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The minimum paid-up capital for a PT PMA in 2026 sits at a figure that is, depending on which advisor you ask, either IDR 2.5 billion or IDR 10 billion — and that discrepancy is not a rounding error; it reflects a genuine inconsistency in how practitioners are interpreting the currently in-force BKPM regulation. Separately, and non-negotiably, the total investment plan for any PT PMA classified as a large enterprise must exceed IDR 10 billion, excluding the value of land and buildings, per KBLI business-classification code per project location. If you are structuring a foreign-owned eco-resort in Raja Ampat under a PT PMA, those two figures — investment plan and paid-up capital — govern the minimum financial commitment from day one, and conflating them is the first mistake most foreign investors make.
PT PMA as a “Large Enterprise”: The IDR 10 Billion Investment-Plan Floor
Indonesia’s investment framework, reshaped by the Omnibus Law and its implementing regulations, draws a hard line between micro, small, medium, and large enterprises. That classification is not cosmetic — it determines which business fields are open to foreign ownership, what licensing pathway applies, and what minimum capital the state expects you to deploy.
Under PP 7/2021 (Government Regulation on MSMEs, issued as part of the Omnibus Law cluster), the threshold between a medium and large enterprise is an investment value above IDR 10 billion in fixed assets excluding land and buildings. A PT PMA is treated, by default, as a large enterprise. The practical consequence: every PT PMA must demonstrate an investment plan — filed through the OSS (Online Single Submission) system at establishment — that exceeds IDR 10 billion per KBLI code per project location.
For a Raja Ampat eco-resort, that investment plan covers the actual capital expenditure: bungalow construction, dive equipment, boats, solar or generator systems, water treatment, furniture, fixtures, and working capital. What it explicitly excludes, per the regulation, is the land and the buildings themselves in the sense of site acquisition costs. On a remote island where material logistics carry a substantial premium over mainland prices, IDR 10 billion (roughly USD 600,000–650,000 at current exchange rates) is not a ceiling — it is often the floor of what a credible 10–15 bungalow operation actually costs before you add the land-use arrangement with the clan, the AMDAL environmental assessment, and the permitting stack.
The Paid-Up Capital Question: IDR 2.5 Billion or IDR 10 Billion?
Paid-up capital (modal disetor) and the investment plan are not the same instrument. Paid-up capital is the amount shareholders must actually inject into the company at or near formation. The investment plan is the total commitment over the project lifecycle declared to the state.
Here is where advisors diverge — and where you need to be careful.
The IDR 10 Billion Position
Many established investment consultants and notaris continue to cite IDR 10 billion as the minimum paid-up capital for a PT PMA. This figure derives from longstanding BKPM guidance that treated paid-up capital as co-extensive with the large-enterprise investment threshold. Under this reading, you commit the full IDR 10 billion as injected capital, not merely as a plan.
The IDR 2.5 Billion Position
A number of advisors — including at least one prominent incorporation-services provider — began citing IDR 2.5 billion as the new minimum paid-up capital effective from around October 2025, attributing this to a revised BKPM regulation (sometimes referenced as BKPM Regulation No. 5/2025 or a similarly numbered ministerial rule). Under this interpretation, paid-up capital is set at 25 percent of the IDR 10 billion investment-plan threshold, with the remainder covered by the declared investment commitment rather than upfront injection.
Why the Inconsistency Persists
Indonesia’s investment-regulation landscape moves faster than advisory practices can fully absorb. BKPM — now operating under the name Kementerian Investasi / BKPM (Ministry of Investment) — has issued a series of implementing regulations since the Omnibus Law took effect, amending and superseding earlier rules. Not all advisors track amendments in real time. Some are citing the pre-amendment standard. Others are working from the latest circular they received. A few may be extrapolating from OSS system behavior rather than from the published regulation text itself.
The key regulations to verify — in their most recent amended form — are:
- PP 5/2021
- Government Regulation on Risk-Based Business Licensing (the OSS framework). Governs NIB issuance and the risk classification that determines which licenses apply.
