The KBLI codes for a dive resort and liveaboard operation in Indonesia typically combine 55111 or 55112 (star-rated or non-star hotel) for the accommodation, 93119 or 93299 for diving and marine recreation, 50119 for sea passenger or charter transport, and 56101 or 56102 if you run a restaurant or café as a commercial activity. A PT PMA, the foreign-owned limited company, registers one or more of these five-digit KBLI 2020 classifications in its deed of establishment and in the OSS (Online Single Submission) licensing system, and every later permit hangs off that selection. Get the codes right at incorporation and the licensing chain tends to follow in sequence. Get them wrong, and the problem stays invisible until the day you apply for an alcohol permit, a vessel operating license, or a marine park concession and discover the system has no basis to grant it.
This article maps the candidate codes for a combined resort, dive, boat and restaurant operation in a setting like Raja Ampat, explains how to prioritize them by revenue stream, and walks through the quiet ways a mismatched code blocks growth later. It is editorial information, not legal or financial advice, and KBLI entries plus their foreign-ownership conditions change. Verify everything against the live OSS system with a licensed notaris or setup consultant before you sign a deed.
What a KBLI Code Actually Does Inside a PT PMA
KBLI stands for Klasifikasi Baku Lapangan Usaha Indonesia, the standard business field classification maintained by Statistics Indonesia (BPS). The current edition is KBLI 2020. Every Indonesian company, foreign-owned or local, declares its business activities as five-digit KBLI codes, and those codes are not decorative. Three consequences flow from them.
First, the OSS risk-based licensing system (built under Government Regulation 5/2021, part of the Omnibus Law architecture) assigns a risk level to each code: low, medium or high. That risk level determines whether your NIB (Nomor Induk Berusaha, the business identification number) alone is enough to operate, or whether you need additional standard certificates and operational licenses on top.
Second, the Positive Investment List (Presidential Regulation 10/2021, as amended by 49/2021) is written per KBLI line. Whether a foreigner can own 100 percent of the activity, a capped percentage, or nothing at all is decided code by code. Most large-scale tourism activities are open to full foreign ownership; micro and small-scale activities are generally reserved for Indonesian MSMEs and cooperatives.
Third, the investment commitment attaches to the code. The widely applied rule treats a PT PMA as a large enterprise with an investment plan above IDR 10 billion per KBLI code per project location, excluding land and buildings, with paid-up capital commonly cited at IDR 2.5 billion under recent BKPM practice. Advisors quote these figures inconsistently, and they have moved before. Confirm the in-force numbers before budgeting.
The Candidate Codes for a Resort, Liveaboard and Restaurant Operation
Marine tourism is fragmented across the accommodation (55xxx), food and beverage (56xxx), travel (79xxx), recreation (93xxx) and sea transport (50xxx) chapters of KBLI 2020. No single code covers a dive resort with its own boats and kitchen. The table below maps the usual candidates. Treat the descriptions as orientation, not gospel; the binding text is the official KBLI entry as displayed in OSS on the day you file.
| KBLI code | Activity (KBLI 2020) | When you need it |
|---|---|---|
| 55111 | Star-rated hotel | Resort accommodation positioned and licensed at star classification; often relevant to alcohol licensing later |
| 55112 | Non-star hotel (melati) | Smaller lodge or bungalow operation that will not pursue star rating |
| 56101 | Restaurant | A restaurant serving guests and outside customers as a commercial activity, not just included board |
| 56102 | Café / eating establishment (warung-scale lines exist nearby; check the exact entry) | A beach café or bar-style outlet distinct from the main restaurant |
| 79121 | Travel agency | Selling third-party travel products: transfers, flights, other operators’ trips |
| 79122 | Tour operator | Packaging and selling your own multi-component trips and itineraries |
| 93119 / 93299 | Sports facility / other recreation and amusement activities (diving and marine recreation typically sit in this cluster) | Running the dive center: guided dives, courses, equipment, snorkel trips |
| 50119 | Sea transport of passengers (non-scheduled / charter lines sit in this group) | Carrying paying passengers on your vessel: liveaboard berths, charters, inter-island transfers |
Accommodation: 55111 vs 55112
The choice is partly about ambition. A star-rated hotel code signals a different inspection and classification pathway than a non-star lodge, and some downstream permits, alcohol service among them, have historically been easier to anchor to a star-rated establishment. A ten-bungalow eco-resort on a clan-leased island may sensibly start at 55112. Note that very small accommodation lines, such as pondok wisata and homestay-scale codes, are generally reserved for Indonesian small business and are not open to a PT PMA at all.
Recreation vs transport: the line that trips up liveaboards
Here is the distinction that matters most for a dive operation with boats. Taking guests diving from a resort jetty is recreation, the 93xxx cluster. Selling cabins on a vessel that sails multi-day routes through the Dampier Strait is passenger transport, the 50xxx cluster, with its own maritime regime: ship registration, flagging and cabotage rules, crewing and safety certification. Many operators need both. Assuming the dive-recreation code covers the boat is one of the most common structural mistakes we see described in setup disputes.
How to Choose: Follow the Primary Revenue Stream
Because the investment-plan requirement is commonly applied per KBLI per location, every code you add can carry weight. The discipline is to identify where the money actually comes from, register that activity as the lead code, and add supporting codes deliberately rather than defensively.
Resort-led operation
If most revenue is room-plus-board packages, lead with 55111 or 55112. The dive center becomes the supporting 93xxx code. If meals are bundled into the package and you never sell food separately, some structures treat F&B as part of the hotel activity; the moment you open the restaurant to walk-in or yacht traffic, 56101 becomes its own commercial line.
