The headline PT PMA investment requirement in Indonesia is not simply IDR 10 billion for the company. The general rule is total investment of more than IDR 10 billion, excluding land and buildings, per five-digit KBLI business field per project location—but Article 26 of the current investment regulation contains important exceptions that can change both the KBLI grouping and whether land and buildings are included.
For PT PMA Investment Value in Indonesia: How the IDR 10 Billion Rule Works by KBLI and Project Location, use this sequence:
- Identify the current KBLI 2025 activity
- Identify the relevant project location
- Check whether the activity follows the ordinary five-digit rule or a sector exception
- Determine whether land and buildings are excluded or included
- Keep total investment value separate from paid-up capital
PT PMA Investment Value in Indonesia: How the IDR 10 Billion Rule Works by KBLI and Project Location
Article 26 of the current Ministerial Regulation No. 5 of 2025 treats PMA business entities as large businesses and subjects them to minimum investment-value requirements unless another law or regulation provides otherwise.
The key point is that the regulation establishes a calculation basis, not one universal investment amount for every PT PMA.
The General Rule: More Than IDR 10 Billion
As the general rule, Article 26 of Ministerial Regulation No. 5 of 2025 requires total PMA investment of more than IDR 10 billion, excluding land and buildings, per five-digit KBLI business field per project location.
Three elements therefore matter:
- Amount: more than IDR 10 billion
- Activity unit: ordinarily each five-digit KBLI business field
- Location unit: ordinarily each project location
Because the investment formula is tied to business classification, investors should work from the current classification: OSS KBLI 2025 guidance states that KBLI 2025 is the principal reference for new applications, changes, expansions, updates and extensions.
For the broader PT PMA setup sequence around ownership, KBLI, company establishment and OSS, see Bali Legal ID’s complete PT PMA setup guide.
Why You Cannot Simply Multiply IDR 10 Billion by Every KBLI
The ordinary five-digit-KBLI-per-location rule has statutory exceptions. A mechanical formula such as ‘three KBLI codes equals more than IDR 30 billion’ can therefore be wrong if one or more activities fall under a special Article 26 calculation.
The correct question is:
What calculation unit does Article 26 assign to this specific business activity?
Wholesale Trade, Food and Beverage, Construction and Industry
Article 26 changes the ordinary formula for several sectors.
| Activity | Investment-value basis under Article 26 |
|---|---|
| Ordinary PMA activity | More than IDR 10 billion excluding land and buildings per 5-digit KBLI per project location |
| Wholesale trade | More than IDR 10 billion excluding land and buildings per first 4 digits of KBLI |
| Food and beverage services | More than IDR 10 billion excluding land and buildings per first 2 digits of KBLI per location point |
| Construction | More than IDR 10 billion excluding land and buildings per first 4 digits of KBLI |
| Certain industrial production | More than IDR 10 billion excluding land and buildings for types or varieties of products within one production line |
For wholesale trade, the same Article 26 changes the calculation basis to more than IDR 10 billion excluding land and buildings per first four digits of KBLI.
For food and beverage services, Article 26 of the same regulation uses more than IDR 10 billion excluding land and buildings per first two digits of KBLI per location point, and the regulation states that this location point applies per regency or city.
Construction also has a special calculation rule: the regulation applies the threshold per first four digits of KBLI rather than the ordinary five-digit-KBLI-per-location formula.
Article 26 also creates a special rule for industrial activities producing types or varieties of products within one production line, using a threshold of more than IDR 10 billion excluding land and buildings under the current regulation.
These exceptions are why investors should classify the business first and calculate second.
Property and Accommodation: Why Land and Buildings Matter
This is particularly important for Bali investors because the general phrase ‘excluding land and buildings’ does not apply uniformly to every property or hospitality project.
Article 26 specifically states that for activities including property development or operation, short- and long-term accommodation, agriculture, plantations, livestock and aquaculture, the investment-value criterion includes land and buildings.
Property businesses need another layer of review because Article 26 of the regulation distinguishes a whole building or integrated housing complex from property units that are not within one whole building or one integrated housing complex.
For a whole building or integrated housing complex, the regulation provides a more-than-IDR-10-billion criterion including land and buildings. For certain property units outside that configuration, Article 26 provides different treatment that can exclude land and buildings.
This means an investor considering a hotel, villa accommodation project, property development or property operation in Bali should not use a generic PT PMA capital article as the final calculation. The actual KBLI and project configuration matter.
How Project Location Changes the Calculation
Under the ordinary rule, the investment threshold applies per five-digit KBLI per project location. Location is therefore part of the investment-value test, not merely an address field.
For example, a company with the same ordinary five-digit KBLI at more than one project location may need to review the investment requirement for each location rather than assuming one company-wide investment amount covers every project.
However, do not multiply automatically. Food and beverage services have their own location rule, wholesale and construction use different KBLI grouping rules, and other activities may have sector-specific provisions.
