KBLI 2025 has changed how Indonesian companies classify real estate development, property rental, brokerage, property management and short-term accommodation activities.

For existing property companies, the change does not automatically mean obtaining a new NIB, replacing every business licence or amending the company’s deed.

The correct action depends on whether the transition:

• Changes only the KBLI number.
• Narrows or expands the activity’s description.
• Splits one previous code into several new codes.
• Introduces a genuinely new business activity.
• Creates a mismatch between the company’s deed, AHU record, OSS profile and actual operations.

This distinction is especially important for companies that previously used KBLI 68111, because the numerical code remains in KBLI 2025 while its meaning has changed substantially.

What is KBLI 2025?

KBLI stands for Klasifikasi Baku Lapangan Usaha Indonesia, or Indonesia Standard Classification of Business Fields.

The classification identifies the economic activities conducted by an Indonesian business. KBLI codes are used across:

• Company establishment and corporate deeds.
• AHU corporate administration.
• Investment registration.
• The OSS risk-based licensing system.
• NIB issuance.
• Business licences and standard certificates.
• Government statistical reporting.
• Certain sector-specific approvals.

Statistics Indonesia Regulation No. 7 of 2025 introduced KBLI 2025 and revoked KBLI 2020. The regulation became effective on 18 December 2025 and gave existing users six months to adjust. Statistics Indonesia Regulation No. 7 of 2025

The six-month adjustment period ended on 18 June 2026. New applications, company changes and licensing processes should now be assessed using KBLI 2025.

What changed for the real estate sector?

Under KBLI 2025, real estate activities are classified under Category M.

The category covers activities such as:

• Buying and selling real estate.
• Residential property development.
• Leasing property owned or leased by the business.
• Operating certain properties.
• Real estate brokerage and intermediation.
• Property appraisal.
• Property management for another owner.
• Other real estate services performed under a fee or contract.

However, construction and accommodation are treated separately.

A property developer, construction contractor, long-term landlord, villa operator, broker and property manager may all work with property, but they do not necessarily perform the same KBLI activity.

The correct code must follow what the company actually does.

Does every company have to update to KBLI 2025?

Existing companies must ensure their registered activities are aligned with KBLI 2025.

That does not mean every company must:

• Establish a new legal entity.
• Obtain a completely new NIB.
• Replace every existing licence.
• Amend its deed.
• Add every possible replacement code.

Government implementation guidance confirms that existing business licences and supporting licences issued, verified or approved before the implementation of KBLI 2025 generally remain valid. Statistics Indonesia’s KBLI implementation announcement

The update process depends on the relationship between the previous code and the new classification.

The five types of KBLI conversion

The official OSS conversion system recognises five general conversion patterns.

1. Unchanged one-to-one conversion

One KBLI 2020 code maps to the same numerical code in KBLI 2025.

The company must still compare the descriptions. An unchanged number does not always mean the scope is unchanged.

KBLI 68111 is the most important example of this risk.

2. Changed one-to-one conversion

One KBLI 2020 code maps to one different KBLI 2025 code.

If the underlying business activity remains the same, the change may be treated as a non-substantive numerical conversion.

3. One-to-many conversion

One KBLI 2020 code is divided into several more specific KBLI 2025 codes.

The business must select the new code or codes that match its actual activities. It should not automatically select every available descendant code.

4. Many-to-one conversion

Several previous codes are consolidated into one KBLI 2025 code.

The company should confirm that the consolidated description still covers every activity it conducts.

5. Many-to-many rearrangement

Several previous classifications are reorganised across several new codes.

This requires a careful comparison of the old activities, new descriptions and the company’s actual operations.

The official mappings can be reviewed through the OSS KBLI conversion tool.

Does updating KBLI 2025 require a notarial deed?

A KBLI 2025 conversion does not always require a deed amendment.

The main question is whether the change is substantive.

When a deed amendment may not be required

A notarial amendment should not be required solely for a numerical conversion when:

• The underlying activity remains the same.
• The company does not expand its business.
• The new description still falls within the purposes authorised by its articles.
• The conversion does not introduce a new line of business.
• The company’s actual operations remain unchanged.

