2 B turnover
Medium-High risk
NIB + ministry-verified Standard Certificate before invoicing.
02

Small

Usaha Kecil
IDR 2 – 15 B
Medium-High risk
NIB + ministry-verified Standard Certificate before invoicing.
03

Medium

Usaha Menengah
IDR 15 – 50 B
Medium-High risk
NIB + ministry-verified Standard Certificate before invoicing.
04

Large

PMA scale
Usaha Besar
IDR > 50 B
Medium-High risk
NIB + ministry-verified Standard Certificate before invoicing.
What does each risk level require to operate?
Low. NIB alone is sufficient for both preparation and commercial operation. Issued instantly via OSS.
Medium-Low. NIB enables preparation only. Commercial operation requires a self-declared Sertifikat Standar (Standard Certificate). Operating with NIB alone is not legally compliant.
Medium-High. NIB enables preparation only. Commercial operation requires a Sertifikat Standar verified by the competent ministry — typically with a site or document inspection.
High. NIB enables preparation only. Commercial operation requires a full Operating License (Izin) issued by the competent ministry after substantive review.
Beyond OSS, sector-specific permits commonly apply on top — e.g. SBU for construction, BPOM for food/cosmetics/medicines, OJK for financial services, IUP for mining, PSE for digital services. See the industry-specific guidance below for what applies to this KBLI.
§ 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

7

Documents and capabilities you must demonstrate at registration

  • 01Profil klinik
  • 02Self assesment klinik
  • 03List of medicines and Health-Related Products
  • 04Daftar SDM klinik
  • 05Dokumen pendukung izin praktik tenaga medis/ tenaga kesehatan
  • 06Perjanjian kerja sama pengelolaan limbah B3
  • 07Data pendukung (jika diperlukan): a. Dokumen mempekerjakan TKWNA b. Dokumen perpanjangan perizinan (perizinan sebelumnya, peraturan internal klinik/ kebijakan lain tentang penyelenggaraan klinik, bukti registrasi, kewajiban klinik lainnya) c. Dokumen perubahan perizinan (perizinan sebelumnya, surat keterangan alasan perubahan dari pemilik klinik, kewajiban klinik lainnya)

Ongoing obligations

7

Compliance and reporting duties throughout operation

  • 01Register the clinic in accordance with applicable regulations.
  • 02Menyelenggarakan tata kelola klinik yang baik, termasuk pelayanan kesehatan diberikan sesuai standar pelayanan, standar prosedur operasional, dan standar profesi masing masing tenaga medis/ tenaga kesehatan
  • 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.
  • 07Mendukung pelaksanaan program nasional

Issuing authority

The authority that issues the license depends on your situation.

AuthorityApplies when
Regent/MayorBLU/BLUD
Minister/Head of AgencyForeign Investment
§ 04

Basic requirements (KKPR)

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.

Mandatory before any license can be issued
  1. 01Business licensing can be processed through the Risk-Based OSS System only for "Government" Business Actors that are public legal entities in the form of Public Service Agencies (BLU) or Regional Public Service Agencies (BLUD).
§ 05

Auxiliary permits (PB UMKU)

This KBLI commonly carries 7 additional permits attached to specific operational activities. PB UMKU permits are issued separately from the main business license — Emerhub files only the ones relevant to your operation.

§ 08

Common questions about KBLI 86104

What is KBLI 86104?

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).

Can foreign investors operate under KBLI 86104?

Yes — KBLI 86104 is fully open to foreign investment. A PT PMA may operate with up to 100% foreign ownership, subject to BKPM Reg. 5/2025 capital requirements (IDR 2.5 billion paid-up + IDR 10 billion+ commitment per KBLI).

What is the risk level of KBLI 86104?

KBLI 86104's risk levels per business scale: Mikro Medium-High, Kecil Medium-High, Menengah Medium-High, Besar Medium-High. Foreign-owned entities (PT PMA) must register at the Large scale.

What licenses does KBLI 86104 require?

NIB only — KBLI 86104 is a low-risk activity in OSS RBA, so the Business Identification Number alone suffices for operational licensing.

What is the minimum capital for a PT PMA under KBLI 86104?

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.

How long does it take to register a business under KBLI 86104?

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.

Is KBLI 86104 eligible for Indonesian tax incentives?

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.

Which authority issues the KBLI 86104 license?

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.

What other permits beyond the NIB does KBLI 86104 need?

Beyond the NIB, KBLI 86104 commonly requires: License/establishment of hyperbaric medical services in hospitals., License/establishment for dialysis service provision, Establishment of health examination procedures for Indonesian Migrant Worker Candidates (CPMI) at primary clinics., Occupational Health and Safety Services for Health Inspection/Testing of Workers and/or Occupational Health Services, Diagnostic and/or Interventional Radiology License, +2 more. The auxiliary permits list (PB UMKU) shown on this page is the complete set OSS associates with this code.

What KBLI codes are similar to 86104?

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.

Emerhub advisor
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.