Update on KBLI 2025 and Its Implementation
- FKNK Law Firm
- 4 days ago
- 6 min read
On 17 December 2025, the Badan Pusat Statistik (“BPS”) issued Regulation No. 7 of 2025 on the Indonesian Standard Industrial Classification (“BPS Reg. 7/2025”). This regulation revokes and replaces BPS Regulation No. 2 of 2020 and introduces updates to the Indonesian Standard Industrial Classification (Klasifikasi Baku Lapangan Usaha Indonesia – “KBLI”) transitioning from KBLI 2020 to KBLI 2025.
Under BPS Reg. 7/2025, all business actors utilizing KBLI classification are required to comply with KBLI 2025 within a maximum period of 6 (six) months from the date of its promulgation, i.e., no later than 18 June 2026. Accordingly, business actors should promptly conduct a comprehensive review and assessment of their business activities to ensure its alignment with the updated KBLI 2025 classification.
In relation to the implementation of KBLI 2025, on 25 March 2026, the Minister of Investment and Downstream Industry/Head of the Investment Coordinating Board, the Minister of Law, and the Head of BPS jointly issued a Circular Letter No. 4.S of 2026, No. M.HH-1.HH.04.02 of 2026, and No. 1 of 2026 regarding the Implementation of KBLI 2025 in the Administration of Risk-Based Business Licensing (“Joint Circular Letter”). This Joint Circular Letter addresses the integration of KBLI 2025 into the Online Single Submission (“OSS”) system, the Directorate General of Legal Administration (Administrasi Hukum Umum – “AHU”) system, and other relevant ministries and government agencies system connected to OSS.
Pursuant to the Joint Circular Letter, the implementation of KBLI 2025 within the OSS and AHU systems will be carried out by the Ministry of Investment and Downstream Industry/ Investment Coordinating Board and the Minister of Law no later than 18 June 2026. Until such implementation is completed, both the OSS system and the AHU system will continue to operate using KBLI 2020.
Overview of KBLI 2025
KBLI 2025 represents a refinement of KBLI 2020, while maintaining the fundamental principles, concepts, and methodologies for classifying economic activities in accordance with international standards referring to the International Standard Industrial Classification of All Economic Activities – ISIC.
Each update to the ISIC issued by the United Nations Statistics Division (UNSD) serves as the basis for BPS to adjust the KBLI, in this present case referring to ISIC Revision 5. KBLI 2025 which adopts the ISIC Revision 5 replaces the previous reference to ISIC Revision 4 which was applied under KBLI 2020. At the five-digit level, KBLI 2025 has been tailored to reflect the specific conditions and characteristics to the economic activities in Indonesia.
The amendments to the KBLI are intended to adjust business activity classifications with the evolving structure of the national economy, including the emergence of new business models, advancements in digital technology, and the need for a more accurate and detailed classification system.
It is also important to note that the refinement process of KBLI requires active participation from relevant Ministries and Government Agencies, particularly in identifying newly emerging economic activities and evaluating previously classified business sectors. Input from these Ministries or Government Agencies constitutes a critical component in ensuring the accuracy and comprehensiveness of the classification system, as reflected in the number of proposed amendments to KBLI 2025 submitted by various Ministries and Government Agencies.
The coding structure under KBLI 2025 is as follows:
Section (Kategori), refers to the classification category of economic activities. This classification is assigned a single-digit alphabetical code.
Pursuant to Article 3 of BPS Reg. 7/2025, under KBLI 2025, all economic activities in Indonesia are classified into 22 categories (compared to 21 categories under KBLI 2020), ranging from Category A to Category V, which include:
Division (Golongan Pokok), each category is further broken down into one or more divisions based on the specific characteristics of the relevant division. Each division is assigned a two-digit numerical code representing the first two digits of the classification code.
Group (Golongan), constitutes a further breakdown of a division. The group code consists of three numerical digits, the first two digits indicate the relevant division, while the third digit identifies the specific economic activity within the respective group. For clarity, each division may be subdivided into a maximum of nine groups.
Sub-group (Subgolongan), represents a further specification of the economic activities encompassed within a group. The sub-group code consists of four numerical digits, the first three digits indicate the relevant group, and the fourth digit identifies the specific economic activity within the respective sub-group. Each group may be subdivided into a maximum of nine sub-groups.