In this situation, AHU and OSS may process the conversion automatically or through a system-assisted procedure.

The company should still retain evidence of the conversion and verify the resulting AHU and OSS records.

When a deed amendment is normally required

Shareholder approval and a notarial deed will normally be required when the conversion involves:

• Adding a new business activity.
• Expanding the company’s authorised purposes.
• Moving into a materially different business.
• Selecting a replacement code outside the existing articles.
• Changing from property ownership or leasing to accommodation operation.
• Adding development, brokerage or property management activities that were not previously authorised.

Under Ministry of Law Regulation No. 49 of 2025, changes to a company’s purposes, objectives or business activities require Ministerial approval through the AHU system. Ministry of Law Regulation No. 49 of 2025

The shareholder resolution must be recorded in an Indonesian notarial deed and filed within the applicable corporate filing period.

Can the KBLI update be approved at the annual RUPS?

Yes, if a substantive amendment is required.

A company can include the proposed KBLI and business-purpose amendment as a separate agenda item at its annual RUPS, or RUPST.

The annual-report approval and KBLI amendment remain separate corporate decisions.

An amendment to the articles is subject to the quorum and voting requirements for articles amendments. Article 88 of the Company Law generally requires:

• At least two thirds of voting shares to be present or represented.
• Approval from at least two thirds of the votes cast.

The company’s articles may impose a stricter requirement. Law No. 40 of 2007 on Limited Liability Companies

A unanimous written shareholder resolution outside a meeting may also be possible where the requirements of the Company Law are satisfied.

Combining the KBLI amendment with the RUPST can be efficient, but a company should not amend its deed merely because its code was converted numerically.

KBLI 68111 has changed meaning

KBLI 68111 is a major issue for Indonesian property companies.

Under KBLI 2020, code 68111 was titled:

‍Real Estat Yang Dimiliki Sendiri atau Disewa

The description broadly covered real estate owned or leased by the business.

Under KBLI 2025, the same numerical code is titled:

Aktivitas Pengembangan Bangunan dan Lahan Hunian

It now focuses on residential building and land development, including residential development projects intended for sale.

The official OSS converter displays 68111 as an unchanged one-to-one conversion because the number remains the same. However, the old and new descriptions are materially different. Official OSS conversion result for KBLI 68111

This means a company should not retain 68111 automatically merely because the number appears unchanged.

A company that develops houses or apartments for sale may still fit within 68111.

A company that owns completed residential property and rents it to tenants may need 68112 instead.

A company that operates villas as short-term tourist accommodation may need an accommodation code under Category 55.

Important KBLI 2025 real estate codes

KBLI 68111

Residential building and land development

This code covers the development of residential property, including houses, flats and apartments, as well as residential projects developed for sale.

It is primarily relevant to developers rather than passive landlords or short-term accommodation operators.

KBLI 68112

Leasing residential buildings and land owned or leased by the business

This code is relevant where a company owns or leases residential real estate and makes it available under a residential leasing model.

It may apply to longer-term rentals of:

• Houses.
• Apartments.
• Residential units.
• Residential land.

It should not automatically be used for daily or weekly accommodation involving hospitality services.

KBLI 68121

Tourism-area management

This code concerns the management of a tourism area.

It does not, by itself, replace the activity code required to operate an individual hotel, villa or other accommodation business inside that area.

KBLI 68124

Leasing buildings and land for MICE activities

This code applies to property used for meetings, incentives, conferences, exhibitions and related events.

Under the 2025 reorganisation, it replaces the previous placement of this activity under code 68112.

KBLI 68125

Shopping-centre management

This code is relevant to the management or operation of shopping-centre real estate.

KBLI 68126

Warehouse and self-storage leasing

This classification covers warehouse, storage and self-storage property activities.

KBLI 68127

Office-building management

This code is relevant to the management or operation of office-building real estate.

KBLI 68129

Other non-residential real estate owned or leased

This is a residual classification for non-residential ownership or leasing activities that do not fall under a more specific 6812 classification.

It should be used only after checking whether a more specific code covers the property.