- PP 7/2021
- Government Regulation on MSMEs. Establishes the IDR 10 billion large-enterprise threshold (excl. land & buildings) that PT PMA investment plans must clear.
- Ministerial Regulation / BKPM Regulation (latest in-force version)
- Governs minimum paid-up capital for PT PMA. This is the specific regulation whose current version — whether it is No. 4/2021 as amended, or a newer 2025 rule — determines whether IDR 2.5 billion or IDR 10 billion applies. Confirm the current in-force text with a licensed Indonesian notaris or BKPM-registered consultant before you rely on either figure.
- Perpres 10/2021 and Perpres 49/2021
- Presidential Regulations on the Positive Investment List. Confirm whether your specific KBLI code is open to 100% foreign ownership, subject to conditions, or reserved for MSMEs/cooperatives.
The reason we flag this inconsistency explicitly — rather than simply printing one number — is that the difference between IDR 2.5 billion and IDR 10 billion as injected capital matters materially to your liquidity planning. If you structure your entity on the IDR 2.5 billion assumption and the notaris processing your deed insists on IDR 10 billion per the regulation they are working from, you face a capital shortfall at incorporation. Conversely, injecting IDR 10 billion when the current regulation only requires IDR 2.5 billion ties up capital unnecessarily in the early project phase.
How the Numbers Work Together in Practice
Let’s be concrete about the layered structure, because this is where investor confusion most often compounds:
| Requirement | Amount | What It Covers | Status |
|---|---|---|---|
| Investment plan (rencana investasi) | > IDR 10 billion | All capex excl. land & buildings, per KBLI per location | Non-negotiable under PP 7/2021 |
| Paid-up capital (modal disetor) — conservative | IDR 10 billion | Injected at or near formation per older BKPM guidance | Advisors still citing this — verify |
| Paid-up capital — revised position | IDR 2.5 billion (~USD 150,000) | 25% of IDR 10bn threshold per cited 2025 BKPM regulation | Requires primary-document confirmation |
| Authorized capital (modal dasar) | Typically 4× paid-up | Stated in the company deed; can be drawn on as the project scales | Standard notarial practice |
The investment plan is a declaration, not necessarily an immediate cash transfer. You demonstrate to the state — through your OSS filing and subsequent LKPM (investment-activity reports filed quarterly) — that you are deploying capital into the project over the agreed timeline. Miss those milestones, and you risk a compliance flag from BKPM. The paid-up capital, by contrast, is the actual subscribed and injected equity at incorporation — it sits in the company’s account and needs to be verifiable.
KBLI Code Choice: It Is Not a Formality
A detail that Bali-generic PT PMA guides almost universally gloss over: the KBLI code you select at OSS registration quietly shapes which downstream licenses you can obtain, which foreign-ownership percentage is permissible for your activity, and how BKPM assesses your investment plan compliance.
For a Raja Ampat eco-resort with a dive center, a restaurant, and small-boat excursions, you are almost certainly dealing with multiple KBLI codes. Possible relevant categories include starred accommodation (55111) or non-star/villa-type lodging (55112, or variants near 55199 for pondok wisata), food and beverage operations (56101 for restaurants), diving and marine recreation (codes in the 93xxx range — commonly cited as 93119 or 93299 for recreation and sports services), and possibly tour-operator or marine-transport codes for your excursion boats (79122, or 50119 range for sea passenger/charter transport).
Each KBLI code technically carries its own investment-plan requirement. A large-scale integrated resort will file a combined plan, but the licensing body may scrutinize whether each activity line meets the large-enterprise threshold independently. Choosing the wrong KBLI — say, a micro-scale accommodation code that is formally reserved for Indonesian MSMEs — can block you from obtaining the lodging license you need, or expose the entity to challenge as a nominally-foreign structure operating in a protected sector.
The correct current KBLI mapping for a marine-tourism operation in West Papua should be confirmed against the official 2020 KBLI classification list and the OSS system at the time of filing. The codes evolve with periodic BPS (Statistics Indonesia) updates, and OSS sometimes groups or reclassifies activities differently from the raw KBLI list.
