Indonesia’s Positive Investment List

Indonesia’s Positive Investment List is officially the Daftar Prioritas Investasi (DPI) inside Indonesia’s rules on Business Fields for Investment (Bidang Usaha Penanaman Modal / BUPM).

It replaced the old “Negative Investment List” approach by making the baseline “open unless restricted”, then putting restrictions/conditions into annexes tied to KBLI business codes.

 

What It Is

Indonesia replaced the old Negative Investment List (DNI) with a “Positive Investment List” approach under Presidential Regulation (Perpres) No. 10 of 2021, later amended by Perpres No. 49 of 2021.

The key idea is business fields are generally open, except those that are closed, reserved, or open with conditions (including foreign ownership caps, partnership requirements, licensing, and location restrictions).

For PT PMA planning, DPI is the starting point because it affects:

• whether your KBLI is allowed for foreign ownership,
• how much foreign ownership is permitted (e.g., 100%, 67%, 49%, etc.),
• whether you must partner with UMKM/cooperatives,
• whether you qualify for incentives as a “priority” line.

Note: The PMA establishment and licensing process is conducted through OSS RBA (Online Single Submission with Risk-Based Approach), which streamlines document submission and regulatory compliance.

 

The Legal Backbone

Core regulations:

• Perpres 10/2021 on Investment Business Fields (Bidang Usaha Penanaman Modal).
• Perpres 49/2021 amending Perpres 10/2021 (important changes in the Annex and certain provisions).

Where the “list” actually lives:

The DPI is mostly implemented via the Annex (Lampiran) of the Perpres, organized by KBLI (Klasifikasi Baku Lapangan Usaha Indonesia) codes.

 

Priority Sectors under Indonesia’s Positive Investment List

Under Indonesia’s Positive Investment List (Daftar Prioritas Investasi), certain business fields are classified as priority sectors. These sectors receive special attention from the government and may qualify for fiscal and non-fiscal incentives.

To be classified as a priority sector, a business must meet one or more of the following criteria:

• Labor-intensive industries that generate significant employment
• Capital-intensive projects with substantial investment value
• Businesses supporting national strategic projects or programs
• Export-oriented industries
• Pioneer industries, such as renewable energy, oil refining, or metal processing
• Activities utilizing advanced or high-tech solutions
• Businesses that conduct structured research and development (R&D)

Currently, the DPI lists over 245 business fields, including 14 open investment sectors and 6 closed sectors. Of these, 153 business fields are designated for cooperatives and SMEs. Additionally, 46 sectors have specific restrictions for foreign investors, and 30 sectors impose a maximum foreign ownership limit.

Once you determine your KBLI/business field in the DPI, check whether it is classified as low, medium, or high risk. This classification affects the documentation and approvals required to establish a PMA.

 

Incentives for Priority Sector Businesses

Companies operating in priority sectors are eligible for a combination of fiscal and non-fiscal incentives, depending on the scale and nature of the investment.

Fiscal Incentives

Fiscal incentives may include:

• Corporate Income Tax (CIT) reduction
  • 50% CIT reduction for investments between IDR 100–500 billion for 5 years
  • 100% CIT reduction (tax holiday) for investments above IDR 500 billion, for 5 to 20 years
• Tax allowances, such as:
  • Reduction of taxable income by 30% of total investment over 6 years
  • 10% withholding tax on dividends
  • Loss carry-forward period of up to 10 years

Non-Fiscal Incentives

Non-fiscal incentives may include:

• Provision of supporting infrastructure
• Simplified business licensing
• Priority access to energy supply and raw materials

 

Examples of Priority Business Sectors and Incentives

Business Sector	Incentive Type
Textile and garment industry	Tax allowance / investment allowance
Pharmaceutical industry	Tax allowance
Digital economy (data processing, hosting, etc.)	Tax holiday
Geothermal exploration and drilling	Tax allowance
Cooking palm oil industry	Tax allowance
Iron and steel industry	Tax allowance
Automotive industry	Tax allowance
Oil and gas refinery	Tax holiday
Cosmetics industry	Tax allowance
Coal gasification	Tax allowance

 

Business Fields Open with Specific Requirements or Limitations

Some business fields are open to foreign investment, but subject to specific restrictions or conditions. These typically fall into one or more of the following categories:

• Reserved exclusively for domestic investors
• Subject to foreign ownership caps
• Requiring special licenses from relevant authorities
• Strictly regulated or supervised under sector-specific laws

This category also includes business activities related to alcoholic beverages, which are tightly controlled.

