Indonesia has significantly reshaped its foreign investment landscape over the past few years, moving away from restrictive policies toward a more open, pro-investment framework. For foreign investors, multinational companies, and founders planning to enter Southeast Asia’s largest economy, one question continues to dominate early-stage discussions: which sectors allow 100% Foreign Ownership in Indonesia?
The answer lies in Indonesia’s Positive Investment List, a regulatory framework that reversed the country’s long-standing “negative list” approach. While the core Positive Investment List remains unchanged as of 2025, recent regulatory updates have refined how licensing and implementation work in practice. Understanding this distinction is critical for investors who want clarity, certainty, and compliance.
This article provides a practical, up-to-date breakdown of the Positive Investment List, explains how 100% Foreign Ownership works in real-world application, highlights sectors that are fully open, and clarifies what changed — and did not change — under Indonesia’s 2025 investment updates.
What Is the Positive Investment List?
Indonesia’s Positive Investment List was introduced through Presidential Regulation No. 10 of 2021, later amended by Presidential Regulation No. 49 of 2021. Together, these regulations replaced the former Negative Investment List (DNI) and fundamentally altered how foreign ownership is regulated.
Instead of listing which sectors are closed or restricted, the Positive Investment List operates on a simple principle: all business fields are open to investment, including foreign investment, unless expressly stated otherwise.
From a foreign investor’s perspective, this means 100% Foreign Ownership is allowed by default, provided the business activity does not fall under restricted, conditional, or reserved categories listed in the regulation’s annexes.
As of 2025, there has been no new presidential regulation replacing or superseding the Positive Investment List. The ownership rules governing 100% Foreign Ownership remain anchored in Perpres 10/2021 as amended by Perpres 49/2021.
Important Clarification: What Changed in 2025?
A common source of confusion among investors is the belief that Indonesia issued a “new Positive Investment List” in 2025. This is not accurate.
What did change in 2025 were implementation and licensing regulations, not the ownership list itself.
New government and ministerial regulations refined how business licensing, risk categorization, capital requirements, and OSS (Online Single Submission) procedures operate. These updates affect how investors establish and operate companies, but not which sectors allow 100% Foreign Ownership.
In short:
- Ownership eligibility → still governed by the Positive Investment List (Perpres 10/2021 & 49/2021)
- Licensing, capital, and risk classification → refined through 2025 implementing regulations
This distinction is crucial and often misunderstood.
How the Positive Investment List Is Structured
To determine whether 100% Foreign Ownership is permitted, business activities are grouped into four main categories under the Positive Investment List.
Fully Open Business Fields
These are business activities where no foreign ownership limitation applies. Foreign investors may own 100% of the shares in a PT PMA, subject only to standard corporate, licensing, and reporting requirements.
This category represents the majority of business fields under the current framework and reflects Indonesia’s shift toward openness.
Priority Business Fields
Priority sectors are industries that the Indonesian government actively encourages due to their economic, technological, or strategic value. These sectors typically allow 100% Foreign Ownership and may qualify for fiscal incentives such as tax holidays or tax allowances, as well as non-fiscal incentives like streamlined licensing.
Priority status does not automatically grant incentives, but it significantly strengthens the investment case.
Business Fields with Specific Conditions
Some sectors allow foreign investment but impose conditions, such as:
- foreign ownership caps
- special licensing requirements
- operational limitations
In these sectors, 100% Foreign Ownership is not permitted, even though partial foreign participation may be allowed.
Business Fields Reserved or Closed
A limited number of activities are either:
- reserved for the government,
- allocated to cooperatives and MSMEs, or
- fully closed to foreign investment.
In these cases, 100% Foreign Ownership is prohibited by law.
Sectors That Commonly Allow 100% Foreign Ownership
While investors must always verify the exact KBLI (business classification) code, several broad sectors are widely recognized as allowing 100% Foreign Ownership under the Positive Investment List.
Manufacturing and Industrial Processing
Manufacturing remains one of the most open sectors for foreign investors. Many KBLI classifications covering industrial production, component manufacturing, and export-oriented processing allow full foreign ownership.