If you are ready to structure your entity and want to discuss which approach fits your project, plan your investment pathway with our team — or reach us on WhatsApp for a faster initial conversation about your specific setup.
What the Positive Investment List Says About Foreign Ownership
The short answer for large-scale tourism: most hotel, resort, large-restaurant, and tour-operator activities are open to 100% foreign ownership through a qualifying PT PMA under Perpres 10/2021 as amended by Perpres 49/2021 (the Positive Investment List).
The important carve-out: micro and small-scale accommodation — which includes pondok wisata, family guesthouses, and small homestays — is reserved for Indonesian MSMEs and cooperatives. A foreigner cannot legally structure a PT PMA to own what is functionally a small homestay, even if the physical property looks the same as the lower end of a resort. The distinction is scale-based, tied back to the IDR 10 billion threshold. If your operation falls below that level, foreign ownership is not available via the PT PMA route.
For Raja Ampat specifically, this distinction matters practically: the community homestay model that supports over a hundred indigenous Papuan-owned operations around Waigeo, Kri, Arborek, and Misool is structurally inaccessible to foreign PT PMA ownership — both by national MSME rules and by the strong local-policy intent that keeps homestay revenue within indigenous communities. A foreign investor looking at the homestay sector is looking at indirect participation models — training support, marketing partnerships, infrastructure grants — rather than equity ownership.
Tax Implications From Day One
Capital structure feeds directly into your tax position. A few numbers worth having in your model from the start:
- Corporate income tax: 22% standard rate under Law 7/2021 (HPP). Reduced to 11% for companies whose gross revenue is below IDR 4.8 billion. A new eco-resort in early operations will likely fall below that ceiling for the first year or two — but confirm the threshold annually with a licensed tax consultant (konsultan pajak).
- Final income tax (PPh Final): 0.5% of gross revenue for the first three fiscal years for certain MSME-qualifying entities. Whether a PT PMA qualifies for this concession depends on revenue scale and KBLI — not a given.
- VAT: 11% statutory rate. Tourism services generally attract VAT; some exemptions apply. Verify for your specific KBLI.
- Dividend withholding tax: 20% for distributions to foreign shareholders under domestic law, reducible under applicable bilateral tax treaties. Indonesia has treaties with many European, ASEAN, and other jurisdictions — your holding company’s residence country matters.
- Local hotel and restaurant tax: Typically around 10%, collected by the regency (Kabupaten Raja Ampat). Confirm the current Raja Ampat Perda (regional regulation) rate.
- LKPM reporting: Quarterly investment-activity reports to BKPM via OSS. Non-compliance triggers warnings and can affect your business license standing.
The Nominee Trap: Why It Keeps Resurfacing
A frank note, because this comes up in every conversation about Indonesian investment structuring for foreigners who are worried about the capital and complexity of a proper PT PMA setup.
The nominee structure — where an Indonesian individual holds shares, land title, or both on behalf of a foreign investor under a private side-agreement — is explicitly illegal under Article 10(1) of Law 25/2007 on Investment. The consequences are not theoretical: dissolution of the company, forfeiture of assets, and criminal exposure for both the nominee and the foreign investor. Indonesian courts do not enforce nominee agreements. A side-letter witnessed by a notaris does not make a nominee arrangement lawful.
This matters in Raja Ampat because the capital required for a proper PT PMA can feel daunting compared to an informal arrangement with a local partner. The IDR 10 billion investment plan — and whatever the verified paid-up capital figure turns out to be — is real money. But the downside of a dissolved company and forfeited assets in a remote location with thin legal infrastructure is far larger. The correct path is a properly capitalized PT PMA with vetted Indonesian counsel, not a shortcut that appears to work until it doesn’t.
Putting It Together: What to Do Before You Commit Capital
The sequence that reduces risk is not complicated, but it is easy to compress in ways that create problems later.
