Foreign Investor FeasibilityKBLI 86109
§ 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 · No foreign ownership
Reserved for small Indonesian operators
KBLI 86109 is set up for warungs, smallholders, individual practitioners and similar small businesses — Indonesia's licensing rules only define micro and small business sizes for it. Foreign-owned companies have to register at the Large business size, so even though this code isn't on the official "closed" list, foreign ownership isn't possible in practice. Pick a related KBLI that covers larger operations, or set up a partnership with an Indonesian operator who already holds the licence.
This activity is reserved for small Indonesian operators — think warungs, food stalls, smallholders, individual practitioners. KBLI 86109 only has licensing rules defined for micro and small business sizes. Foreign-owned companies have to register at the Large business size, so this code isn't available to them even though it's not on the "closed" list. Pick a related KBLI that covers larger operations, or ask us about partnering with an Indonesian operator who already holds the licence.
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
Healthcare-specific guidance
Sector context that applies to KBLI 86109 beyond the generic OSS process. Verify with the relevant ministry before committing capital.
Lead regulator
Ministry of Health (Kemenkes)
- ·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.
- ·Medical devices imported or distributed require BPOM medical-device registration.
§ 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.
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
Speak to Emerhub
KBLI 86109 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.