Liveaboard-led operation
If the asset is a phinisi and the product is a seven-night route, the gravitational center shifts to sea transport (50119 area) plus the recreation code for the diving itself, with 79122 if you package land extensions. Vessel ownership and operation by a foreign-controlled company sits under maritime law as well as investment law, and the two must be checked together.
Restaurant as a third leg
A standalone beach restaurant aimed at the public is its own activity and its own license trail: food hygiene certification, local tourism business registration, and potentially alcohol permits. Registering it as an afterthought under the hotel code is exactly the kind of shortcut that surfaces later as a refusal.
If you are mapping a specific Raja Ampat project and want a structured second pair of eyes on the code stack before you brief a notaris, you can request a briefing or reach us on WhatsApp. We can also introduce vetted independent setup partners who work with the OSS system daily. We publish intelligence; they execute filings.
Why Multiple KBLI Codes Are Normal, Not a Red Flag
A combined resort, dive and restaurant business is genuinely several activities under one roof, and Indonesian practice expects the deed to say so. Three to five codes is unremarkable for an integrated marine tourism operation. What matters is coherence. The codes should describe activities you will actually perform at the declared location, because each one generates its own compliance trail: quarterly LKPM investment-activity reports to BKPM are filed against your registered activities, and an abandoned code you never operate still sits in your record.
Two cautions temper the “add everything” instinct. The per-KBLI, per-location investment-plan rule means a casually added code can inflate your committed investment on paper, although sector exceptions exist for certain activities in one location. And every additional high-risk code can raise the verification burden on your NIB. Lean, accurate, complete. That is the target.
How a Wrong Code Quietly Blocks Later Licenses
The failure mode is rarely a rejection letter at incorporation. OSS will happily issue an NIB for a plausible but mismatched code. The block appears months or years later, downstream.
The liquor example
Alcohol licensing in Indonesia is tied to the character of the establishment in your licensing record. Applications typically anchor to star-rated hotel or qualifying restaurant and bar classifications. A resort that incorporated under a guesthouse-scale code, with no separate restaurant line, can find there is simply no registered activity for an alcohol-serving permit to attach to. Fixing it means amending the deed, updating OSS, and possibly restating the investment plan. Months, not days.
The marine operations example
A company holding only the dive-recreation code that starts selling overnight berths is operating passenger transport without the corresponding classification. In a managed environment like the Raja Ampat marine protected area, where the Marine Park Authority layers its own permits, entrance-fee administration and mooring rules on top of national licensing, an operator whose company-level codes do not match the activity has a structural problem that no goodwill at the local office can paper over.
The compounding cost
Adding a KBLI code after the fact is possible. It requires a shareholders’ resolution, a notarial deed amendment, Ministry of Law notification, and an OSS update, after which the new code is screened at its own risk level and foreign-ownership conditions as they stand on that day, not the day you incorporated. If the rules tightened in between, you inherit the new version.
Verify Against the Live OSS System. Always.
Every code in this article is a well-established reference point, and every one of them should still be checked the week you file. KBLI entries get reinterpreted, risk levels get reassigned, and the Positive Investment List annex is amended. The OSS portal shows the current entry text, risk level and requirements for each code; a licensed notaris or experienced setup consultant will read those entries against your actual business plan and catch the mismatches a founder cannot. In Raja Ampat specifically, where adat land arrangements, MPA zoning and maritime rules already stack on top of company law, the KBLI selection is the one variable you fully control at the start. Control it well. And to repeat the standing caveat: this is information and analysis, not legal, tax or investment advice.
Frequently Asked Questions
Can one PT PMA hold all the KBLI codes for a resort, liveaboard and restaurant?
Yes. A single PT PMA can register multiple KBLI codes covering accommodation, F&B, recreation, tour operation and sea transport, and integrated operations commonly do. The practical constraints are the investment-plan treatment per code per location and the foreign-ownership condition attached to each individual line, both of which must be verified in the current Positive Investment List and OSS entries.
Does every KBLI code require its own IDR 10 billion investment plan?
The commonly applied rule sets the investment plan above IDR 10 billion per five-digit KBLI per project location, excluding land and buildings, with sector-specific exceptions for certain activities grouped in one location. Advisors apply this unevenly and the underlying BKPM regulation has been amended before, so confirm the current treatment for your exact code combination before committing capital.
Which KBLI code covers scuba diving operations?
Diving and marine recreation typically sit in the 93xxx recreation cluster, with 93119 and 93299 the usual candidates depending on how the activity is framed. The classification is fragmented, and the right entry depends on whether you run a facility, guided trips, or instruction. Read the live entry text in OSS with your consultant rather than relying on a code list from a blog, including this one.
Can a foreign-owned PT PMA use homestay or pondok wisata codes?
Generally no. Micro and small-scale accommodation lines are reserved for Indonesian MSMEs and cooperatives under the Positive Investment List framework, which is one reason the Papuan community homestay sector in Raja Ampat remains locally owned. Foreign participation in that segment usually takes indirect forms such as training or marketing support rather than ownership.
Can I add or change KBLI codes after incorporation?
Yes, through a notarial amendment to the deed and an update in OSS, but the new code is assessed under the rules in force at the time of the change, and the process can stall operations that depend on the missing classification. Mapping the full code stack before incorporation is cheaper in every way than retrofitting it.
If you are structuring a dive resort, liveaboard or combined operation and want the code map pressure-tested against your actual revenue model, request a briefing or message us on WhatsApp. We will walk through the candidate KBLI stack with you and, where it helps, introduce vetted independent notaris and OSS setup partners who can take it from analysis to filing. No pressure, no sales script: the goal is that your deed matches your business before the licensing system tests it.