Selecting KBLI Codes for a PT PMA in software development

Indonesia offers promising opportunities for foreign investors looking to establish software development companies, SaaS businesses, IT consulting firms, and digital technology startups. However, before incorporating a foreign-owned company, investors must make an important regulatory decision: selecting the appropriate Indonesian business classification codes.

These codes are known as KBLI (Klasifikasi Baku Lapangan Usaha Indonesia). They identify the economic activities a company intends to conduct and help determine the business licensing requirements applicable to its operations.

For a software development PT PMA, choosing the correct KBLI can be more complicated than simply selecting a category that mentions computers or programming. A business developing custom applications for corporate clients may operate differently from a company publishing its own software products or providing cloud-based subscription services.

Furthermore, Indonesia introduced KBLI 2025, updating the previous classification framework to reflect changes in technology and economic activities.

Foreign investors must therefore evaluate their actual business model before completing company incorporation.

This guide explores the practical questions software entrepreneurs should ask when selecting KBLI codes for a PT PMA in Indonesia.

Why Does KBLI Selection Matter for a Software Development PT PMA?

A PT PMA is an Indonesian limited liability company established with foreign investment. Like other Indonesian business entities, it must register its intended business activities using the appropriate KBLI classifications.

These classifications are relevant to the company’s registration through the Online Single Submission (OSS) system, which administers Indonesia’s risk-based business licensing framework.

For software businesses, KBLI selection can influence the company’s licensing requirements, regulatory obligations, and ability to conduct particular commercial activities.

For example, a company registered to provide custom programming services should not automatically assume that its classification covers every type of digital platform, financial technology service, or software publishing activity.

Choosing an inaccurate classification can create difficulties when applying for additional licenses, entering corporate contracts, or expanding the business.

A properly selected KBLI should reflect what the company actually does, rather than merely describing the broader technology industry.

1. Will Your Company Develop Software for Clients or Sell Its Own Products?

The first question concerns the company’s primary business model.

A custom software development company typically creates applications based on client requirements. Its projects may include enterprise resource planning systems, mobile applications, inventory management software, or internal business platforms.

The company usually receives project fees, development payments, or ongoing maintenance revenue.

By contrast, a software product company develops applications intended for distribution or licensing to multiple customers. Its revenue may come from software subscriptions, licenses, or product sales.

These activities may fall under different classifications.

Under KBLI 2025, software publishing activities are distinguished from programming and related computer services. The classification for other software publishing activities, KBLI 58290, includes various ready-to-use software products, including certain business applications and AI-related software.

However, that does not mean every SaaS or software development business automatically belongs under KBLI 58290.

The correct classification depends on the actual activity, product ownership, service model, and applicable OSS descriptions.

2. Is Your Business Primarily Software Development or IT Consulting?

Software development and IT consulting are closely related, but they are not identical activities.

A software development company may focus on writing code, designing applications, testing software, and maintaining customized systems.

An IT consulting firm may primarily advise clients on technology strategy, systems architecture, digital transformation, or the selection and implementation of technology solutions.

Some companies provide both services.

For example, a foreign-owned technology firm may initially advise Indonesian manufacturers on digital transformation before developing custom software to implement its recommendations.

In this situation, investors should evaluate whether more than one KBLI classification is appropriate.

The objective is not to register as many codes as possible. Instead, the company should identify the activities it genuinely intends to perform and confirm the licensing consequences of each classification.

3. Does Your SaaS Business Require a Different KBLI?

Software as a Service, commonly known as SaaS, is an increasingly popular business model among technology startups.

A SaaS company typically provides customers with access to software through the internet rather than delivering a conventional installed application.

Examples include subscription-based accounting platforms, customer relationship management systems, project management applications, and cloud-based inventory software.

However, the term SaaS describes how software is delivered and monetized. It does not automatically determine a single KBLI classification.

A SaaS business may involve software publishing, programming, hosting, data processing, or other activities depending on its operating model.

Investors should examine whether the company develops and publishes its own software, provides software services on behalf of clients, operates infrastructure, or combines several activities.

The distinction is particularly important when a startup plans to operate a platform involving regulated services.

4. Should You Use KBLI 2025 Instead of Older Software Development Codes?

Yes. Investors establishing a new software company should review the applicable KBLI 2025 classifications and the current OSS requirements.

Indonesia’s Central Statistics Agency (BPS) introduced KBLI 2025 through Regulation No. 7 of 2025.