A safer calculation model is:
KBLI → sector rule → project-location rule → included investment components
not:
number of KBLI codes × IDR 10 billion.
Investment Value Is Not the Same as Paid-Up Capital
Another common source of confusion is treating the IDR 10 billion investment value and paid-up capital as the same requirement.
They are separate.
The investment-value calculation should not be confused with paid-up capital: the same regulation separately sets minimum placed or paid-up capital for PMA at IDR 2.5 billion per limited liability company, unless another regulation provides otherwise.
| Concept | General function |
|---|---|
| Total investment value | Measures the planned investment under the Article 26 calculation applicable to the activity and project |
| Paid-up capital | Company capital requirement, generally at least IDR 2.5 billion per PT PMA |
| Setup/service cost | Professional, notarial or administrative commercial expense; not the same as regulatory investment or capital |
For discussion of professional setup expenses, Bali Legal ID’s PT PMA Setup Cost Bali guide is the appropriate supporting page.
A Practical PT PMA Investment Calculation Checklist
Before incorporating a PT PMA or adding a major new activity or project location, review these questions:
- What is the exact KBLI 2025 code?
- Does the activity use the ordinary five-digit rule or a sector exception?
- What is the relevant project-location unit?
- Does the calculation exclude or include land and buildings?
- If it is property, what is the project configuration under Article 26?
- Are multiple KBLI activities being grouped differently under a sector rule?
- Is the total investment calculation being confused with the IDR 2.5 billion paid-up capital rule?
- Does the planned OSS project data describe the same activity and location used in the investment calculation?
Do not finalize the investment plan based only on a headline threshold. The Article 26 calculation should be matched to the actual KBLI, sector and project structure.
Once the activity, investment calculation and ownership structure have been reviewed, Bali Legal ID’s verified PT PMA Setup service is the relevant transactional next step for company-establishment support.
Conclusion
The IDR 10 billion PT PMA rule is best understood as a regulatory calculation framework, not as one flat capital requirement.
The ordinary formula is more than IDR 10 billion excluding land and buildings per five-digit KBLI per project location. But wholesale trade, food and beverage services, construction, industry, property, accommodation and other specified activities can follow different calculation rules.
For Bali investors, the land-and-building exception is especially important because specified property and accommodation activities can include those components in the investment-value criterion.
The practical rule is: identify the KBLI, identify the project location, apply the sector-specific Article 26 calculation, and only then determine the required investment value. Keep that figure separate from the PT PMA’s paid-up capital.
Check the Investment Calculation Before Incorporation
If your PT PMA will have multiple KBLI activities, more than one project location, or a property, accommodation, food and beverage, construction or other activity with a special calculation rule, review the investment structure before finalizing the deed and OSS project data.
Discuss the proposed KBLI, locations and investment plan with Bali Legal ID to determine how the PT PMA setup and licensing structure should be reviewed for the actual business.
FAQ – PT PMA Investment Value in Indonesia
Does every PT PMA need more than IDR 10 billion in total investment?
PMA business entities are generally subject to a more-than-IDR-10-billion minimum investment-value rule under Ministerial Regulation No. 5 of 2025 unless another regulation provides otherwise. The calculation basis varies by business activity, KBLI grouping and project-location rule.
Is the IDR 10 billion requirement calculated for every KBLI code?
The general rule applies per five-digit KBLI per project location, but Article 26 contains sector exceptions. Wholesale trade and construction use a four-digit grouping, food and beverage services use a two-digit grouping per specified location point, and other sectors have their own calculation treatment.
Does PT PMA investment value exclude land and buildings?
Under the general rule, yes, but not universally. Article 26 states that specified activities including property development or operation and short- or long-term accommodation use an investment-value criterion that includes land and buildings, subject to further property-specific provisions.
If I have two project locations, do I automatically need more than IDR 20 billion?
Do not calculate it mechanically. The ordinary rule is location-based, but sector exceptions can change the location unit and KBLI grouping. Review the actual activities and locations under Article 26 before determining the total required investment.
Is the IDR 2.5 billion paid-up capital part of the IDR 10 billion investment rule?
They are separate regulatory concepts. Ministerial Regulation No. 5 of 2025 separately sets minimum placed or paid-up capital for PMA at IDR 2.5 billion per limited liability company unless another regulation provides otherwise.
Does a Bali hotel or accommodation PT PMA use the same land-and-building rule as an ordinary consulting company?
No. Article 26 specifically lists short- and long-term accommodation among activities where the investment-value criterion includes land and buildings, while the ordinary rule excludes those components.
References & Sources
- Bali Legal ID – Complete Guide to Setting Up PT PMA in Bali
- Minister of Investment and Downstream Industry/Head of BKPM Regulation No. 5 of 2025 – Official PDF
- BKPM JDIH – Minister of Investment and Downstream Industry/Head of BKPM Regulation No. 5 of 2025
- OSS Guide – Conversion of KBLI 2020 and Earlier to KBLI 2025