BKPM Reg. 5/2025: Indonesia's capital rules for PT PMA
Two figures every foreign investor needs before incorporating: IDR 2.5 billion paid-up at the bank, and IDR 10 billion total investment commitment per 5-digit KBLI on the NIB — realised over time, not upfront. This page is the plain-English breakdown of how the numbers work, what counts toward each, and the sector exceptions.
The two numbers, explained.
Cash deposited from shareholders' personal accounts into the corporate bank account during PT PMA incorporation. The bank issues a setoran modal letter used for the NIB application. Funds become available for legitimate business expenses immediately after.
Total investment value committed in the business plan, covering machinery, office, equipment, working capital, salaries — not just cash. Realised over time and reported quarterly via LKPM. Each additional KBLI on the NIB triggers another IDR 10 billion commitment.
Many third-party guides still cite "IDR 10 billion paid-up" — that was the rule before 2021 and it is wrong today. Wiring USD 640K into a corporate bank account at incorporation is unnecessary; you only need IDR 2.5 billion in cash. The IDR 10 billion is a multi-year commitment you realise through normal business spending.
BKPM 5/2025 vs. the prior BKPM 4/2021 regime.
The headline numbers (IDR 2.5b paid-up + IDR 10b commitment) are unchanged. Most substantive changes are in how the rules are administered:
Some agencies under 4/2021 grouped commitments at the 4-digit subgroup level (e.g. all of 6420 as one IDR 10b bucket). 5/2025 reaffirms that each registered 5-digit KBLI carries its own commitment — meaning a PMA with three 5-digit codes commits to IDR 30b total, not IDR 10b grouped.
Quarterly LKPM filings are now actively cross-checked against the cumulative commitment. Persistent under-realisation triggers BKPM correspondence faster than under the 4/2021 regime; a NIB suspension for unfiled LKPM is now a more credible enforcement step.
Pure holding companies under KBLI 64200 retain the standard threshold but BKPM now requires evidence that the holding company itself has substantive activity (not just shell ownership of subsidiaries). The investment commitment must be against the holding entity's own balance sheet, not consolidated subsidiary investment.
PMAs incorporated under BKPM 4/2021 are grandfathered for KBLIs already on their NIB at the time 5/2025 took effect. New KBLI additions to existing NIBs after October 2025 apply the new rules.
When the sector regulator sets a higher floor.
BKPM 5/2025 is the default. Several sector regulators set their own minimums that supersede the IDR 2.5b / 10b numbers — when both apply, the higher number wins.
This list isn't exhaustive. We confirm sector-specific minimums against the latest regulator guidance for the specific KBLIs you're registering, before incorporation — wrong assumptions here are expensive to unwind.
How the IDR 10 billion is realised.
The investment commitment is a total-investment figure — broader than just cash capital. The categories below all count toward realisation in your LKPM.
Office, building, land
Lease deposits, fit-out costs, owned property used for the business — measured at original cost or appraised value.
Machinery & equipment
Production equipment, IT hardware, vehicles, tools — the depreciated book value as recorded in audited financials.
Working capital
Cash held for operations, accounts receivable, inventory in regular business cycles. Not the same as paid-up capital.
Salaries & operating expenses
Employment costs paid to staff (Indonesian + foreign), professional fees and other operating expenses since incorporation.
Intangibles
Software licences, trademark filings, technology transfer payments, R&D expensed during the period.
Loans & shareholder advances
Working-capital loans drawn down and shareholder loans booked against the entity. Not double-counted with paid-up capital.
Common questions about BKPM Reg. 5/2025.
What is BKPM Regulation No. 5 of 2025?
BKPM Reg. 5/2025 (Peraturan BKPM Nomor 5 Tahun 2025) is the implementing regulation that sets the minimum-capital framework for PT PMA — Indonesian limited-liability companies with any foreign shareholding. It came into effect in October 2025, replacing BKPM Reg. 4/2021 (Perka 4/2021). Together with Pres. Reg. 10/2021 (the BUPM Investment Business Fields list) it governs which activities a PMA can enter and at what capital scale.
What are the actual capital numbers for a PT PMA?
Two distinct figures: (1) IDR 2.5 billion paid-up capital, the cash that must be deposited into the company's bank account at incorporation — roughly USD 160,000. (2) IDR 10 billion total investment commitment per 5-digit KBLI registered on the NIB, realised over time through machinery, office space, salaries, working capital. This second figure is reported quarterly via LKPM and is not required upfront. Many third-party agencies still cite "IDR 10 billion paid-up", which is the old (pre-2021) rule and is wrong.
