KBLI 88991: Other Non-Accommodation Government Social…

KBLI 88991: Other Non-Accommodation Government Social… · Open to PMA

§ 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 88991 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 88991 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.

§ 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 adjacent industries

These KBLIs solve a related business problem and are open to foreign ownership. None are a perfect substitute for the activity above — but they often unlock 80% of the commercial outcome. Talk to us about which fits your plan.

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 88991 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.

Discuss your structure

§ 01

Foreign investment rules

Status · No foreign ownership

Reserved for small Indonesian operators

§ 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 adjacent industries

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 88991 needs a tailored structure. Let's design it.

Discuss your structure

§ 03

What is KBLI 88991?

A plain-English explanation of this classification and the businesses it covers.

KBLI 88991 (Aktivitas Sosial Pemerintah Tanpa Akomodasi Lainnya YTDL) is the 5-digit Indonesian Standard Industrial Classification code for other non-accommodation government social activities. It sits within Human Health and Social Work Activities under the subgroup Social Activities Without Other Accommodations YTDL (major group 88) in the official KBLI 2020 taxonomy maintained by Statistics Indonesia (BPS).

This group includes activities based on social work professions, the provision of social activity services, counseling, welfare, refugees, delivery, and similar services provided to individuals and families at home or elsewhere, conducted by the government, disaster relief organizations, and specialized counseling service organizations, such as welfare and guidance services for children and adolescents, adoption activities, and activities to prevent juvenile delinquency, household financial counseling services, marriage and family guidance, debt consultation services, community and environmental activities, activities for disaster victims, refugees, immigrants, and others including temporary or long-term shelters, rehabilitation and job habitations for the unemployed where the education component is limited, activities to determine compliance with welfare assistance, loans, or food coupons, daily child care activities, including for children with disabilities, daily facility activities for the homeless and other lower-middle social groups. This includes activities such as community development for marginalized communities, family consultations, women's leadership training, and village women's self-help initiatives, adoption, resocialization, and mentoring.

Who needs KBLI 88991?

Any Indonesian or foreign-owned entity that intends to operate in other non-accommodation government social 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.

§ 08

Common questions about KBLI 88991

What is KBLI 88991?

KBLI 88991 (Aktivitas Sosial Pemerintah Tanpa Akomodasi Lainnya YTDL) is the 5-digit Indonesian Standard Industrial Classification code for other non-accommodation government social 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 88991?

Not in practice. KBLI 88991 is not on Pres. Reg. 10/2021's closed list, but OSS RBA only defines licensing rules at the Micro and Small business scales for this activity — there is no Large-scale matrix. Foreign-owned PT PMA must register at the Large scale, so this code isn't structurally available to foreign investors. PT lokal (100% Indonesian-owned) at the Micro / Small scale can operate freely.

What is the risk level of KBLI 88991?

KBLI 88991 has no Large-scale licensing matrix in OSS — it's structured for Micro and Small business scales only. PT PMA cannot register under this code as a result.

What licenses does KBLI 88991 require?

Not applicable to PT PMA — KBLI 88991 is not viable for foreign-owned entities (closed, SME-reserved, domestic-only, or no Large-scale licensing matrix in OSS RBA, depending on the case). Foreign investors should pick a related KBLI that is open at the Large scale.

What is the minimum capital for a PT PMA under KBLI 88991?

Not applicable to PT PMA — KBLI 88991 is not viable for foreign-owned entities, so neither BKPM Reg. 5/2025's paid-up minimum nor any sector-specific capital floor enters the picture. The structural barrier comes first.

How long does it take to register a business under KBLI 88991?

Not applicable to PT PMA — KBLI 88991 is not viable for foreign-owned entities, so the 4-8 week PT PMA setup timeline doesn't apply. Move to a sibling code with a Large-scale matrix or a different structure.

Is KBLI 88991 eligible for Indonesian tax incentives?

Not on the Tax Holiday or Tax Allowance priority lists. KBLI 88991 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 88991 license?

Not applicable to PT PMA — KBLI 88991 is not viable for foreign-owned entities, so OSS doesn't designate a PMA issuing authority. Smaller-scale registrations (Micro / Small) for Indonesian operators are typically issued at the Regency / City level.

What other permits beyond the NIB does KBLI 88991 need?

Beyond the NIB, no specific auxiliary permits (PB UMKU) are recorded for KBLI 88991. Sector-specific obligations may still apply — verify with the relevant ministry.

What KBLI codes are similar to 88991?

KBLIs in the same subgroup 8899: 88992 (Private Social Activities Without Other Accommodations). These are closely related activities — see the related-codes section below for full list.

Three layers decide whether a foreign-owned PT PMA can be set up — and operated — under this code.

Ownership — open under BUPM

Industry licensing — no Large-scale OSS RBA matrix

Operational requirements — standard PT PMA setup

KBLI 88991 at a glance

Foreign investment rules

Reserved for small Indonesian operators

What this means for foreign investors

Move to a different value-chain step

Special Economic Zone (KEK) or Free Trade Zone (Batam)

Indonesian-owned operating company + commercial agreement

KBLI 88991 needs a tailored structure. Let's design it.

88991Other Non-Accommodation Government Social Activities

Foreign investment rules

Reserved for small Indonesian operators

What this means for foreign investors

Move to a different value-chain step

Special Economic Zone (KEK) or Free Trade Zone (Batam)

Indonesian-owned operating company + commercial agreement

KBLI 88991 needs a tailored structure. Let's design it.

What is KBLI 88991?

Who needs KBLI 88991?

Why does the code matter?

Under KBLI 2025

Reorganised in KBLI 2025

Common questions about KBLI 88991

What is KBLI 88991?

Can foreign investors operate under KBLI 88991?

What is the risk level of KBLI 88991?

What licenses does KBLI 88991 require?

What is the minimum capital for a PT PMA under KBLI 88991?

How long does it take to register a business under KBLI 88991?

Is KBLI 88991 eligible for Indonesian tax incentives?

Which authority issues the KBLI 88991 license?

What other permits beyond the NIB does KBLI 88991 need?

What KBLI codes are similar to 88991?

Ownership — open under BUPM

Industry licensing — no Large-scale OSS RBA matrix

Operational requirements — standard PT PMA setup

KBLI 88991 at a glance

Foreign investment rules

Reserved for small Indonesian operators

What this means for foreign investors

Move to a different value-chain step

Special Economic Zone (KEK) or Free Trade Zone (Batam)

Indonesian-owned operating company + commercial agreement

Related codes in Social Activities Without Other Accommodations YTDL

KBLI 88991 needs a tailored structure. Let's design it.

Foreign investment rules

Reserved for small Indonesian operators

What this means for foreign investors

Move to a different value-chain step

Special Economic Zone (KEK) or Free Trade Zone (Batam)

Indonesian-owned operating company + commercial agreement

Related codes in Social Activities Without Other Accommodations YTDL

KBLI 88991 needs a tailored structure. Let's design it.

What is KBLI 88991?

Who needs KBLI 88991?

Why does the code matter?

Under KBLI 2025

Reorganised in KBLI 2025

Common questions about KBLI 88991

What is KBLI 88991?

Can foreign investors operate under KBLI 88991?

What is the risk level of KBLI 88991?

What licenses does KBLI 88991 require?

What is the minimum capital for a PT PMA under KBLI 88991?

How long does it take to register a business under KBLI 88991?

Is KBLI 88991 eligible for Indonesian tax incentives?

Which authority issues the KBLI 88991 license?

What other permits beyond the NIB does KBLI 88991 need?

What KBLI codes are similar to 88991?