Indonesia's positive investment list: open sectors, closed sectors and the Bali exception

It is Presidential Regulation 10/2021 on investment business fields, signed on February 2, 2021 and in force from March 4, 2021. It replaced the 2016 negative list, which restricted twenty activities. The logic flipped: a sector is open unless the regulation closes or conditions it.

Open sectors fall into four groups. Priority sectors get incentives. Some sectors belong to cooperatives and small businesses, or admit foreigners only as their partners. A further group carries special conditions. Everything else is open. The category counts differ between law-firm summaries (245 or 246 priority sectors), so check the appendix for your own code.

Source: Perpres 10/2021, peraturan.bpk.go.id (signed February 2, 2021; in force March 4, 2021); PwC Omnibus Flash, 2021; CMS, February 2021

Six. Perpres 10/2021 closes cultivation and manufacture of class 1 narcotics, gambling and casinos, fishing of species listed under CITES, harvesting of coral and sea rock for building materials or souvenirs, chemical weapons, and the industrial chemicals and ozone-depleting substances sector.

Perpres 49/2021, signed on May 24, 2021, added alcohol production (KBLI 11010, 11020 and 11031). The first regulation had left it open in four provinces, Bali among them. Hotels, villas, restaurants and property aren't on the closed list. Their limits come through business-code conditions, licensing and, now, provincial rules.

Source: Perpres 10/2021 and 49/2021, peraturan.bpk.go.id; PwC Omnibus Flash, 2021; Tempo, June 2021

Foreign investors operate through a PT PMA. BKPM Regulation 5/2025, issued on October 1, 2025, set its minimum paid-up capital at Rp 2.5 billion in cash, down from Rp 10 billion. The money has to stay in the company's bank account for 12 months, except for assets, construction and operating costs.

A second test sits beside it. Planned investment has to exceed Rp 10 billion per five-digit KBLI code and project location, and land and buildings normally don't count. Two law firms say property, accommodation, farming and similar sectors may count them. Firms also split on the capital rule itself. Three read the Rp 2.5 billion per company, and one reads it per business activity. We follow the majority, and the regulation's own text governs.

Our PT PMA guide prices the company for a villa buyer, and business in Indonesia for foreigners covers what investors do beyond villas.

Source: Emerhub, SSEK, Withers and A&O Shearman on BKPM Regulation 5/2025, October 2025

A KBLI code is the five-digit number that tells the OSS licensing system what a company does. Each code carries a risk level and its own conditions, and the positive list works code by code. Pick the wrong one and registration fails.

Codes changed recently. BPS Regulation 7/2025, enacted on December 18, 2025, replaced the 2020 classification with KBLI 2025, and companies had until June 18, 2026 to align their registrations. Government Regulation 28/2025 on risk-based licensing, which replaced GR 5/2021, sits underneath. So a code quoted in an older article may have moved.

Source: BPS Regulation 7/2025, via Hogan Lovells and Emerhub; Government Regulation 28/2025, via ASEAN Briefing and XPND

Antara Bali reported on July 23, 2026 that the provincial government had announced a bar on new PT PMA licenses in 18 business fields. The restriction had been in force since the third week of May, when OSS began rejecting new foreign applications with a Bali address in the listed low-risk codes. Existing licenses stay valid, and those companies must keep filing their LKPM activity reports. The stated aim is to protect local small businesses from unfair competition.

Reports disagree on the scope. The governor's January 28, 2026 letter named nine problem codes. One consultancy lists seven under review. Antara Bali printed 18. Emerhub reports OSS rejecting every low and medium-low risk code for a Bali address, while medium-high and high-risk codes stay open. Treat the table as the public list and test your own code in OSS. The codes follow the 2020 numbering, so check the KBLI 2025 equivalent.

Source: Antara Bali, July 23, 2026; Emerhub, Bali PMA licensing closure, 2026; Let's Move Indonesia, 2026

A purchase in your own name, such as a lease or a right-to-use title, isn't a company registration, so the closure doesn't touch it. That is our reading, not a ruling. The routes open to foreign buyers are laid out in one table.

The closure bites when you plan to hold the villa in a new PT PMA. Real estate (68111), star hotels and other accommodation codes are on the list. A company registered before May keeps its license, and a new one may need another code. Ask a licensed consultant which code OSS accepts for your plan. We don't register companies. If the villa will let by the night, the rental license guide explains the NIB, and our zoning guide covers the plot.

Source: Rise Real Bali reading of Antara Bali, July 23, 2026, and BKPM Regulation 5/2025

Work in order, and start from the code, not the business name. First, find the KBLI 2025 code that matches what you will actually do. Then read its OSS entry for the risk level and conditions. Third, compare it with the national closed list and, if your company's address is in Bali, with the 18 codes in the table above.

Fourth, test your numbers, meaning paid-up capital against Rp 2.5 billion and planned investment against Rp 10 billion. Last, check which zone the plot sits in under the detailed spatial plan, because a permitted activity still needs permitted land. The zoning guide explains how to read that plan. Keep the OSS screenshots with your records.

Source: BKPM Regulation 5/2025; Rise Real Bali checklist

Probably. Presidential Decree 38/2025, dated December 22, 2025, started a one-year process to draft a new regulation on investment sectors. It covers incentive criteria, sectors reserved for small businesses, those with foreign-capital limits and the alcohol sector.

An official at the Coordinating Ministry for Economic Affairs was quoted in March 2026 saying the revision should finish in the second half of the year. As of October 3, 2026, we found no published replacement, so Perpres 10/2021 as amended still governs. Recheck the text on the day you register. If you're comparing destinations, Bali against Dubai sets ownership rules side by side.

Source: Keppres 38/2025, via DDTC, February 3, 2026; Bisnis.com, March 4, 2026

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