Legal News Update
Contributors: Almaida Askandar, S.H., MBA, Rania Adhara Safira, S.H.
Published on 13 May 2026 by IABF Law Firm, Jakarta, Indonesia.
Navigating the Shift from KBLI 2020 to KBLI 2025
Indonesia is preparing to adopt the 2025 Indonesian Standard Business Field Classification (Klasifikasi Baku Lapangan Usaha Indonesia or “KBLI 2025”), as part of its risk-based business licensing framework. Since KBLI codes are used to identify business activities in corporate administration and licensing systems, this transition is relevant for companies, investors, notaries, and government institutions.
To support the implementation, on 25 March 2026, the Ministry of Investment and Downstream Industry/Head of the Investment Coordinating Board (“BKPM”), the Ministry of Law (“MOL”), and the Central Bureau of Statistics (“BPS”) jointly issued Joint Circular Letter No. 4.S, M.HH-1.HH.04.02, 1 Year 2026 regarding the Implementation of the Adjustment to KBLI 2025 in the Administration of Risk-Based Business Licensing (“Circular Letter“).
The Circular Letter provides practical guidance on how KBLI 2025 will be applied in government systems, particularly the Online Single Submission (“OSS”) system and the Directorate General of General Law Administration (Direktorat Jenderal Administrasi Hukum Umum or “Ditjen AHU”) system. It is intended to ensure that the transition from KBLI 2020 to KBLI 2025 can be carried out in an orderly manner without disrupting ongoing corporate and licensing processes.
For existing businesses, the Circular Letter confirms that licenses and approvals issued, verified, or approved before the implementation of KBLI 2025 will remain valid. These include Business Identification Numbers (Nomor Induk Berusaha or “NIB”), basic requirements, as well as supporting licenses for certain business activities. Businesses are therefore not required to replace or reapply for their existing licenses solely because of the introduction of KBLI 2025.
The Circular Letter also clarifies the position on amendments to a company’s articles of association (“AOA”). A company is only required to amend its AOA if the adjustment to KBLI 2025 results in a substantive change to its purposes, objectives, or business activities. Where the change is limited to the numerical KBLI code and does not affect the actual scope of business activities stated in the AOA, no formal AOA amendment is required. In that situation, the adjustment will be made automatically through the Ditjen AHU and OSS systems.
The treatment of KBLI adjustments may vary depending on how the relevant business activities are reclassified. Where one KBLI 2020 code is converted into one KBLI 2025 code, the adjustment should generally be treated as an administrative update, provided that there is no change to the company’s purposes, objectives, or business activities as stated in its deed.
A similar approach applies where one KBLI 2020 code is separated into several KBLI 2025 codes. In this case, an AOA amendment is not required as long as the new codes do not expand or materially change the company’s existing business activities. However, each resulting KBLI 2025 code must still be consistent with the company’s purposes and objectives in its AOA. If any of the new classifications are not adequately covered, the company must amend its AOA.
The same principle applies where several KBLI 2020 codes are consolidated into one KBLI 2025 code. If the consolidation does not change the substance of the company’s business activities, no AOA amendment should be required. Nevertheless, the consolidated classification must remain aligned with the company’s purposes and objectives. If the broader or consolidated scope is not properly reflected in the AOA, an amendment will be necessary.
The integration of KBLI 2025 into the Ditjen AHU and OSS systems is expected to be completed by the MOL and BKPM no later than 18 June 2026. Until these systems are fully updated, KBLI 2025 has not yet been applied in the relevant government platforms. During the transition period, business actors should continue to rely on KBLI 2020 for corporate and licensing purposes. The Ditjen AHU system will continue to process the legalization and administration of business entities using KBLI 2020, while the OSS system will continue to process risk-based business licensing under the same framework.
In practice, companies should use this transition period to review their current KBLI classifications and assess whether the shift to KBLI 2025 affects only the code number or also changes the description and scope of their business activities. If the change is merely administrative, no immediate corporate action may be necessary. However, if the new classification affects the substance of the company’s business activities, an AOA amendment and related licensing adjustments may need to be considered.
Disclaimer
This news update is prepared for general informational purposes only. The content does not constitute legal advice, a legal opinion, or counsel from IABF Law Firm. The information contained herein may not reflect the most current developments. Any quotation, distribution, or use of this information for any purpose is solely at the user’s own risk.