KBLI 68210

Real estate intermediation

This code covers intermediary activities such as:

• Real estate agencies.
• Property brokers.
• Transaction intermediation.
• Property listings.
• Digital and non-digital intermediation.

A company that introduces buyers and sellers or earns a transaction commission may require this code rather than a property ownership code.

KBLI 68291

Real estate appraisal

This code applies to property valuation and appraisal activities.

Professional and sector requirements may apply in addition to the KBLI classification.

KBLI 68292

Residential property management for a fee or contract

This code applies when a company manages residential property for another owner.

It differs from 68112:

• Under 68112, the company leases or operates residential property that it owns or leases.
• Under 68292, the company manages residential property for somebody else in exchange for a fee.

KBLI 68299

Other real estate activities for a fee or contract

This residual service classification may cover activities such as:

• Rent collection.
• Certain non-residential property management.
• Real estate consultancy.
• Other contract-based real estate services not classified elsewhere.

What happened to KBLI 68200?

Under KBLI 2020, code 68200 broadly covered real estate activities performed under a fee or contract.

KBLI 2025 separates that activity into more specific functions:

• 68210: Real estate intermediation.
• 68291: Real estate appraisal.
• 68292: Residential property management.
• 68299: Other real estate activities under a fee or contract.

A company previously registered under 68200 must identify which services it actually performs.

For example:

• A broker should review 68210.
• A valuer should review 68291.
• A residential property manager should review 68292.
• A company collecting rent or managing non-residential property may need to assess 68299.

The company should not select all four codes unless it genuinely conducts and is authorised to conduct all four activities.

Is a villa rental a real estate activity or accommodation activity?

It depends on the operating model.

A long-term residential lease and a short-term villa stay are not necessarily the same business activity.

A company operating daily or weekly tourist accommodation may need a Category 55 accommodation code rather than, or in addition to, a real estate code.

Relevant KBLI 2025 accommodation codes include the following.

KBLI 55203

Villa accommodation

This code covers short-term accommodation in private houses specifically rented to tourists, generally on a daily or weekly basis.

It is likely to be more relevant than 68112 when the property is marketed and operated as tourist accommodation.

KBLI 55201

Homestay accommodation

This code concerns short-term accommodation within an owner-occupied home, where part of the home is offered to guests and interaction with the owner forms part of the model.

Calling every small villa or guesthouse a homestay does not make the activity fall within 55201.

KBLI 55204

Apartment hotel accommodation

This code covers short-term apartment accommodation operated with hotel-like or serviced-apartment characteristics.

KBLI 55209

Other short-term accommodation

This residual code may apply to short-term accommodation that does not fit a more specific classification.

KBLI 55901

Accommodation management services

This code is relevant where a third-party operator manages accommodation on behalf of the owner and receives a management fee.

KBLI 55400

Accommodation intermediation

This activity covers businesses that connect guests with accommodation providers, including certain agency or platform-based models.

How to select the correct code for a villa business

The company should examine the actual operation rather than the name used in its marketing.

Relevant questions include:

1. Is the property rented daily, weekly, monthly or annually?
2. Are cleaning, reception, breakfast, concierge or guest services provided?
3. Is the property marketed to tourists?
4. Does the company own, lease, manage or only market the villa?
5. Who signs the contract with the guest?
6. Who receives the accommodation revenue?
7. Does the company receive rent, a management fee or a brokerage commission?
8. Is the villa operated by its owner or by a separate management company?
9. Does local zoning allow tourist accommodation?
10. Which tourism, building and operational approvals apply?

Depending on the answers, a villa project may involve different activities:

• Property ownership or leasing.
• Accommodation operation.
• Third-party property management.
• Accommodation management.
• Brokerage or booking intermediation.

One KBLI code should not be used to conceal several materially different activities.

Example KBLI scenarios

Residential developer selling completed units

A company acquires or controls land, develops houses or apartments and sells the completed units.

Likely starting point: 68111.

Construction work itself may require separate construction classifications and licences if performed by the same company.

Company renting apartments to long-term tenants

A company owns or leases completed residential units and rents them under residential tenancy agreements.

Likely starting point: 68112.

The company must still check its investment eligibility, land rights, zoning and other applicable conditions.

