As previously the Indonesian Standard Industrial Classification 2025 (“KBLI 2025”) has been introduced on December 2025 under BPS 7/2025, currently Indonesia has updated its implementation of KBLI 2025 and the transition update within the Online Single Submission (“OSS”) system. As of 27 March 2026, we note that currently the Ministry of Investment and Downstreaming/BKPMhas issuedthe Joint Circular Letter No. B-69.S/PI.08/A.1/2026 dated 27 March 2026 (“SEB KBLI 2025”) to introduce a new OSS adjustment mechanism to facilitate the transition toward KBLI 2025. Accordingly, this Legal Alert will discuss on: (i) the new OSS adjustment mechanism introduced under SEB KBLI 2025; and (ii) several practical challenges encountered by business actors in the implementation process.
The general overview on the update on KBLI 2025 adjustment practices are as follows:
Under the SEB KBLI 2025, OSS has issued implementation guidance for KBLI 2025 adjustments, including the introduction of conversion mechanisms categorized as One-to-One, One-to-Many, and Many-to-One adjustments, aimed at providing further clarification for business actors, with the following overview:
The relevant KBLI code remains unchanged, and no adjustment is required. The refinement generally involves updates to the title, additional descriptions or business scope, and/or recoding adjustments.
A KBLI code is divided into several new KBLI codes, either to separate business scopes based on regulatory authority or to align with the latest International Standard Industrial Classification of All Economic Activities (“ISIC”) structure. Such division may occur within the same category or across different categories.
Multiple KBLI codes are consolidated into a single KBLI code to align with the updated ISIC structure and current business developments. This consolidation is generally intended to simplify the classification process for business actors.
Further, pursuant to Point 5(d)(3) of SEB KBLI 2025, businesses with changes to KBLI strictly to its numbers with no alter on the substance, intent, or scope of the existing business activities, are no longer required to conduct manual adjustments. Further, it is stated that the Directorate General of General Law Administration (“Ditjen AHU”) and the OSS system will perform these adjustments automatically using a conversion table
On the other hand, where the system is unable to automatically convert the business actor’s KBLI codes, particularly due to changes in the substance, purpose, or scope of the relevant business activities, the OSS system will issue a notification to the business actor as stipulated under Attachment I of SEB KBLI 2025. In such cases, the business actors will be required to manually amend its Articles of Association through the AHU system, which adjustment will subsequently be reflected in the OSS system.
Although SEB KBLI 2025 introduces new adjustment mechanisms, Point 5(d)(1) of SEB KBLI 2025 ensures certainty by maintaining the validity of any previously issued or approved PD, PB, or PB UMKU. Furthermore, under Points 5(d)(4) and (5) of SEB KBLI 2025 and Article 5 of BPS 7/2025, the OSS and AHU systems will continue processing KBLI 2020 codes during the transition; however, all users must adjust to KBLI 2025 by June 2026 (six months from BPS 7/2025 enactment).
Notwithstanding the issuance of SEB KBLI 2025 and other supporting regulations, the implementation of KBLI 2025 adjustments remains subject to several practical challenges, particularly as the adjustment and system refinement process is still ongoing. In practice, certain KBLI classifications have undergone changes, consolidations, or divisions, requiring business actors to reassess the alignment of their business activities with KBLI 2025. Further, although business actors have gradually been encouraged to conduct adjustments through the OSS system, certain KBLI 2025 adjustments may not yet be fully available or reflected in some OSS accounts during the current transition process. The implementation of an automatic adjustment mechanism to KBLI 2025 as explained above also remains unclear, as the OSS system has not yet adopted KBLI 2025 to date.
While waiting on the full implementation of KBLI 2025 adjustments within the OSS system, business actors may start reviewing changes from KBLI 2020 to KBLI 2025, assess the relevance of their existing KBLI classifications to their current business activities, and evaluate the impact on their existing licenses and related approvals. This is particularly important because once the KBLI 2025 adjustment process becomes fully available within the OSS system, business actors who fail to conduct the necessary adjustments may result in invalid NIB data, operational constraints, and possible rejection of licensing processes within the OSS system, particularly where there are changes to the applicable business risk level or business activity scope.
To ensure compliance with KBLI 2025 and mitigate risks, business actors shall take proactive steps including: (i) Monitor their OSS accounts for further adjustment of KBLI 2025; (ii) Reassess and map their existing business activities to adjust with KBLI 2025; (iii) Evaluate any impact from the changes on business licensing and risk levels under the OSS RBA Framework; (iv) update any license, and corporate data in the OSS system, if necessary; and (v) monitor further technical guidelines issued by relevant regulators.
Additionally, please also note that the regulatory framework may not always be implemented seamlessly in the system which is newly developed under this SEB KBLI 2025. Accordingly, companies should carefully monitor the regulation issued by relevant regulators and consider the practice implementation, to avoid any potential inconsistencies or issues.
Should you require any further clarification or assistance in relation to the above matters, please do not hesitate to contact us. We would be happy to support you in addressing any related inquiries and provide you with necessary assistance.
