
Value Added Tax on Cross-Border Digital Sales in Indonesia
Selling digital products or services to customers in Indonesia can create tax questions for businesses based overseas.

The implementation of KBLI 2025 has raised an important question among businesses across Indonesia: Do I need to update my OSS licenses because of KBLI 2025?
Since the updated Indonesian business classification system (KBLI) was introduced, many companies have been unsure whether their existing licenses, permits, and NIB are still valid. Some assume that any change in KBLI automatically means they must update their OSS records, while others are unclear whether any action is needed at all.
To provide clarity, the Government issued transition guidance through the Joint Circular Letter of the Minister of Investment and Downstreaming, the Minister of Law, and the Head of Statistics No. 4.S/2026. This circular explains how KBLI 2025 should be implemented within Indonesia’s licensing framework.
The good news is that not every KBLI adjustment requires businesses to obtain new licenses or immediately amend their OSS records. However, companies should still understand how KBLI affects licensing requirements and whether their business operations require further review.
To determine whether any updates are needed, businesses first need to understand how KBLI relates to the OSS (Online Single Submission) system.
KBLI forms the basis of Indonesia’s risk-based licensing framework. When a business registers through OSS, the selected KBLI code determines:
In short, OSS relies on KBLI to decide what licenses and approvals a business must have before it can operate legally.
The licensing structure generally consists of:
The classification code that identifies the business activity.
The primary business identification issued through OSS.
Indonesia's business licensing framework classifies activities according to risk levels, ranging from low-risk to high-risk activities.
Business licenses required based on the risk level and business activity.
Additional specific permits or approvals required by relevant ministries or government institutes for business with certain activity to support their business operations.
For example, a software development company and a telecommunications operator may both operate within the same technology sector, but because they use different KBLI classifications, they may face different licensing requirements within OSS.
This is why any change to a KBLI classification can potentially affect licensing obligations, even when the business itself has not changed.
One of the most important points clarified by the Government is that existing licenses generally remain valid.
Under Joint Circular No. 4.S/2026, the transition to KBLI 2025 does not automatically invalidate previously issued:
The Government has made it clear that the transition should not create unnecessary burdens or disrupt business operations.
In other words, businesses are not required to obtain entirely new licenses simply because the classification system has changed.
However, companies should still review whether their current business activities remain aligned with the applicable KBLI 2025 classifications.
A key feature of the KBLI 2025 transition is automatic conversion.
In some cases, businesses do not need to take any action because the OSS and AHU systems can automatically adjust to the updated KBLI classifications.
Automatic conversion generally applies where:
The conversion process is supported by:
OSS System
The OSS platform may automatically update licensing records based on official conversion mappings.
AHU System
Corporate registration data managed through the Ministry of Law's AHU system may also be adjusted according to the conversion framework.
For example, if an old KBLI code and a new KBLI code describe exactly the same business activity but use different code numbers, the adjustment may be processed automatically without requiring the company to amend its licenses.
This approach is intended to simplify the transition process and reduce administrative burdens on businesses.
Even with automatic conversion, businesses should not assume that no further action is needed.
A review is recommended in the following situations:
Business Activities Have Expanded
Businesses that have added new products, services, or operational activities may require additional KBLI classifications.
Business Activities Have Developed
Many companies have transformed their business models since their original OSS registration may require updated or additional KBLI classifications.
Multiple KBLI Codes Exist
Companies operating under several KBLI classifications should verify whether all classifications remain appropriate under KBLI 2025.
Significant Conversion Changes Occur
If the KBLI conversion table indicates that a classification has been split, merged, or substantially revised, further review may be required.
New Classifications Better Suited Business Operations
KBLI 2025 introduces new categories, especially for digital and emerging industries. These may better reflect actual business activities.
For instance, a digital company that has shifted into a platform-based model may now find a more accurate classification under KBLI 2025. While automatic conversion helps, a more detailed review is still recommended to ensure compliance.
The NIB remains tied to the KBLI classifications recorded in OSS.
In most cases, the NIB itself remains valid. However, businesses should review the underlying data if:
In short, the NIB stays valid, but the supporting data should still be checked for accuracy.
Indonesia’s licensing framework is based on risk levels. Changes in KBLI classification may affect:
If a business is reclassified, its risk level may also change, which could trigger additional requirements. This is why businesses should assess whether their updated classifications could trigger additional licensing requirements.
Business Licenses (PB) are directly linked to the business activities identified through KBLI.
If a company's actual operations no longer align with the KBLI codes recorded in OSS, licensing records may require updating. Maintaining consistency between business activities and licensing records is essential for regulatory compliance.
PB UMKU refers to additional permits required in specific sectors.
Businesses in regulated industries may face greater impact if their classifications change, such as:
In some cases, a revised classification may introduce new licensing requirements that did not previously apply.
Before making any changes to OSS records, businesses should complete the following review:
Taking these steps can help businesses avoid compliance issues and ensure that licensing records remain accurate.
Do I need to update my NIB because of KBLI 2025?
Generally, no. Existing NIBs remain valid. However, businesses should review whether the underlying business activity classifications remain accurate.
Will my existing OSS licenses remain valid?
Yes. According to Joint Circular No. 4.S/2026, existing NIB, Basic Requirements (PD), PB, and PB UMKU generally remain valid during the transition to KBLI 2025.
Is KBLI conversion automatic?
In certain cases, yes. Administrative updates may be processed automatically through OSS and AHU systems.
How can I check whether my business is affected?
Review your current KBLI codes, compare them against the official conversion table, and assess whether the KBLI classifications accurately reflect your actual business activities.
What happens if my OSS data does not match my activities?
Inaccurate OSS data may create licensing, compliance, and regulatory risks. Businesses should ensure that their recorded KBLI classifications align with their actual operations.
The transition to KBLI 2025 does not automatically invalidate existing NIBs, business licenses, or supporting permits. In many cases, system updates will be handled automatically, allowing businesses to continue operating without disruption.
However, companies should not rely solely on automatic conversion. Reviewing KBLI classifications, OSS data, licensing requirements, and actual business activities remains essential to staying compliant.
Businesses that have expanded, changed their business models, or operate under multiple classifications should pay close attention to this transition and assess whether updates are needed.
Need Help Reviewing Your OSS Licenses?
CPT Corporate can help your business navigate the KBLI 2025 transition. Our team can assist with:
Contact CPT Corporate today to ensure your business remains fully compliant under KBLI 2025 and Indonesia’s evolving licensing framework.
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