Indonesia’s investment policy has undergone a structural shift that is still widely misunderstood outside the country. While headlines often focus on licensing hurdles or regulatory complexity, a more consequential change has been unfolding in the background: a broad expansion of sectors that allow full foreign ownership.
For international investors assessing Southeast Asia, Indonesia’s Positive Investment List has become a central reference point. Introduced in 2021 and still in force today, the framework fundamentally reversed Indonesia’s traditional approach to foreign investment. Instead of specifying what foreign investors cannot do, the system now assumes openness—placing restrictions only where they are explicitly stated. As a result, 100 percent foreign ownership is no longer the exception, but increasingly the default.
Indonesia’s Positive Investment List was introduced through Presidential Regulation No. 10 of 2021, later refined by Presidential Regulation No. 49 of 2021. Together, they replaced the former Negative Investment List, which for decades limited foreign ownership across wide segments of the economy.
Under the current model, all business activities are considered open to investment, including foreign investment, unless they are expressly restricted, conditional, or reserved. For foreign companies, this change dramatically alters the starting assumption when evaluating market entry. Instead of asking whether a sector is open, investors now ask whether it is specifically closed.
Importantly, this ownership framework remains unchanged as of 2025. While Indonesia introduced several new implementing regulations this year, those updates focused on licensing mechanics and risk-based supervision, not on foreign ownership limits.
One persistent misconception is that Indonesia released a “new” Positive Investment List in 2025. It did not.
What changed were the rules governing how businesses are licensed and supervised through the Online Single Submission (OSS) system. These refinements affect capital thresholds, risk categorization, and procedural timelines, but they do not alter which sectors permit full foreign ownership.
This distinction matters. Investors who assume ownership rules tightened in 2025 may delay or abandon projects that remain fully permissible under existing law.
The Positive Investment List organizes business activities into four broad categories.
The largest group consists of fully open business fields. These activities allow foreign investors to own 100 percent of shares in a PT PMA, subject to standard incorporation, licensing, and reporting requirements.
A second category covers priority business fields. These are sectors the government actively encourages due to their economic or strategic importance. Most priority sectors also allow full foreign ownership and may qualify for fiscal or non-fiscal incentives, though incentives are not automatic.
Other categories include business fields that are open with conditions—such as foreign ownership caps or special approvals—and a limited group of activities that are reserved for domestic enterprises or closed entirely to foreign investment.
In practice, the fully open category now covers a majority of Indonesia’s economic activities.
Manufacturing remains one of the most open sectors for foreign investors. Many industrial, processing, and export-oriented manufacturing activities allow 100 percent foreign ownership, reflecting Indonesia’s push to strengthen domestic value chains.
Technology and digital services are similarly open. Software development, IT consulting, and many digital platforms permit full foreign ownership, provided companies comply with sector-specific rules on data protection and system registration.
Renewable energy and sustainability-related projects are also widely open and often classified as priority sectors. These projects align with Indonesia’s long-term energy transition goals and frequently attract international capital.
Logistics, warehousing, and various business support services—including non-regulated professional services—are likewise open in many cases, supporting Indonesia’s role as a regional trade and services hub.
Despite the broad openness, some sectors remain sensitive. Natural resource extraction, certain media and broadcasting activities, and strategic infrastructure may impose ownership caps or additional conditions. Other activities are reserved for cooperatives or micro and small enterprises, effectively excluding full foreign ownership.
These distinctions are not always intuitive. Two businesses that appear similar commercially may fall under different ownership regimes depending on how they are classified. This is why accuracy at the business classification (KBLI) level is critical.
Ownership eligibility in Indonesia is determined not by broad sector labels, but by specific KBLI codes. A single misclassification can lead to rejected licenses or force restructuring after incorporation—often at significant cost.
Confirming whether 100 percent foreign ownership is permitted requires careful alignment between the intended activity, its KBLI classification, and the Positive Investment List annexes. It also requires coordination with the OSS licensing system to ensure consistency across filings.
This technical layer is where many foreign investors encounter difficulty, particularly those entering Indonesia for the first time.
The expansion of fully open sectors has improved legal certainty for foreign investors. Full ownership allows companies to retain operational control, protect intellectual property, and align Indonesian subsidiaries with global governance standards.
At the same time, openness does not eliminate regulatory complexity. Licensing, reporting, and compliance obligations remain robust, and mistakes at the incorporation stage can have long-term consequences.
This is why many international businesses rely on professional support when handling company registration and ownership structuring in Indonesia. Advisory firms such as CPT Corporate are often referenced by investors navigating KBLI analysis, PT PMA establishment, and OSS licensing to ensure ownership structures are correct from the outset.
Indonesia’s Positive Investment List reflects a broader policy direction. The country is positioning itself as more open, predictable, and aligned with global investment norms—while still maintaining safeguards in strategic areas.
For foreign media observers, the takeaway is not that Indonesia has removed all barriers, but that it has recalibrated how openness is defined. The rules are clearer, more permissive, and more stable than in previous decades.
As of 2025, Indonesia’s foreign ownership framework remains one of the most open it has ever been. Investors who understand how the Positive Investment List operates—and who approach classification and licensing with precision—are well positioned to take advantage of the opportunities it offers.