Why per-KBLI? What if my business needs multiple KBLIs?
The IDR 10 billion commitment applies per 5-digit KBLI selected on your NIB, not per company. A holding company registering KBLI 64200 plus consulting services KBLI 70209 would commit IDR 20 billion total. This is intentional — the regulation discourages "umbrella" KBLI registrations and pushes investors to scope tightly to the activities they actually plan to operate. If you incorporate with three KBLIs you couldn't realistically realise IDR 30 billion across, expect your LKPM to flag the mismatch.
Does the IDR 10 billion need to be paid in cash?
No. The investment commitment is a total-investment figure that includes machinery, equipment, office facilities, vehicles, intangible assets, working capital and salaries — anything the PMA actually invests in the business. Paid-up capital (the IDR 2.5b) is the only figure that must be cash-in-bank at incorporation. The remainder is realised over time and reported through LKPM each quarter.
How is the IDR 10 billion realised? What's the timeline?
There is no hard deadline by which the IDR 10b must be realised, but BKPM monitors quarterly LKPM filings to track realisation against commitment. Practical reality: most foreign investors realise the bulk in years 1-3 through capex (offices, equipment) and working capital. Persistent under-realisation can trigger LKPM warnings and, in extreme cases, NIB suspension. Sector-specific guidance varies — financial services tend to be more closely watched than e-commerce or services.
What sectors have higher minimums than the BKPM 5/2025 default?
Several. OJK-regulated activities (banking, insurance, financing, fintech P2P, securities) carry their own paid-up capital floors set by the financial-services authority — banking is IDR 3 trillion paid-up; fintech P2P is IDR 25 billion. ESDM (energy & mining) sets activity-specific minimums for IUP / IPL holders. Kemenkes (health) sets minimums for hospitals and clinics. Kominfo (tech) sets minimums for telco operators and PSE-registered platforms. BKPM 5/2025 is the default; the sector regulator wins when it sets a higher number.
I'm a 100% Indonesian-owned PT (no foreign shareholders) — does this apply to me?
No. BKPM Reg. 5/2025 governs PMA only — PT lokal (companies with 100% Indonesian shareholders) is not subject to these floors. Paid-up capital for PT lokal is set by the founders in the akta and follows UU Cipta Kerja / PP 8/2021 — typically IDR 50 million to IDR 500 million for SMEs. See our domestic PT setup page for details.
How does this interact with the BUPM list (Pres. Reg. 10/2021)?
BUPM tells you whether a foreign investor can enter the activity at all — closed, conditional with cap, SME-reserved, partnership-required, or open. BKPM 5/2025 tells you the capital requirements once you're entering an open or conditional KBLI. The two regulations layer: a KBLI on the conditional list with a 49% foreign cap still needs the BKPM 5/2025 capital evidence on the foreign portion. A closed KBLI is closed regardless of whether you can meet the capital.
What changed vs the prior BKPM Reg. 4/2021?
The 2025 update kept the IDR 10b per-KBLI commitment unchanged (the headline number every guide cites) but tightened LKPM enforcement, clarified the per-5-digit-KBLI scope (some agencies were grouping by 4-digit subgroup), and adjusted treatment of conduit / holding structures. Pre-existing PMAs incorporated under the 2021 regime are grandfathered in but new KBLI registrations on existing NIBs apply 5/2025 rules.
How is paid-up capital actually deposited and verified?
After AHU approves your akta pendirian (deed of establishment), you open a corporate bank account. The IDR 2.5b is wired in from the shareholders' personal accounts. The bank issues a setoran modal letter (capital deposit confirmation) which becomes part of the NIB application package. BKPM/OSS doesn't hold the money — the verification is documentary. You can use the funds for legitimate business expenses immediately.
What happens if I want to add a new KBLI to an existing PMA?
You file a perubahan NIB (NIB amendment) via OSS. Each new 5-digit KBLI added triggers a fresh IDR 10 billion commitment that must be realised over time. Adding three new KBLIs to an existing 2-KBLI PMA means the total commitment goes from IDR 20b to IDR 50b — your future LKPM filings need to reflect realisation against the larger total.
Where can I read the actual regulation text?
The official text is published on JDIH BKPM (jdih.bkpm.go.id) — the legal database maintained by the Ministry of Investment / BKPM. It's in Bahasa Indonesia. For investor-facing summaries, BKPM publishes English fact-sheets via investindonesia.go.id, but the binding text is the Indonesian original. We work from JDIH directly for our compliance work.