The updated classification reflects changes in economic activities, including developments involving digital technology, artificial intelligence, and other emerging sectors.

Some classifications have been renumbered, divided, combined, or redefined.

As a result, a KBLI code found in an older incorporation guide may no longer be the most appropriate reference for a new application.

BPS has also released conversion tables connecting KBLI 2020 and KBLI 2025.

Foreign investors should use these conversion references alongside the official descriptions in OSS, rather than assuming that a previous code remains unchanged.

For existing companies, the transition does not necessarily invalidate previously issued licenses. The need for an update depends on the applicable transition arrangements and whether the company’s business activities have substantively changed.

5. Can a Software Development PT PMA Register Multiple KBLI Codes?

A PT PMA may register multiple business activities when permitted under the applicable rules and when those activities genuinely reflect its intended operations.

For example, a software company might provide custom application development while also offering IT consulting and publishing its own software products.

Nevertheless, each additional classification should be evaluated carefully.

Different business activities may have different licensing requirements, investment considerations, and operational obligations.

Adding unrelated classifications merely to create flexibility can introduce unnecessary administrative complexity.

A more practical approach is to prepare a clear description of the company’s planned revenue-generating activities and map each activity to the relevant classification.

The selected codes should also be consistent with the company’s articles of association and OSS registration.

6. Does Foreign Ownership Affect KBLI Selection?

Foreign ownership is an important consideration when establishing a software development PT PMA.

Investors must verify whether the intended business activities are open to foreign investment and whether any applicable restrictions or special conditions apply.

A classification describing a technology activity does not, by itself, confirm that the proposed foreign ownership structure is permissible.

Foreign investors should assess the relevant investment regulations, sector-specific requirements, and company establishment rules before finalizing the structure.

They should also consider the applicable minimum investment and capital requirements for a PT PMA.

For entrepreneurs unfamiliar with these requirements, professional pt pma registration indonesia support can help coordinate business classification, incorporation documentation, and licensing considerations.

Addressing these questions early can prevent unnecessary amendments after the company has already been established.

7. Will Your Software Company Operate a Digital Platform?

A software company may develop applications without operating a public digital platform. However, some startups intend to launch online marketplaces, digital service platforms, or applications that connect users with third-party providers.

These business models can involve activities beyond conventional software development.

For example, a company operating an online marketplace may have different regulatory responsibilities from a developer building marketplace software for a client.

The same distinction can apply to platforms offering financial services, healthcare-related functions, or other regulated activities.

Depending on the business, electronic system operator registration or additional sector-specific obligations may need to be assessed.

Founders should therefore explain both the technical product and the commercial service provided to customers when selecting KBLI classifications.

8. Does the Company’s Business Address Affect Licensing?

A software development PT PMA must also consider its registered business location.

Many technology companies operate remotely, particularly when developers and product teams are distributed across different locations.

Some founders consider using a virtual office to reduce operating expenses during the early stages of incorporation.

However, a virtual office is not automatically suitable for every software-related activity.

The company should confirm whether the proposed address meets the requirements associated with its business classification, licensing, and relevant administrative registrations.

A software consultancy with remote employees may have different premises requirements from a business operating physical servers, laboratories, or specialized equipment.

The business address should therefore be reviewed together with the proposed KBLI codes.

9. What Happens If the Software Company Expands Its Services?

Technology businesses frequently evolve after incorporation.

A startup may begin by developing custom software for Indonesian clients and later introduce its own SaaS platform.

Another company may expand from software engineering into cybersecurity consulting, cloud infrastructure management, or artificial intelligence solutions.

These changes can affect the company’s registered business activities.

Before launching a materially different service, management should review whether the existing KBLI classifications remain appropriate.

Where necessary, the company may need to update its corporate documents, OSS information, or relevant licenses.

Planning for foreseeable business expansion during incorporation can reduce future administrative work, but investors should avoid registering speculative activities that have no genuine connection to the company’s business plan.

10. What Documents Should Founders Prepare Before Selecting KBLI?

Software entrepreneurs can make the classification process more efficient by preparing a short business activity summary.

The document should describe the company’s actual and planned services in practical terms.

Useful information includes:

• The software products or services the company will provide.
• Whether applications are developed for clients or owned by the company.
• How the business will generate revenue.
• Whether customers are businesses or individual consumers.
• Whether the company operates a public digital platform.
• Whether it provides hosting, infrastructure, or data processing services.
• Whether additional regulated activities are involved.
• The company’s expected expansion plans.

