In accordance to the implementation of KBLI 2025 as stipulated in Government Regulation No. 28 of 2025 concerning the Administration of Risk-Based Business Licensing (“GR 28/2025”), the Minister of Investment and Downstream Industry/Head of the Investment Coordinating Board, the Minister of Law, and the Head of the Central Statistics Agency have issued a Joint Circular Letter concerning the Implementation of the 2025 KBLI Adjustment in Risk-Based Licensing (2026).

The Circular Letter mentioned that the integration of KBLI 2025 into the Online Single Submission (“OSS”) System will be completed no later than 18 June 2026. Until full integration is achieved, the OSS system will continue to process business classifications using KBLI 2020. Accordingly, business actors are required to align their business classifications with the prevailing laws and regulations.

Nevertheless, the Circular Letter also introduces certain exceptions. Business actors are not required to manually adjust their KBLI classifications where the changes are purely numerical and do not affect the substance of their business activities, as such updates will be automatically reflected in the OSS system. However, where the registered KBLI codes have materially changed and no longer correspond to the company’s actual business activities, the company is required to update its KBLI classifications accordingly. In addition, any business licenses issued prior to the implementation of KBLI 2025 shall remain valid, provided that they are still within their respective validity periods.

From a legal certainty perspective, in the event of discrepancies between the KBLI codes stated in the company’s Articles of Association and those recorded in its Business Identification Number (Nomor Induk Berusaha or “NIB”), amendments to the Articles of Association are not mandatory as long as the company’s purpose, activities, and business scope remain unchanged. However, if during the future licensing processes require consistency between the NIB and the Articles of Association, the company will need to amend its Articles of Association accordingly.

If you, a prospective client, have further inquiries about the topic discussed above, Schinder Law Firm is one of many corporate law firms in Indonesia that has handled numerous similar matters, with many experienced and professional corporate and civil lawyers in its arsenal, making it one of the top consulting firms in Indonesia. Feel free to contact us at info@schinderlawfirm.com for further consultation.

Author:
Dewi Susanti