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Permen Investasi/BKPM 5/2025: the PT PMA rules, article by article

The October 2025 regulation that cut PT PMA paid-up capital from IDR 10 billion to IDR 2.5 billion, counted land in for accommodation, and added a 12-month lock-up.

Written from the Indonesian originals · Editor-reviewed · Law as read on 2026-10-01
By the balipropertyguide.com editorial team · Published 2026-10-01 · Last reviewed 2026-10-01 · 8 min read
5 primary sources cited on this page. How we check what is on this site

Permen Investasi/BKPM 5/2025, the articles behind a PT PMA, in order

This is the regulation that sets what a foreign-owned company must put in. It replaced Perka BKPM 4/2021, which is revoked (Permen Investasi/BKPM 5/2025 art. 398(b)) — the source of the “IDR 10 billion paid-up capital” figure that most PT PMA guides still quote. It implements PP 28/2025 on the investment side. Here are the articles this site relies on.

ArticleWhat it decidesUsed on
Permen Investasi/BKPM 5/2025 art. 23(2), (8)An individual business actor is classed as the domestic investment category — and an individual applicant must be an Indonesian citizen.PT PMA
Permen Investasi/BKPM 5/2025 art. 23(11)Foreign investment must be an Indonesian limited liability company.PT PMA
Permen Investasi/BKPM 5/2025 art. 23(13)A foreign individual shareholder is identified by the passport used when the company was founded, not by permanent residence of another country.—
Permen Investasi/BKPM 5/2025 art. 25(4)(c)A medium domestic business has business capital above IDR 5 billion up to IDR 10 billion, excluding land and buildings, or annual sales up to IDR 50 billion.accommodation codes
Permen Investasi/BKPM 5/2025 art. 25(6)For domestic accommodation and property, the scale tests do not exclude land and buildings.—
Permen Investasi/BKPM 5/2025 art. 26(1)A PMA is classed as a large business.accommodation codes
Permen Investasi/BKPM 5/2025 art. 26(2)Minimum investment value, per 5-digit KBLI per location: more than IDR 10 billion.HGB explained
Permen Investasi/BKPM 5/2025 art. 26(3)(b), (4)For food and beverage, counted per 2-digit KBLI group per location, a location being a regency or city.PT PMA
Permen Investasi/BKPM 5/2025 art. 26(5)For property and accommodation, the value is counted including land and buildings.investing
Permen Investasi/BKPM 5/2025 art. 26(6)(b)For scattered property units, the value is counted excluding land and buildings.HGB explained
Permen Investasi/BKPM 5/2025 art. 26(10)Issued/paid-up capital, per company: at least IDR 2.5 billion.PT PMA
Permen Investasi/BKPM 5/2025 art. 27(1)Paid-up capital stays in the company for at least 12 months, except to buy assets, construct a building or run the business.PT PMA
Permen Investasi/BKPM 5/2025 art. 392(1)Applications already in process were still processed under Perka BKPM 4/2021.—
Permen Investasi/BKPM 5/2025 art. 398(b)Perka BKPM 4/2021 is revoked.regulations index
Permen Investasi/BKPM 5/2025 art. 400The regulation was set on 1 October 2025 and promulgated on 2 October 2025.—

What changed from Perka BKPM 4/2021

RulePerka BKPM 4/2021 (revoked)Permen Investasi/BKPM 5/2025
Paid-up capitalat least IDR 10 billion (art. 12(7))at least IDR 2.5 billion (Permen Investasi/BKPM 5/2025 art. 26(10))
Investment valuemore than IDR 10 billion (art. 12(2))more than IDR 10 billion (Permen Investasi/BKPM 5/2025 art. 26(2))
Land and buildings, accommodationexcluded (the general rule of art. 12(2); the art. 12(3)(e) carve-out covered property development only)including land and buildings (Permen Investasi/BKPM 5/2025 art. 26(5))
Capital lock-up—at least 12 months, except to buy assets, construct a building or run the business (Permen Investasi/BKPM 5/2025 art. 27(1))

Three of the four rows move in the same direction: a foreign-owned accommodation business is easier to start on paper than it was. The capital is a quarter of what it was, and the land the business stands on now counts toward the investment value. This site said the opposite on the capital until 1 October 2026, and has corrected the pages that relied on the old figure.

The fourth row is new. The paid-up capital must stay in the company for at least 12 months, except to buy assets, construct a building or run the business (Permen Investasi/BKPM 5/2025 art. 27(1)). One drafting point: article 27(1) refers back to “article 26 paragraph (6)”, but the paid-up capital is set in paragraphs (9) and (10). We read the reference as meaning the capital, because 27(1) speaks of capital placed and paid up; the regulation does not say so in terms.