Company operating a nightly rental villa

A company accepts short-term bookings, receives guests and provides accommodation services.

Likely starting point: 55203, subject to the actual operating model and local requirements.

A general real estate leasing code may not be sufficient.

Company managing villas for other owners

A company manages residential properties for owners and receives a management fee.

Possible starting points:

• 68292 for residential property management.
• 55901 where the company takes responsibility for accommodation operations.

The correct classification depends on whether the company manages the real estate, operates the accommodation business, or performs both functions.

Property agency earning sales commissions

A company markets properties, introduces buyers and sellers, and earns a transaction commission.

Likely starting point: 68210.

Property ownership or development codes do not automatically authorise brokerage activity.

KBLI does not replace other property approvals

A correct KBLI is only one component of compliance.

It does not replace or prove:

• Ownership of the land.
• Validity of the land certificate.
• Eligibility to hold the land right.
• Spatial conformity or zoning.
• Environmental approval.
• Building approval.
• Certificate of proper function.
• Tourism licensing.
• Tax compliance.
• Foreign-investment eligibility.
• Compliance with local operating restrictions.

For example, a company may hold KBLI 55203 for villa accommodation but still be unable to operate a particular villa if the site is not zoned for tourist accommodation.

Similarly, a company may legally hold an HGB title while lacking the KBLI and operational approvals required to generate revenue from the property.

Corporate, land, spatial, building and operating compliance must be reviewed separately.

KBLI 2025 update process

An existing company can use the following process.

Step 1: Collect the current records

Obtain:

• The latest deed and articles.
• All amendments.
• Current AHU company profile.
• Current NIB.
• Full OSS business-activity profile.
• Existing licences and standard certificates.
• Project-location records.
• Relevant contracts and revenue descriptions.

Step 2: Identify every old KBLI

Create a list of all activities appearing in:

• The company’s deed.
• AHU.
• NIB.
• OSS.
• Investment reports.
• Sector licences.

Any inconsistencies should be recorded before data is changed.

Step 3: Use the official conversion tool

Enter each old code into the official OSS converter.

Record whether the conversion is:

• One-to-one.
• One-to-many.
• Many-to-one.
• Many-to-many.
• Numerically unchanged but substantively revised.

The converter is an important reference, but it should not be treated as a substitute for reading the descriptions.

Step 4: Compare the old and new descriptions

Review:

• Activities expressly included.
• Activities expressly excluded.
• Changes in property type.
• Changes between ownership, rental, management and operation.
• Changes between real estate and accommodation.
• Whether the new code is broader or narrower.

Step 5: Compare the description with actual operations

Review the company’s:

• Contracts.
• Invoices.
• Revenue sources.
• Marketing.
• Property portfolio.
• Length-of-stay model.
• Management responsibilities.
• Customer relationships.

The correct classification is determined by the actual business activity.

Step 6: Decide whether the change is substantive

If the activity remains substantively unchanged, use the available automatic or system-assisted conversion route.

If the company changes or expands its purpose or activities, arrange the necessary shareholder approval and notarial deed.

Step 7: Update AHU before OSS when necessary

Where a deed amendment is required, the corporate purpose and activities should first be approved and recorded through the notary and AHU process.

The company can then align its OSS and NIB records.

Companies still using KBLI 2009 or KBLI 2017 may need to update through their notary and AHU before continuing the OSS conversion.

Step 8: Review licensing consequences

Check whether the new code affects:

• Risk classification.
• Standard certificates.
• Business licences.
• Licences supporting business activities.
• Environmental requirements.
• Spatial requirements.
• Investment commitments.
• Project-location records.

Step 9: Reconcile the completed records

After the conversion, compare:

• The deed.
• AHU profile.
• NIB.
• OSS activity list.
• Business licences.
• Actual operations.

The records should consistently describe the same business.

Common KBLI 2025 mistakes

Assuming the same number means the same activity

KBLI 68111 demonstrates why this is dangerous. The number remained, but the description changed materially.

Selecting every replacement code

A one-to-many mapping does not authorise the company to select every descendant activity automatically.

The company should select only activities it genuinely conducts and is legally authorised to conduct.

