Indonesia’s investment framework is designed to make more business activities available to international capital while retaining restrictions in selected sectors. For foreign investors planning to establish a large enterprise or enter the Indonesian market, the first question is therefore not simply whether a sector is open, but under what conditions.
The framework is commonly known as the Positive Investment List, introduced through Presidential Regulation No. 10 of 2021 and amended by Presidential Regulation No. 49 of 2021. The rules divide business fields into categories covering priority business sectors open to foreign investment, and regulates activities reserved for cooperatives and MSMEs.
The list is particularly relevant to foreign ownership, company registration, investment structure and business licensing in Indonesia.
Positive Investment List in Indonesia for Foreign Investors
The Positive Investment List is a classification of business sectors open to foreign investors, that determines whether and under what conditions an activity is open to investment.
Under the current framework, commercial business fields are generally open to investment unless they fall into a prohibited activity, are reserved for the government or are subject to specific conditions. Presidential Regulation No. 49 of 2021 removed many of the previous restrictions on foreign investment, including restrictions across hundreds of business fields.
For a foreign investor, being open to investment does not automatically mean every ownership structure is available. Sector-specific rules, licensing requirements and other regulations may still apply.
Categories of business sectors open to foreign investment in Indonesia
The Positive Investment List broadly divides investment opportunities into several categories.
Business fields requiring partnerships with cooperatives and SMEs
Certain activities are allocated to cooperatives and MSMEs, or require partnerships with them.
The purpose is to preserve opportunities for smaller Indonesian businesses while allowing larger enterprises or investors to participate through prescribed partnership arrangements.
Business fields with specific requirements or limitations
Some business fields are open to foreign investors but subject to particular conditions.
These may relate to foreign ownership, Indonesian shareholding, special licences, locations, capital requirements or other regulatory conditions. The restrictions can differ significantly between industries.
For this reason, investors should review the exact KBLI classification rather than relying on the general description of an industry.
Priority Business Sectors open to all investors
Other commercial activities are fully open to foreign investments, subject to the applicable regulations and business licensing requirements.
In practice, this has created a substantially broader market-entry framework than the former Negative Investment List. BKPM states that, under the revised framework, commercial activities are generally open to 100% foreign ownership, except for activities subject to specific conditions.
A foreign investor establishing a PT PMA must nevertheless meet applicable investment and corporate requirements before beginning operations.
Negative Investment List (DNI)
The term Negative Investment List, or DNI, refers to Indonesia’s earlier approach to regulating foreign investment.
The Positive Investment List replaced the previous framework under Presidential Regulation No. 10 of 2021, as amended under Presidential Regulation No. 49 of 2021. The earlier DNI approach focused more heavily on listing business fields that were closed or restricted to foreign investment.
Read more about Negative List here: Indonesia Negative Investment List (DNI)
Investment Value and Foreign Ownership
Foreign investors should distinguish between foreign ownership and the required total investment.
For a PT PMA, investment requirements apply separately from the question of whether a particular business permits foreign ownership. BKPM guidance has historically set a general minimum investment requirement of more than IDR 10 billion, excluding land and buildings, subject to sector-specific rules and exceptions.
The actual structure should therefore be reviewed against the company’s proposed KBLI codes, location, activities and investment plan before incorporation.
Fiscal Incentives for Investors
Being listed as a priority activity can also be relevant when assessing Indonesia’s fiscal incentives.
Certain qualifying investments may access facilities such as a tax holiday, tax allowance or other investment incentives, depending on the business sector, location and applicable criteria. BKPM describes tax holiday as a corporate income tax reduction for qualifying pioneer industries, while tax allowance provides specified tax benefits for qualifying activities and regions.
In practice, factors such as new investment, investment value, sector, location and qualifying activities can affect eligibility. A company should not assume that being in a priority sector automatically grants a tax holiday or corporate income tax reduction.
Understanding KBLI 2025 for PT PMA in Indonesia
The Positive Investment List must be considered alongside the company’s KBLI classification.
KBLI 2025, established through BPS Regulation No. 7 of 2025, updates Indonesia’s official classification of economic activities and aligns it with ISIC Revision 5. The new classification includes emerging activities such as artificial intelligence, content creation and certain climate-related activities.
For foreign investors, choosing the correct KBLI is important because it can affect ownership rules, licensing, reporting and access to incentives.
Read more: KBLI 2025 for Business in Indonesia
Consult Your Company Registration with Lets Move Indonesia
The Positive Investment List is only one part of the process of establishing a foreign-owned business in Indonesia.
Before incorporating a PT PMA, investors should assess foreign ownership, KBLI classification, total investment, licensing requirements, potential partnerships, available fiscal incentives and the company’s intended business activities. Investors in manufacturing or processing should also consider issues such as access to raw materials, location and sector-specific requirements.
Indonesia’s current risk-based licensing system is governed by Government Regulation No. 28 of 2025, with business licences and related requirements administered through the OSS system.
Lets Move Indonesia provides professional Legal and Business Setup Consultation, Immigration Consultation and Tax Consultation in Indonesia and ASEAN for foreign investors and businesses.
Whether you are establishing a new PT PMA, assessing a potential market entry or reviewing an existing company’s business activities, our team can help assess the applicable investment rules, license requirements and corporate structure before you commit capital.
