BALI BUSINESS CODES: What’s Actually Happening?

A Practical Business & Licensing Briefing by Lexeron Advocates

Running a business in Bali has never been only about choosing a company name, incorporating a PT PMA and obtaining an NIB. The business activities registered under a company, the KBLI classifications attached to those activities, the licences generated through OSS, and the way the business actually operates all need to remain aligned. Over the past several months, this has become increasingly important.

The implementation of KBLI 2025, changes within the OSS system, and the recent restrictions affecting certain foreign-investment activities in Bali have created a great deal of uncertainty for business owners, directors and investors. We regularly receive questions from existing PT PMAs asking whether their current business activities remain protected, whether a new activity can still be added, whether an old KBLI needs to be converted, or whether a proposed expansion may now require a different structure.

For businesses that have not yet been established, the questions can be even more fundamental. A business model that appears commercially simple may involve several different KBLIs, different levels of licensing risk, foreign-investment restrictions, or activities that cannot simply be placed under one PT PMA because they look similar commercially. This is why Lexeron Advocates is hosting, "BALI BUSINESS CODES: What’s Actually Happening?"

The event is not intended to be another long seminar explaining what KBLI stands for or reading regulations from presentation slides. We are organising it because these are issues our legal team is already dealing with in our day-to-day work with clients in Bali.

Why We Are Holding This Session

In our current practice, we have been assisting both existing businesses and new investors in navigating the changing licensing environment in Bali. Some clients already operate through established PT PMAs and need to understand how the new KBLI framework affects licences that were obtained years ago. Others are restructuring their businesses, adding activities, acquiring existing companies, opening new business lines or trying to determine whether an activity that was previously straightforward for foreign investment remains workable today.

We have also seen situations where the answer is not simply that a business activity is “allowed” or “not allowed.” The actual position can depend on when the company was established, what licences have already been issued, whether the activity is genuinely covered by those licences, how OSS treats the relevant KBLI transition, what the company is doing in practice, and whether the proposed expansion amounts to an entirely new business activity. That distinction matters.

A company that has been operating for several years may face a very different legal and regulatory position from a newly incorporated PT PMA attempting to register the same activity today. Similarly, changing a KBLI number because of the KBLI 2025 transition is not necessarily the same thing as adding a genuinely new line of business. These are the practical distinctions we want to discuss during the session.

What We Will Discuss

The briefing will cover the latest developments concerning KBLI 2025 and its practical implementation, together with the issues we are currently seeing around OSS, PT PMA licensing and Bali’s evolving approach to foreign-investment activities. We will discuss the position of new versus existing PT PMAs, what businesses should consider before adding or changing business activities, and how companies should approach the transition from older KBLI classifications into the new framework.

We will also look at an issue that is often overlooked: the difference between what a company is registered to do and what it is actually doing in practice. Having a KBLI listed in a corporate deed does not automatically mean that every corresponding activity is properly licensed through OSS. In the same way, an existing NIB does not necessarily answer whether a new commercial activity can simply be added without further analysis. The purpose of the discussion is therefore not only to explain the regulatory framework, but to help participants understand what they should actually be checking within their own businesses.

Practical Experience From Current Client Matters

A significant part of the session will be based on the practical issues Lexeron Advocates has encountered while advising businesses during the recent changes in Bali. We have been working with foreign-investment companies reviewing existing KBLI portfolios, businesses considering whether legacy activities should be preserved or converted, investors trying to establish new companies within the current restrictions, and clients whose commercial activities fall across several different regulatory classifications.

In some cases, the straightforward PT PMA route remains available. In others, the legal analysis becomes more complex and requires us to distinguish between the principal activity of the company, supporting activities, activities requiring another licence, and activities that may need to be carried out through a different legally compliant arrangement. We want participants to understand how those questions are approached in practice.

That does not mean there is one universal structure that works for every business. There is not. The appropriate solution depends heavily on the actual operating model, the parties involved, the location of the business, existing licences and the commercial objective. But there are often better questions to ask before restructuring a company, changing its licences, acquiring another business or investing further capital. Those are the questions we want participants to leave with.

30 Minutes of Insights. 30 Minutes for Your Questions.

The session will be led by:

Erik Maulidan, S.H., C.Med.
Managing Partner, Lexeron Advocates

and

Refnaldy Maulana, S.H., M.H.
Senior Lawyer, Lexeron Advocates

The first 30 minutes will be a focused briefing on the current KBLI, PT PMA, OSS and Bali business-licensing landscape. The following 30 minutes will be dedicated to open Q&A.

This is an important part of the event. We want business owners and investors to be able to bring the practical questions they are already facing. You may be considering adding a new activity, restructuring an existing company, acquiring another business, reviewing an old licence or simply trying to understand whether the way your business currently operates still aligns with its registered activities. While the session is not intended to replace matter-specific legal advice, it will give participants direct access to Lexeron's legal team and an opportunity to understand how we would approach these issues before deciding whether a more detailed review is necessary.

Who Should Attend?

This session is particularly relevant for PT PMA shareholders and directors, foreign investors, founders and business owners currently operating in Bali, as well as those planning to establish, acquire, expand or restructure a business in Bali. It may also be useful for businesses that were incorporated several years ago and have not recently reviewed whether their corporate purposes, OSS registrations, NIB, business licences and actual operations remain properly aligned.

If your business has changed since the company was first established, this is a particularly good time to understand what may need to be reviewed.