Reclassifying a supporting KBLI as a primary activity in Indonesia’s OSS RBA cannot be done with a single click. The path forward hinges on one question: is the target KBLI code already listed in your company’s Articles of Association (Anggaran Dasar)? If it is, the fix is mostly an OSS data update. If it is not, you need a shareholder resolution, a deed amendment through a notary, and Kemenkumham approval before the OSS record can change.
Many businesses that registered during the early OSS RBA rollout in 2021 ended up in this situation. A system gap at the time allowed supporting KBLI entries without a confirmed primary activity, so core revenue-generating operations got filed under the wrong category. The labels did not appear on NIBs back then. Once the system was updated and category labels became visible, the misclassification surfaced.
Primary vs. Supporting KBLI: What the Law Actually Says
Under Article 210 of Government Regulation No. 28 of 2025 on Risk-Based Business Licensing, a primary KBLI is a business activity listed in the company’s deed, commercial in nature, and the main source of company revenue. It must appear in Article 3 of the Articles of Association and forms the legal basis for NIB issuance and all accompanying licenses.
A supporting KBLI, per Article 210 paragraph 3 of the same regulation, supports the primary activity, does not independently generate revenue, and may be completed before the primary activity is fully operational. BKPM Regulation No. 5 of 2025 tightened this considerably: supporting KBLIs that are commercial in nature must now appear in the deed and are treated like primary activities for investment minimum purposes.
In practice, this distinction matters because primary KBLI determines risk level, required permits, and minimum investment obligations. Supporting KBLI is exempt from several of these checks, but only when it is genuinely non-commercial. For a broader overview of how Indonesian business classification codes work, read Business Sectors of PT: A Guide to Categories A-G.
Why Does a Core Business Activity End Up as Supporting?
Three scenarios produce this problem in practice.
System gaps during the initial OSS RBA rollout
When OSS RBA launched in mid-2021, it was possible to register a supporting KBLI without having a confirmed primary activity on file. Many companies whose primary KBLI had not yet been migrated to the KBLI 2020 format in the Ministry of Law’s AHU system used this route and registered their core activity under the supporting category. The NIB issued at the time did not show category labels, so nothing looked wrong. When labels became visible after the system was updated, the misclassification appeared.
Input error during initial registration
The OSS registration form asks you to select whether a business activity is primary or supporting. Business owners who did not understand the distinction, or who used a third-party agent without proper guidance, sometimes applied the supporting label to their main revenue activity.
Deed not updated after the business expanded
OSS only allows KBLI codes already listed in Article 3 of the company deed to be registered as primary. If the activity was added to the business after the original deed was issued, the system will reject that code as a primary entry or only offer it as a supporting option.
Can the Supporting KBLI Be Changed Directly to Primary in OSS?
Not directly. Two scenarios determine which path to take, and identifying the right one is the first step.
Scenario A: The KBLI already appears in Article 3 of the Articles of Association, but was entered as supporting in OSS due to an input error or the early system gap. No deed amendment needed. Remove the KBLI from the supporting category in OSS and re-register it as primary. If OSS rejects the process, consult your local DPMPTSP (One-Stop Integrated Service Office) directly.
Scenario B: The KBLI does not appear in the current Articles of Association. A deed amendment through a RUPS and notary is required first. The OSS update can only happen after the Kemenkumham ministerial decree is issued.
Step-by-Step: How to Reclassify a Supporting KBLI as Primary
Step 1: Review the Articles of Association
Open the company deed and find Article 3 on Purpose and Objectives (Maksud dan Tujuan). Check whether the target KBLI appears there, either as a 5-digit code or as a business description matching the activity.
One complication worth noting: some Indonesian notaries draft Article 3 using general business descriptions without explicit KBLI numbers. If that is your case, ask your notary to verify what codes were actually entered into the AHU Online system, because OSS reads the AHU data, not the printed deed text.
Step 2: Amend the Articles of Association (Scenario B only)
Hold a General Meeting of Shareholders (RUPS) with the agenda of amending Article 3. The RUPS resolution is the legal foundation for everything that follows. Single-shareholder companies may pass this resolution outside a formal RUPS meeting under specific conditions allowed by the Indonesian Company Law.
Have the resolution formalized in a notarial deed in Indonesian. The application for Kemenkumham approval must be submitted within 30 days of the notary deed date, electronically through the Legal Entity Administration System (SABH), with supporting documents including the amended Articles, RUPS minutes, and the company NPWP (tax ID).
Wait for the Ministerial Decree (SK) from Kemenkumham. The deed amendment only takes legal effect after the SK is issued. This typically takes 1 to 3 weeks depending on document completeness and processing queue at the ministry.
Step 3: Remove the KBLI from the Supporting Category in OSS
Once the Kemenkumham SK is in hand (or for Scenario A from the start), log into OSS using the account linked to your company NIB. Navigate to the Perizinan Berusaha (Business Licensing) menu and locate the relevant KBLI.
For supporting KBLIs without an active license, use the Pembatalan Perizinan (Cancellation) option on the KBLI entry. Fill in the reason and confirm. Keep the cancellation confirmation as a record. A detailed walkthrough is in the guide on how to remove KBLI in OSS RBA.
If the supporting KBLI already has an active license, the process is different. The license needs formal revocation before the KBLI can be removed. Consult your local DPMPTSP or a business licensing consultant before proceeding with this route.
Step 4: Re-register as Primary KBLI
After removal, re-enter the same KBLI code through the Ubah Data (Change Data) menu, this time selecting Kegiatan Usaha Utama (Primary Business Activity). Make sure the latest Kemenkumham SK number is entered during the data synchronization step.