Alcohol-Related Business Lines with Restrictions

• Wholesale trade of alcoholic beverages (importers, distributors, sub-distributors)
• Retail trade of alcoholic beverages
• Street-level retail of alcoholic beverages

 

Selected Business Fields with Ownership Restrictions

Business Field	Key Requirement
Newspaper and magazine publishing	100% domestic capital for establishment; up to 49% foreign ownership for expansion
Private broadcasting	100% domestic capital for establishment; up to 20% foreign ownership
Subscription-based broadcasting	100% domestic capital for establishment; up to 20% foreign ownership
Postal services	Maximum foreign capital ownership of 49%
Domestic air transportation	Max 49% foreign ownership; domestic shareholders must be the single majority
Sea transportation (domestic & overseas)	Max 49% foreign ownership
Weapons and defense equipment	Ownership subject to Ministry of Defense approval
Horticulture	Max 30% foreign ownership
Traditional medicine products	100% domestic capital
Fish processing	100% domestic capital
Traditional handicrafts, batik, cosmetics	100% domestic capital
Hajj and Umrah services	100% domestic capital; Muslim-owned

 

Exceptions to Foreign Ownership Limits

Foreign ownership restrictions do not apply in the following situations:

• Investments located within Special Economic Zones (SEZs)
• Non-direct investments made through the Indonesian Stock Exchange
• Investments covered by bilateral or multilateral treaties granting more favorable treatment
• Investments approved before the issuance of the Positive Investment List (grandfathering policy)

 

Business Fields Requiring Mandatory MSME Partnerships

Certain business fields are open to foreign or large-scale investors only through compulsory partnerships with MSMEs (Micro, Small, and Medium Enterprises) or cooperatives.

There are 106 business lines under this category, typically characterized by:

• Use of non-advanced technology
• Labor-intensive or culturally rooted activities
• Capital requirements not exceeding IDR 10 billion (excluding land/buildings)

Partnership arrangements may take the form of:

• Operational cooperation
• Profit-sharing agreements
• Subcontracting or outsourcing
• Distribution partnerships

This policy aims to integrate MSMEs into larger supply chains while preserving local economic participation.

 

Business Fields Open to 100% Foreign Ownership

The following sectors are fully open to 100% foreign investment:

• Oil and gas construction and drilling services
• Onshore and offshore oil and gas pipelines
• Electricity generation and installation
• Geothermal power generation
• Supermarkets (under 1,200 sqm)
• Department stores (400–2,000 sqm)
• Ports and port services
• Airports and airport support services
• Maritime cargo handling
• Telecommunications
• E-commerce platforms
• Pharmaceutical manufacturing
• Hospitals

Foreign nationals can verify whether a KBLI/business field allows 100% foreign ownership or requires a partnership with Indonesian entities. This can be checked in the DPI (Perpres 49/2021) or directly via the OSS portal.

Some sectors, such as healthcare, mining, and construction, are governed by additional sector-specific regulations that must be followed even if listed in the DPI.

 

Business Fields Closed to Investment

Indonesia strictly prohibits investment (both domestic and foreign) in the following sectors:

• Class-I narcotics cultivation and production
• Gambling and casino activities
• Fishing of endangered species
• Commercial use of natural corals
• Chemical weapons manufacturing
• Alcoholic beverage manufacturing (including wine and malt-based alcohol)
• Production of ozone-depleting substances and certain industrial chemicals

 

Minimum “large-scale” investment rule (important for PT PMA)

Perpres 10/2021 elevated a key principle: foreign investors are generally expected to operate at “large-scale”, commonly summarized as minimum investment value of more than IDR 10 billion (excluding land/buildings) per business line/project (implementation details are commonly handled in BKPM/OSS practice and related regulations, but the Perpres level made the concept more explicit).

This matters because it affects feasibility for “small lifestyle businesses” and is one reason many small activities end up better structured via local PT (PMDN) + agreements (depending on legality and substance).

 

Where to get the official tables

• BKPM “Indonesia Investment Guidebook” (government guide referencing the framework).