Indonesia actively promotes downstream manufacturing, particularly where it supports job creation, technology transfer, or export growth. As a result, many manufacturing activities also fall under priority sectors.
Technology, Software, and Digital Services
Indonesia’s rapidly expanding digital economy is another area where 100% Foreign Ownership is commonly permitted. Software development, IT consulting, SaaS platforms, and digital solutions businesses are generally open to full foreign ownership.
While ownership is open, companies must still comply with data protection, cybersecurity, and sector-specific regulations. From a shareholding perspective, however, foreign founders often retain full control.
Renewable Energy and Sustainability Projects
Renewable energy, clean technology, and environmentally focused projects are frequently listed as priority business fields. These sectors not only allow 100% Foreign Ownership, but may also benefit from investment incentives.
This aligns with Indonesia’s broader sustainability and energy transition goals, making green investment increasingly attractive for foreign capital.
Logistics, Warehousing, and Business Support Services
Many logistics and supply chain support activities, including warehousing and distribution services, allow full foreign ownership. As Indonesia strengthens its regional trade and logistics infrastructure, these sectors continue to draw international interest.
Professional and business support services — such as management consulting and non-regulated advisory services — are also often open to 100% Foreign Ownership.
Sectors Where 100% Foreign Ownership Remains Limited
Despite the broad openness of the Positive Investment List, some sectors remain sensitive.
Natural resource extraction, certain media and broadcasting activities, and strategic infrastructure sectors may impose ownership caps or additional conditions. Similarly, business fields reserved for MSMEs require partnership arrangements, making full foreign ownership impossible.
These restrictions highlight why KBLI accuracy is critical. Two businesses that sound similar on paper may fall under different ownership rules depending on classification.
How to Confirm Whether 100% Foreign Ownership Is Allowed
The most reliable way to confirm ownership eligibility is to:
- Identify the precise business activity.
- Match it to the correct KBLI code.
- Check the KBLI against the Positive Investment List annex.
- Confirm licensing requirements through Indonesia’s OSS system.
Errors at this stage can lead to rejected licenses or forced ownership restructuring after incorporation. This is one of the most common and costly mistakes foreign investors make.
Frequently Asked Questions (FAQ)
Does 100% Foreign Ownership eliminate all regulatory requirements?
No. 100% Foreign Ownership only addresses shareholding. Companies must still comply with licensing, capital, reporting, tax, and sector-specific regulations.
Did Indonesia issue a new Positive Investment List in 2025?
No. The Positive Investment List under Perpres 10/2021 and Perpres 49/2021 remains in force. Updates in 2025 focused on licensing and implementation, not ownership permissions.
Can ownership rules change in the future?
Yes. Investment policy evolves over time. Investors should always verify the latest regulations before committing capital.
Why the Positive Investment List Matters for Foreign Investors
The Positive Investment List has significantly improved legal certainty and flexibility for foreign investors. By expanding sectors that allow 100% Foreign Ownership, Indonesia enables foreign companies to retain control, protect intellectual property, and align Indonesian operations with global corporate governance standards.
At the same time, the framework demands careful planning. Openness does not remove the need for precision, compliance, and regulatory awareness.
Conclusion
Indonesia’s Positive Investment List represents a fundamental shift toward openness and investor confidence. As of 2025, 100% Foreign Ownership is permitted in a wide range of sectors, particularly in manufacturing, technology, renewable energy, and business services.
However, ownership eligibility is determined at the KBLI level, not by broad sector labels. The absence of a “new” Positive Investment List in 2025 does not reduce opportunities — instead, recent updates have improved how investments are implemented and licensed.
With proper structuring and accurate classification, the Positive Investment List remains one of the most investor-friendly frameworks Indonesia has ever offered.
Determining whether your business activity allows 100% Foreign Ownership requires more than reading a summary of regulations. It requires accurate KBLI analysis, licensing strategy, and long-term compliance planning.
CPT Corporate assists foreign investors with KBLI assessment, PT PMA establishment, OSS licensing, and regulatory compliance to ensure ownership structures are correct from the start. If you are planning to enter or expand in Indonesia, professional guidance can help you move faster while minimizing legal and operational risk.