This information helps advisers evaluate the relevant KBLI descriptions and identify potential licensing issues.

It also reduces the risk of selecting a classification based solely on a company’s marketing description.

Practical Example: Choosing KBLI for a Foreign-Owned Software Startup

Consider a Singapore-based technology company planning to establish a PT PMA in Jakarta.

The business intends to provide custom inventory management applications to Indonesian manufacturers.

During its first year, the company will earn revenue from software development projects and maintenance agreements.

In its second year, the founders plan to introduce a subscription-based inventory platform developed and owned by the company.

The initial business activities may involve custom programming services, while the planned subscription product could require a separate assessment of software publishing or related classifications.

The founders should review the relevant KBLI 2025 descriptions and determine whether the proposed activities require one or several classifications.

They should also confirm foreign investment eligibility, the appropriate registered address, and any additional licensing obligations.

By documenting these matters before incorporation, the company can establish a more suitable foundation for its intended operations.

Common KBLI Selection Mistakes Software Startups Should Avoid

One common mistake is choosing a classification solely because its title contains the words software or computer. The full official description and exclusions are often more important than the title itself.

Another mistake is assuming that software development, SaaS publishing, IT consulting, and digital platform operation are interchangeable activities. Although they may overlap commercially, their regulatory classifications can differ.

Founders should also avoid relying exclusively on outdated KBLI lists or copying codes from another technology company without understanding its business model.

Finally, selecting a code should not be treated as the last licensing step. The company must still review the applicable OSS requirements, foreign investment conditions, and any relevant sector-specific regulations.

How Portcorp Helps Foreign Software Companies Establish a PT PMA

Selecting appropriate KBLI codes is an important part of establishing a foreign-owned software business in Indonesia.

For overseas founders, the challenge is often translating a technical business model into the classifications and administrative requirements used by Indonesian authorities.

Portcorp provides company incorporation and corporate administration support for businesses entering the Indonesian market.

For software development companies, Portcorp can assist in discussing the intended business activities, coordinating incorporation requirements, and identifying relevant registration considerations.

Depending on the company’s circumstances and agreed service scope, support may include reviewing proposed business classifications, preparing company establishment documentation, coordinating registration requirements, and addressing ongoing corporate administration needs.

This can be particularly useful for foreign founders who want to establish their Indonesian company while continuing to manage software development and international business operations.

Frequently Asked Questions

What KBLI should a custom software development PT PMA use?

The appropriate classification depends on the company’s actual programming activities and the current KBLI 2025 descriptions. Investors should review the relevant computer programming categories rather than selecting a code based only on its title.

Is the KBLI for SaaS the same as custom software development?

Not necessarily. A SaaS company publishing its own software may conduct different activities from a business developing applications exclusively for clients.

Can a foreign-owned software company register more than one KBLI?

Potentially, yes. Multiple classifications may be appropriate when the company genuinely conducts several distinct activities and satisfies the applicable requirements.

Does selecting a KBLI automatically authorize the company to operate?

No. KBLI selection identifies the business activity, while the applicable registration, licensing, and other regulatory requirements must still be satisfied.

Can a PT PMA change its KBLI after incorporation?

Yes, subject to the applicable corporate and licensing procedures. Depending on the change, updates to the company’s corporate documents and OSS records may be necessary.

Choose KBLI Codes Based on Your Actual Software Business Model

Selecting KBLI codes for a software development PT PMA requires more than finding a classification that mentions programming or technology.

Foreign investors should examine how their company develops software, earns revenue, serves customers, and plans to expand.

Custom development, SaaS publishing, IT consulting, and digital platform operations may require different classification considerations.

With KBLI 2025 now forming part of Indonesia’s business classification framework, founders should also verify current descriptions and applicable licensing rules before submitting their incorporation documents.

A carefully selected business classification can support a smoother establishment process and reduce the likelihood of unnecessary administrative changes as the company grows.

Before You Register Your Software PT PMA, Make Sure Your KBLI Matches Your Business

Your development team may already know exactly what it wants to build. The more difficult question is whether your proposed Indonesian company registration accurately describes how that software will be developed, sold, and delivered.

If you are preparing to establish a software development PT PMA, share a brief outline of your business model with Portcorp. Explain whether you plan to build custom applications, launch a SaaS product, provide IT consulting, or combine several technology services.

The Portcorp team can discuss the relevant incorporation and business classification considerations before you proceed with registration. This gives you an opportunity to identify questions early, rather than discovering a mismatch after your company has been established.