Class (Kelompok), represents the most detailed classification level, comprising more homogeneous activities within a sub-group based on certain criteria. Each sub-group may be subdivided into a maximum of nine classes.
An illustration of the coding structure according to KBLI 2025 are as follows:
Further, KBLI 2025 also introduces changes to certain classification codes, implemented through two primary approaches, which is the “many-to-one” approach or code consolidation and the “one-to-many” approach or code splitting. In principle, the many-to-one approach consolidates multiple previous existing KBLI codes into a single new KBLI code, whereas the one-to-many approach divides a single previous existing KBLI code into several new KBLI codes.
Implications of the Joint Circular Letter on the Implementation of KBLI 2025
The issuance of the Joint Circular Letter provides guidance on the implementation of KBLI 2025 within the OSS system, the AHU system, and other relevant ministries and government agencies system integrated with OSS.
Under this Joint Circular Letter, it is clarified that all existing business licenses-including Basic Requirements (Persyaratan Dasar), Business Licenses (Perizinan Berusaha), and Business Licenses for Supporting Business Activities (Perizinan Berusaha untuk Menunjang Kegiatan Usaha)-that have been issued, verified, or approved prior to the implementation of KBLI 2025 shall remain valid and in full force and effect. The Joint Circular Letter further stipulates that adjustments to KBLI 2025 through amendments to the company’s articles of association are required only where there are corporate actions resulting in changes to the company’s purposes and objectives and/or its business activities, in accordance with the prevailing laws and regulations.
Conversely, no amendment to the articles of association is required where the adjustment is limited to a numerical code conversion based on the official conversion table, provided that there is no substantive change to the company’s purposes and objectives or the scope of its business activities. In such cases, the adjustment will be carried out automatically through the AHU and the OSS systems based on the applicable conversion table.
As noted above, the implementation of KBLI 2025 within the OSS and AHU systems will be carried out by the Ministry of Investment and Downstream Industry/Investment Coordinating Board and the Minister of Law no later than 18 June 2026. Until such implementation is completed, the OSS system will continue to process risk-based business licensing using KBLI 2020, and the AHU system will continue to process the legalization of business entities based on KBLI 2020.
An illustration of the implementation of KBLI 2025 adjustments under the Joint Circular Letter is as follows:
a. One-to-One Reclassification: where a business activity previously classified under a single KBLI 2020 code (e.g., 12345) is reclassified into a single KBLI 2025 code (e.g., 12347) the company is not required to amend its articles of association, provided that there is no change to the substance of its purposes and objectives or the scope of its business activities stated in its deed. In such case, the adjustment is limited to the KBLI code and may be implemented administratively through AHU system.
b. One-to-Many Reclassification: where a activity previously classified under a single KBLI 2020 code (e.g., 12345) is reclassified into multiple KBLI 2025 codes (e.g., 12346, 12347, and 12348), the company is not required to amend its articles of association, provided that the reclassification does not result in any substantive change or expansion of the existing business activity.
However, the relevant KBLI codes must remain aligned with the purpose and objective as stated in the company’s articles of association. If any of the reclassified business activities are not sufficiently covered under the existing purposes and objectives, the company must amend its articles of association accordingly.
c. Many-to-One Reclassification: where multiple KBLI 2020 codes (e.g., 12346, 12347, and 12348) are consolidated into a single KBLI 2025 code (e.g., 12345), the company is likewise not required to amend its articles of association, provided that there is no substantive change to the underlying business activities. In this scenario, the adjustment is limited to KBLI code. Nevertheless, the resulting classification must remain consistent with the company’s purposes and objectives. If the consolidated scope of activities is not adequately reflected in the articles of association, an amendment will be required.
Based on the foregoing, business actors are advised to conduct a comprehensive review of their current KBLI classifications against their actual business activities. This review should consider the alignment with the requirement of relevant ministries and government agencies, both within the OSS system and AHU system. Company should also assess whether the transition to KBLI 2025:
can be implemented automatically through the OSS and AHU systems based on the applicable conversion table; or
requires an amendment to the articles of association.
A clear and accurate understanding of the actual business activities of company remains critical to ensure that any adjustment is properly implemented and compliant with prevailing laws and regulations
For further information or consultation, please feel free to contact us.
Meilisa Husein (Partner) | meilisa@fknk.co.id
Lely Agustina Nugraheni (Associate) | lely@fknk.co.id
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