First, identify your primary KBLI code and confirm it against the current OSS system — not a blog post, including this one. Second, check the Positive Investment List annex for that specific code to confirm the foreign-ownership percentage and any conditions. Third, engage a licensed Indonesian notaris and a BKPM-registered investment consultant to confirm the current in-force paid-up capital figure — specifically ask them to cite the regulation number and date, and to show you that the amendment you are relying on has been officially published in the State Gazette (Berita Negara). Fourth, model your investment plan against the IDR 10 billion floor before you sign anything with a land lessor or a construction contractor.
In Raja Ampat, add a fifth step that mainland projects often skip: confirm your project location’s zoning status in the current Raja Ampat spatial plan (RTRW) and the coastal-marine spatial plan (RZWP3K). A location that is in a marine-park core zone or a conservation-priority zone under the UNESCO Global Geopark framework may not be legally available for resort development regardless of how cleanly your PT PMA is structured. The capital requirements of a PT PMA are knowable and manageable. The zoning and customary-land dimensions are where Raja Ampat projects most often run into trouble that no amount of paid-up capital can fix retroactively.
When you are ready to take those steps in sequence, reach out to our team — we can connect you with the vetted legal and OSS specialists who work specifically in West Papua, and we are available on WhatsApp for an initial scoping conversation at your convenience.
Frequently Asked Questions
What is the minimum investment plan for a PT PMA operating an eco-resort in Raja Ampat?
The investment plan must exceed IDR 10 billion, excluding the value of land and buildings, per KBLI business code per project location. This derives from PP 7/2021, which defines a large enterprise — the category all PT PMA entities fall into — by that threshold. The investment plan is declared through the OSS system at incorporation and tracked via quarterly LKPM reports to BKPM.
Has the minimum paid-up capital for a PT PMA been reduced from IDR 10 billion to IDR 2.5 billion?
Some advisors and incorporation-services providers began citing IDR 2.5 billion (25% of the IDR 10 billion threshold) as the minimum paid-up capital effective from around October 2025, referencing a BKPM regulation. Other practitioners still cite IDR 10 billion based on earlier guidance. This is a genuine inconsistency in the market, not a settled question. You must ask your notaris or BKPM-registered consultant to identify the specific regulation number and its gazette publication date, and to confirm that the version they are working from is currently in force before you rely on either figure for your entity setup.
Can a 100% foreign-owned PT PMA legally own and operate an eco-resort in Raja Ampat?
Large-scale accommodation and tourism operations — hotels, resorts, tour operators — are generally open to 100% foreign ownership under Indonesia’s Positive Investment List (Perpres 10/2021 as amended by Perpres 49/2021), provided the project qualifies as a large enterprise. Micro and small-scale accommodation, including pondok wisata and small homestays, is reserved for Indonesian MSMEs and is not available to a foreign PT PMA. The specific KBLI code you register under must be confirmed against the current Perpres annex, and any additional conditions attached to that code must be satisfied.
Does the IDR 10 billion investment plan include the cost of leasing land from an adat clan in Raja Ampat?
No. The IDR 10 billion large-enterprise threshold under PP 7/2021 excludes land and buildings. Land-use arrangements — including lease payments to an indigenous Papuan clan under a customary-land agreement — fall outside the investment-plan floor calculation. This means your actual total financial commitment will typically be higher than IDR 10 billion once land lease costs, AMDAL environmental assessment fees, and building costs are added. The investment plan captures the operational and capital-expenditure components that the state uses to classify your enterprise tier.
What happens if I use a nominee shareholder instead of a proper PT PMA structure to hold my Raja Ampat resort investment?
A nominee arrangement — where an Indonesian individual holds shares or land title on your behalf under a private side-agreement — is explicitly illegal under Article 10(1) of Law No. 25/2007 on Investment. Penalties include company dissolution, asset forfeiture, and criminal liability for both the foreign investor and the Indonesian nominee. Indonesian courts will not enforce side-letter agreements designed to circumvent the PT PMA requirements. The correct structure is a properly capitalized PT PMA, established with licensed Indonesian counsel, regardless of the apparent convenience or cost savings of a nominee approach.