The Government of the Republic of Indonesia has issued a Joint Circular Letter (“Surat Edaran Bersama/SEB”) of the Minister of Investment and Downstreaming/Head of BKPM, the Minister of Law, and the Head of Statistics Indonesia. The regulations numbered 4.S/Year 2026, Number M.HH-1.HH.04.02/Tahun 2026, and Number 1/Year 2026 govern the Implementation of the Adjustment of the 2025 Indonesia Standard Industrial Classification (“KBLI 2025”) in the Implementation of Risk-Based Business Licensing.
This SEB was stipulated in Jakarta on March 25, 2026. This regulation was issued to provide technical and operational guidance for all stakeholders regarding the procedures for adjusting KBLI codes within the Online Single Submission (“OSS”) System and the Directorate General of General Legal Administration (“Ditjen AHU”) System.
Key Points for Business Actors
Here is a summary of the important provisions that you need to pay attention to regarding your company’s business activities:
Current Licensing Status Remains Valid:
All Basic Requirements (Persyaratan Dasar/PD), Business Licensing (Perizinan Berusaha/PB), and/or Business Licensing to Support Business Activities (PB UMKU) belonging to the company that have been issued, verified, or approved prior to the implementation of KBLI 2025, are declared to remain valid.
Conditions Requiring Articles of Association Amendments:
- Business actors registered in the Ditjen AHU System must adjust to KBLI 2025 through an amendment to the Articles of Association if there is a corporate action.
- The corporate action in question refers to an action that changes the Purpose and Objectives of the company, as well as a change in business activities over the existing ones.
- If the scope of business affected by the KBLI change is not yet listed in the deed, the business actor is required to make adjustments in the deed first.
Automatic KBLI Adjustment Conditions:
- KBLI 2025 adjustment is not required if the change is only a numeric code adjustment based on the conversion table.
- This provision applies provided that the adjustment does not result in a change to the substance of the purpose and objectives as well as the scope of business activities that have been listed in the Articles of Association.
- In this condition, the adjustment will be carried out automatically through the Ditjen AHU System and the OSS System without requiring an amendment to the company’s Articles of Association.
- Recording the purpose and objectives in the deed on the Ditjen AHU system does not need to be adjusted as long as there is no change or addition to the existing business activities.
- Adjustments to the scope based on the conversion table only change the KBLI code and will still follow the purpose and objectives listed in the deed.
Transition Period and System Deadlines:
- The KBLI 2025 adjustment on the OSS System and Ditjen AHU System will be carried out by the relevant agencies no later than June 18, 2026.
- Before the adjustment is implemented, the Ditjen AHU System will continue to process the ratification of business actors using the 2020 KBLI.
- Similarly, the OSS System will still process business licensing using the 2020 KBLI until the adjustment is fully implemented.
Conclusion
The Company does not need to be concerned about the validity of its existing licenses, provided that such licenses were duly issued, as they shall remain valid in principle.
We recommend that the Company undertake the following actions:
- If the Company plans to carry out any corporate actions in the future that result in changes to its business activities, an adjustment to KBLI 2025 through an amendment to the Company’s deed shall become mandatory.
- To consult with professional advisors or the Company’s internal legal team to determine whether such an adjustment to KBLI 2025 needs to be implemented through an amendment to the Articles of Association or is not required.
Disclaimer Statement:
- The information contained in this document is not intended to constitute legal advice, legal opinion, or any form of legal recommendation applicable to your business. The author has prepared this document in good faith and with reasonable care. However, no representation or warranty, whether express or implied, is made as to the accuracy, completeness, or timeliness of the information provided herein.
- The reader acknowledges that each company operates under different circumstances and business practices; therefore, the information presented may not be applicable to all business activities.
- The reader is strongly advised to seek professional advice or contact us directly prior to taking any legal action based on the information contained in this document. By reading this document, the reader is deemed to have agreed to release and hold harmless the author from any and all claims, damages, losses, liabilities, penalties, or sanctions that may arise in connection with the use of the information provided herein.