Indonesia’s foreign investment licensing system is currently undergoing big changes, especially for management consultancy business registration under KBLI 70209. This is a business category long used by foreign-owned companies. So, if you run or plan to establish a foreign-owned company in Indonesia, it’s important to understand these new rules. They reflect a nationwide push to tighten licensing, verify business activities more closely, and crack down on license misuse. While Bali is the clearest example of how they’re implemented, the changes signal a broader shift that applies across Indonesia.
What is KBLI 70209?
In Indonesia, every type of business activity is classified under a code called KBLI (Standard Classification of Indonesian Business Fields). Every company registered through Indonesia’s national online licensing system, OSS (Online Single Submission), must select one or more KBLI codes that describe exactly what it does. The code determines how much capital a company needs, what foreign ownership percentage is allowed, and which licenses apply, regardless of where the company is based in Indonesia.
KBLI 70209, officially called “Other Management Consultancy Activities,” is a broad category covering general business advisory work. Think strategy, operations, HR, marketing, and similar consulting services that don’t fall under a more specific code. Because the category is wide and was classified as low-risk, the management consulting KBLI became one of the easiest and most commonly used codes for foreign-owned companies, known as PT PMA (Perseroan TerbatasPenanaman Modal Asing), to register under when setting up a business in Indonesia.
The Latest KBLI Changes
The clearest case study so far comes from Bali, where the provincial Investment and One-Stop Integrated Service Office (DPMPTSP) proposed closing dozens of low-risk and low-medium-risk KBLI codes to foreign investment. The Ministry of Investment and Downstream Industry approved the request, and a total of 64 KBLI codes were blocked in the OSS system for that province. These codes were made up of 52 low-risk and 12 low-medium-risk categories. A related action closed access to 18 specific KBLI codes covering accommodation, vehicle rental, retail trade, and consultancy services, with 70209 named directly on that list.
What makes this relevant nationwide is the process behind it. A regional government identified a misused category, requested a national-level closure through the Ministry of Investment, and received approval to restrict OSS access. Other provinces or cities facing similar pressure from foreign-backed businesses could follow this approach, using KBLI 70209 and related closures as a precedent.
For any PT PMA using or considering KBLI 70209, the result is the same regardless of location. Anyone researching management consultancy business registration in Indonesia today needs to check current restrictions before assuming this classification is still available.
The Reason Behind the Change
The government made this move because evaluation teams found repeated cases of foreign companies holding a license for one activity while operating an entirely different business in practice. There are cases where companies licensed for virtual office services were actually renting out motorbikes, and where real estate permits were being used for activities not permitted under foreign investment rules.
This pattern reflects a broader national concern, which is the use of “nominee” arrangements, where foreign investors use easy-to-obtain licenses to bypass ownership restrictions or capital requirements in sectors reserved for local enterprises. Closing frequently misused categories makes these workarounds harder without targeting legitimate investment.
The move also aligns with Indonesia’s broader licensing overhaul under Government Regulation No. 28 of 2025 on Risk-Based Business Licensing. The regulation introduced stricter verification for NIB (Nomor Induk Berusaha) issuance, replacing the previous system where licenses could be generated automatically through OSS with minimal review. Now, licenses can be revoked if business activities don’t match registered classifications or violate spatial planning rules, providing the legal basis for province-level actions like Bali’s.
Impact on Existing Companies
For companies already registered under KBLI 70209, existing licenses in unrestricted regions remain unaffected, and Bali licenses aren’t automatically cancelled. However, authorities are now paying closer attention to whether actual business activities match the scope of management consultancy and whether companies seek new approvals or expansions under the restricted code. Future OSS submissions may need to use a different, more suitable KBLI classification.
Companies should also review immigration arrangements if foreign employees hold Investor KITAS linked to a KBLI 70209 business, as sponsorship documents typically reference the underlying business license. For new registrations, the safest approach is to choose a KBLI code that accurately reflects the company’s activities, confirm regional restrictions, and prepare for stricter verification before approval. Getting this right from the start makes management consultancy business registration in Indonesia far smoother than trying to fix a mismatched KBLI code later.
Investment is Still Welcome
It’s important to note that this policy isn’t aimed at discouraging foreign investment. Bali’s 2026 investment target remains around Rp 47.93 trillion from both foreign and domestic sources. By Q1 2026, realized investment had reached Rp 13.31 trillion, including Rp 9.04 trillion in foreign investment. Officials expect the stricter licensing rules to have limited impact, as the goal is improving investment quality rather than reducing overall capital inflows.
The broader message from Indonesian authorities is that legitimate, correctly structured investment remains welcome across the country. What’s being closed off is the narrow set of loopholes that let some foreign-backed businesses operate in spaces intended for local micro, small, and medium enterprises. For serious investors, the shift points toward a more predictable and transparent licensing system nationwide, provided the paperwork matches the reality on the ground.
Before registering a new PT PMA or expanding an existing one, it’s important to check the current list of restricted KBLI codes for the specific region. You should also confirm that your chosen classification genuinely reflects your business activities. Since the list can change at the provincial level with national approval, and OSS applications are now subject to stricter verification against local policies, working with a licensed notary or investment consultant is the safest approach. They can help you navigate management consultancy business registration in Indonesia and avoid delays, rejected applications, or compliance issues later on.
Is KBLI 70209 closed to foreign investment across all of Indonesia?
No. The closure only applies where regional governments have obtained approval to restrict it, with Bali being the clearest confirmed case.
What happens if a company wants to add or change business activities under a restricted code?
Any new OSS filing must be structured under a KBLI code that isn’t restricted in that region. This often means selecting a more specific or alternative classification.
How can a foreign investor find out if a KBLI code is restricted before applying?
Check with the local DPMPTSP office or the OSS system, as restrictions vary by province. You can also consult a licensed notary or investment consultant before filing.
Learn more about other KBLI restrictions in Why are Some KBLI Codes Restricted for Foreign Investors.
