Indonesia is transitioning from the Indonesian Standard Industrial Classification (KBLI) 2020 to KBLI 2025, as mandated under Central Bureau of Statistics Regulation No. 7 of 2025 ("BPS Regulation 7/2025"). This update forms part of the broader regulatory framework for Risk-Based Business Licensing (PBBR) administered through the OSS system.

The transition is supported by a Joint Circular Letter dated 25 March 2026, issued by the Minister of Investment and Downstream Industry/Head of BKPM, the Minister of Law, and the Head of BPS.

Legal Timeline

Under Article 5 of BPS Regulation 7/2025, the updated KBLI must be implemented no later than six (6) months after issuance, with full effectiveness starting 18 June 2026.

Until that date, the system remains in a transitional phase.

Key Legal Mechanisms Behind the Transition

1. Government Discretion in Licensing

   Under Article 545 of Government Regulation No. 28 of 2025, government authorities may exercise discretion in cases of regulatory gaps, ambiguity, or administrative stagnation in the implementation of PBBR.

2. Automatic System Adjustment

   Under Article 393 of Minister of Investment Regulation No. 5 of 2025, any update to KBLI issued by BPS will be automatically reflected in the OSS system, ensuring alignment between classification and licensing data.

Transitional Legal Position

During the transition period, the following applies:

• All business licenses (Basic Requirements, Business Licenses, and Supporting Business Licenses) issued, verified, or approved prior to KBLI 2025 implementation remain valid.

• Companies registered in the AHU system are required to adjust KBLI only if there is a change in business purpose and activities that requires an amendment to the Articles of Association.

• Where changes are purely numerical adjustments under the official conversion table and do not affect substantive business activities, no amendment is required, and updates will be made automatically through OSS and AHU systems.

• Full implementation of KBLI 2025 across OSS and AHU must be completed by 18 June 2026.

• Until implementation, OSS and AHU will continue using KBLI 2020.

• Technical conversion will follow the official annexes of the Joint Circular Letter.

•  business licenses issued based on KBLI 2020 remain valid until:

  • There is a change in the company’s purpose and objectives, requiring amendment of the Articles of Association; or

  • A specific regulation mandates migration to KBLI 2025 for the Business Actor holds KBLI 2020 for the business licenses; or

    
    

Conclusion

The implementation of KBLI 2025 is structured as a gradual and system-based transition. Existing businesses and new incorporations during the transitional period remain governed by KBLI 2020, unless legal or structural changes require otherwise.