Large business, always — and why it matters more than the money

A PMA is classed as a large business (Permen Investasi/BKPM 5/2025 art. 26(1)). For a domestic investor, the scale depends on capital or sales; a medium business has business capital above IDR 5 billion up to IDR 10 billion, excluding land and buildings, or annual sales up to IDR 50 billion (Permen Investasi/BKPM 5/2025 art. 25(4)(c)). A foreign-owned company skips that ladder and starts at the top.

That classification meets the licensing lampiran of PP 28/2025, where the villa code is KBLI 55193 Villa: micro, small and medium businesses only; medium-low risk; NIB plus a standard certificate, issued automatically; regent or mayor (PP 28/2025 Lampiran I.L, KBLI 55193). The lower capital does not change it: a PT PMA with IDR 2.5 billion paid up is still a large business, and the villa code still stops at medium. Which accommodation codes run to large businesses.

In Bali there is a further layer. OSS has been closed to new PMA applications in 18 low and lower-medium risk KBLI, across Bali, since the third week of May 2026 (Bali Provincial Government release, 22 July 2026), including star hotels (55110) and non-star hotels (55120) under 6,000 m2, other accommodation (55900), and real estate owned or leased (68111) (ANTARA (state news agency), 23 July 2026). The national capital rule fell and the provincial door closed within the same year.

Who counts as foreign

An individual business actor must be an Indonesian citizen, and individual activity is classed as the domestic investment category — and an individual applicant must be an Indonesian citizen (Permen Investasi/BKPM 5/2025 art. 23(2), (8)). Foreign investment must be an Indonesian limited liability company (Permen Investasi/BKPM 5/2025 art. 23(11)). A foreign individual shareholder is identified by the passport used when the company was founded, not by permanent residence of another country (Permen Investasi/BKPM 5/2025 art. 23(13)). For a long-term Bali resident with a KITAS or KITAP, that settles a frequent question: residence does not change the category, nationality does.

The changeover

The regulation was set on 1 October 2025 and promulgated on 2 October 2025 (Permen Investasi/BKPM 5/2025 art. 400). Applications already in process when the new OSS went live were still processed under Perka BKPM 4/2021 (Permen Investasi/BKPM 5/2025 art. 392(1)); those not decided in time were returned for a fresh application. A company formed before October 2025 was formed under the old capital rule, and nothing in the articles we have read requires it to reduce its capital.

We do not set up companies and do not recommend anyone who does. This is commentary on the official text, not a translation and not legal advice.

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Questions on this page

What is the minimum paid-up capital for a PT PMA in 2025?

At least IDR 2.5 billion per company, under Permen Investasi/BKPM 5/2025 article 26(10), unless other legislation provides otherwise. It replaced the IDR 10 billion figure of Perka BKPM 4/2021, which article 398(b) revoked. The separate investment value of more than IDR 10 billion per 5-digit KBLI per location (article 26(2)) did not change.

Can a PT PMA withdraw its paid-up capital?

Not for at least 12 months from payment, except to buy assets, construct a building or run the business (article 27(1)). The commitment is given as a self-declaration when applying through OSS (27(2)), and breaching it brings administrative sanctions (27(4)).

Does land count toward the PT PMA investment value for a villa or hotel?

Yes. Article 26(5)(b) counts land and buildings in for short- and long-term accommodation, and 26(5)(a) for property businesses. Article 26(6)(b) keeps them out for property units that are not in one whole building or one integrated complex.

Does a permanent resident count as a foreigner for PT PMA purposes?

Article 23(13) identifies a foreign individual by the passport used when the company was founded, and says permanent-resident status in another country does not count. Nationality is what matters, not residence.

When did Permen Investasi/BKPM 5/2025 take effect?

It was set on 1 October 2025 and promulgated on 2 October 2025, taking effect on promulgation (article 400). Article 399 gave the OSS agency until 5 October 2025 to adjust the system.

Sources cited on this page

  1. Permen Investasi/BKPM 5/2025 — official text, JDIH BPK
  2. Perka BKPM 4/2021 (revoked) — JDIH BPK
  3. PP 28/2025 Lampiran I.L
  4. Bali Provincial Government, OSS access for PMA, 22 July 2026
  5. ANTARA, the 18 business lines closed to PMA in Bali, 23 July 2026

Every rule above was read in the Indonesian original on 20 September 2026, not from an English summary. How we check this.

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