A foreign company representative office, or KPPA, can coordinate and prepare an investment in Indonesia. It cannot enter commercial sales agreements with domestic parties, invoice clients for those sales, or earn income from Indonesian sources.
Key Takeaways
- A KPPA may liaise, coordinate, supervise its parent’s interests, and prepare a PT PMA investment.
- Article 270 of Investment Ministry Regulation No. 5 of 2025 restricts domestic commercial sales agreements and transactions.
- A KPPA’s NIB identifies the representative office; it does not authorize local sales.
- If an Indonesian entity will contract and invoice, assess a PT PMA, its business codes, and applicable permits.
What a KPPA May Do in Indonesia
Article 270 of Minister of Investment and Downstream Industry/BKPM Regulation No. 5 of 2025 permits a KPPA to supervise, liaise, coordinate, and manage the interests of its foreign parent or affiliates. It may also prepare the establishment or development of a foreign investment company, known as a PT PMA.
A local team can gather market information, meet prospective partners, and report findings to headquarters within that scope. The practical question is when those contacts turn into sales activity. The Indonesia market entry strategy guide compares broader entry routes.
Contracts and Invoices That Cross the Line
The regulation prohibits a KPPA from seeking income from Indonesian sources. It expressly includes activities or agreements for commercial purchases and sales of goods or services between the parent company and parties in Indonesia. A KPPA chief should therefore not sign a domestic sales contract on the office’s behalf.
Meeting notes and requests for information serve a different purpose from documents that set prices, delivery duties, payment terms, and customer remedies. Review what the document actually commits the parties to do, regardless of its label.
| Proposed Activity | Practical Check |
|---|---|
| Arrange meetings with prospective partners | Document the liaison purpose and identify who makes commercial decisions. |
| Sign a purchase order or sales contract | Do not treat the KPPA NIB as sales authority; review the seller and required licences. |
| Issue an invoice to an Indonesian client | Identify the seller, service provider, payment recipient, and party recording revenue. |
| Support a contract signed overseas by the parent | Review local staff activity, tax, imports, and sector rules on the transaction facts. |
An overseas contract raises separate questions. The KPPA restriction alone does not settle the parent’s Indonesian tax, import, or licensing position. Map one complete transaction before drawing a conclusion.
Notes for Your vOffice Consultation
Bring one proposed sale and mark who signs, invoices, receives payment, and delivers. If the KPPA appears in the sales flow, obtain a legal review before signing customer documents.
Registration Documents and Office Location
Article 270 requires a KPPA to obtain an NIB through OSS. The listed materials include the foreign parent’s incorporation documents, an appointment letter, a valid office lease, activity data, and a safety, health, and environmental declaration. Check the current OSS filing screens for the exact document format.
A KPPA must be located in an office building in a provincial capital. A PT PMA follows a different address assessment. If incorporation is planned, the PT PMA virtual office guide provides background on matching an address to the actual operation.
When the Business Needs Local Sales
If an Indonesian entity needs to sell, invoice, and perform services for customers, review a PT PMA. Its incorporation, foreign ownership, KBLI classification, licensing, and premises requirements differ from those of a KPPA.
Start with the PT PMA definition and requirements. For ownership conditions, consult the KBLI single majority guide. The PT PMA establishment procedure gives a process outline; verify any figures or older steps against current official rules.
InvestinAsias company registration service describes incorporation and OSS support. Ask for a written scope that separates KPPA review, PT PMA formation, sector permits, and office requirements.
Check the Structure Before Invoicing
Share a draft contract and invoice flow to define the registration scope.
- Ministry of Investment and Downstream Industry/BKPM. Ministerial Regulation No. 5 of 2025, especially Articles 269 to 271. Retrieved November 12, 2026, from
https://jdih-storage.bkpm.go.id/jdih/jdih/2025Permeninvest005Eng-.pdf - Indonesia Investment Promotion Center, BKPM. How to Establish a Foreign Representative Office (KPPA) in Indonesia. Retrieved November 12, 2026, from
https://newyork.bkpm.go.id/support/foreign-representative-office-fro-setup - Online Single Submission. Licensing for Non UMK Representative Office: KPPA. Retrieved November 12, 2026, from
https://oss.go.id/en/panduan/635970086345c7d71a8144d9 - Ministry of Trade. Regulation No. 10/M-DAG/PER/3/2006 and its amendments on KP3A. Retrieved November 12, 2026, from
https://jdih.kemendag.go.id/peraturan/peraturan-menteri-perdagangan-nomor-10m-dagper32006-tentang-ketentuan-dan-tata-cara-penerbitan-surat-izin-usaha-perwakilan-perusahaan-perdagangan-asing - InvestinAsia.id. Company Registration. Retrieved November 12, 2026, from
https://investinasia.id/services/company-registration