Updating OSS without checking the deed

Adding a code in OSS does not necessarily amend or expand the purposes authorised by the company’s articles.

Where the activity is outside the existing corporate purpose, shareholder approval and a notarial amendment may be required.

Treating all villa rentals as real estate leasing

Daily or weekly tourist accommodation can fall under Category 55 rather than long-term residential leasing.

Treating the NIB as a complete operating licence

An NIB establishes the business’s registration identity and can serve additional licensing functions depending on risk level. It does not automatically satisfy every standard certificate, sector licence, spatial requirement or building approval.

Ignoring project locations

A company may hold the correct KBLI but have incomplete or inaccurate OSS project-location records.

This can create problems when the company applies for location-specific licences or approvals.

Confusing property management with accommodation operation

Managing a property for an owner and operating it as guest accommodation are distinct functions.

The company may need to assess 68292, 55901 or another relevant code based on its responsibilities and revenue model.

Documents a property investor should verify

A buyer, shareholder or investor reviewing an Indonesian property company should request:

• Current deed and articles.
• All notarial amendments.
• Ministerial approvals and filing receipts.
• Current AHU profile.
• NIB and complete OSS profile.
• KBLI 2020-to-2025 conversion records.
• All active business licences.
• Standard certificates.
• PB-UMKU or licences supporting business activities.
• Project-location information.
• Property ownership or lease documents.
• Management and operational contracts.
• Tourism licences where applicable.
• Building and spatial approvals.

The objective is to confirm that the company’s legal documents, licences and actual business model are aligned.

Frequently asked questions

Is KBLI 2025 mandatory?

Yes. KBLI 2025 replaced KBLI 2020 and is now the current business-activity classification for new and updated corporate and licensing processes.

When did KBLI 2025 take effect?

KBLI 2025 took effect on 18 December 2025. The six-month adjustment period ended on 18 June 2026.

Did existing business licences expire on 18 June 2026?

No. Government implementation guidance states that existing licences issued, verified or approved before KBLI 2025 generally remain valid.

Does every PT PMA need to amend its deed?

No. A deed amendment is generally unnecessary for a purely numerical, non-substantive conversion. It is normally required when the company adds, expands or materially changes its purposes or activities.

Can the update happen automatically?

Yes. AHU and OSS may automatically or systemically convert eligible code-only changes. The company should still verify the result against the new description.

Which KBLI applies to residential property development?

KBLI 68111 covers residential building and land development, including residential projects developed for sale.

Which KBLI applies to long-term residential rental?

KBLI 68112 is the principal classification for leasing residential buildings and land owned or leased by the business.

Which KBLI applies to a short-term rental villa?

KBLI 55203 may apply where a private house or villa is offered as short-term tourist accommodation. The final classification depends on the actual operating model.

Which KBLI applies to residential property management?

KBLI 68292 applies to residential property management performed under a fee or contract.

Which KBLI applies to a property broker?

KBLI 68210 covers real estate intermediation, including agency, brokerage and listing activities.

Can a KBLI update be approved during the RUPST?

Yes. A substantive KBLI and corporate-purpose amendment can be included as a separate agenda item at the annual RUPS, provided the applicable notice, quorum, voting and notarial requirements are satisfied.

Does a correct KBLI prove that a villa can operate legally?

No. The company must also satisfy applicable zoning, building, environmental, tourism and local operating requirements.

Final considerations

The KBLI 2025 real estate update is not simply an administrative renumbering exercise.

For some companies, the conversion is straightforward and can be completed without amending the deed or replacing existing licences.

For others, the 2025 descriptions reveal that their registered activity no longer matches what they actually do.

Property companies should pay particular attention to:

• The changed scope of KBLI 68111.
• The separation between development and residential leasing.
• The division of the former 68200 service code.
• The distinction between long-term rental and short-term accommodation.
• The difference between managing a property and operating an accommodation business.
• Consistency across the deed, AHU, NIB, OSS and operational licences.

Before completing a substantive update, the company should have an Indonesian notary and qualified licensing adviser verify the proposed classification, corporate approvals and OSS consequences.

The correct KBLI should describe the company’s real business—not simply the code that is easiest to select.