What happens next depends on your KBLI risk level. Low-risk KBLI generates an active NIB immediately. Medium-risk KBLI requires submitting technical compliance documents to obtain a verified Standard Certificate. High-risk KBLI needs a sector-specific permit from the relevant ministry. For the full breakdown, read the guide on how to verify KBLI in OSS RBA (Indonesian).
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Legal Risks of Leaving the Misclassification Uncorrected
This is not a minor bookkeeping problem. Leaving a revenue-generating activity in the supporting category creates real legal exposure.
Wrong permits for the actual risk level. Supporting KBLI is exempt from certain investment minimums and licensing requirements. If your main revenue activity sits there, the company may be holding the wrong permits for the actual risk level of that activity.
Deed inconsistency. Indonesian law requires commercial activities generating primary revenue to appear in the company’s purpose and objectives clause. A gap between what the company actually does and what the deed says creates legal vulnerability under UU No. 40 of 2007.
Financing barriers. Banks and investors typically require an active NIB with KBLI codes matching actual operations. Classification mismatches can block credit applications and complicate investment due diligence.
Administrative sanctions. Under risk-based licensing enforcement, business activities not aligned with the KBLI on the NIB may be treated as operating without proper authorization, which can trigger penalties.
When Is No Deed Amendment Needed?
Two situations allow reclassification without amending the Articles of Association.
The first: the KBLI is already in the deed, but was entered incorrectly in OSS due to a technical error or the 2021 system gap. In this case, the fix is handled entirely within OSS.
The second: the change is a code adjustment from KBLI 2020 to KBLI 2025 with no substantive change in the nature of the business activity. Based on the Joint Circular issued March 28, 2026, administrative code adjustments without substantive changes can be processed automatically through the integrated OSS system.
After any KBLI removal and re-registration, the code sometimes does not appear in the NIB immediately. This is usually a synchronization issue between OSS and the AHU database. The guide on why KBLI does not appear in NIB covers the common causes and fixes.
Foreign-invested companies (PMA) need to watch one additional condition: if paid-up capital is below IDR 10 billion, the Anggaran Dasar amendment must also include a capital increase to meet current PMA requirements. OSS RBA detects this automatically and will block the filing if the threshold is not met.
Before re-registering as primary, also verify that the target KBLI is not in the single-purpose category. Single-purpose KBLIs cannot be combined with other codes in one entity. Attempting to register one as primary alongside unrelated codes creates a conflict the system will reject. More detail is in the article on what is a single-purpose KBLI.
When the reclassification involves a deed amendment, coordination between notary, Kemenkumham, and OSS needs careful sequencing. One delayed document can hold up the rest. For foreign investors unfamiliar with Indonesia’s legal process, local expertise cuts the risk of procedural errors significantly. vOffice PT establishment services cover KBLI selection, deed amendments, and OSS permit registration, with support from the first consultation through to NIB issuance.
Navigating the KBLI Reclassification Process?
vOffice, trusted by 50,000+ clients with 20+ years in Southeast Asia, handles the full process from RUPS to NIB issuance.
Frequently Asked Questions
Can a supporting KBLI be changed to primary in OSS without amending the deed?
Yes, but only if the KBLI already appears in Article 3 of the Articles of Association and the misclassification was an OSS input error. If the code is not in the deed at all, a deed amendment through RUPS and a notary is required first.
How long does the full process take when a deed amendment is needed?
Typically 2 to 5 weeks. Kemenkumham approval for the deed amendment usually takes 1 to 3 weeks from submission. Once the ministerial decree is issued, the OSS update can be completed within a few business days depending on the KBLI risk level.
What happens if the misclassification is left uncorrected?
The company risks holding incorrect permits for its actual risk level, a legal mismatch between the deed and real operations, barriers to bank financing or investment, and potential administrative sanctions under risk-based licensing enforcement.
Do foreign-invested companies (PMA) face additional steps?
Yes. PMA companies with paid-up capital below IDR 10 billion must increase their capital to meet current PMA requirements when filing for a deed amendment. OSS RBA detects this automatically and blocks the process if the threshold is not met.
How do I check whether a KBLI is already in the company deed?
Review Article 3 of the deed under Maksud dan Tujuan. If the deed uses general business descriptions without KBLI codes, ask your notary to verify what was entered into AHU Online, since OSS reads the AHU database rather than the printed deed text.
What costs are involved?
If a deed amendment is required, costs include notary fees and the PNBP (non-tax state revenue) fee for Kemenkumham. For a standard deed amendment, total costs typically range from IDR 5 million to IDR 10 million, varying by notary and complexity.
References
1. Badan Pusat Statistik. (2020). Regulation of the Head of BPS No. 2 of 2020 on Indonesia Standard Classification of Business Fields (KBLI). BPS RI. Retrieved from
https://klasifikasi.web.bps.go.id/app/kbli
2. Government of Indonesia. (2025). Government Regulation No. 28 of 2025 on Risk-Based Business Licensing. Retrieved from
https://peraturan.go.id
3. BKPM. (2025). BKPM Regulation No. 5 of 2025 on Business Activity Classification Guidelines. BKPM RI. Retrieved from
https://jdih.bkpm.go.id
4. Government of Indonesia. (2007). Law No. 40 of 2007 on Limited Liability Companies. Retrieved from
https://peraturan.bpk.go.id/Details/40279/uu-no-40-tahun-2007
5. Government of Indonesia. (2021). Government Regulation No. 5 of 2021 on Risk-Based Business Licensing. Retrieved from
https://jdih.setneg.go.id
6. Badan Pusat Statistik. (2025). BPS Regulation No. 7 of 2025 on the 2025 Indonesia Standard Classification of Business Fields. BPS RI. Retrieved from
https://www.bps.go.id
