KBLI is used as a basis for identifying business sectors, determining risk levels, and establishing the types of licenses and sector-specific requirements that business actors must fulfill. Therefore, the main issue in implementing KBLI 2025 is not merely replacing a KBLI number or code, but ensuring that the recorded code and scope of activities accurately reflect the company’s actual business activities. If there is a mismatch between actual activities and the corporate and OSS data, several legal and compliance risks may arise.

1. Corporate Legality Risk

The purposes, objectives, and business activities set out in the articles of association form the basis for the board of directors in managing the company. If the company’s actual activities fall outside the stated scope of business, certain corporate actions may be questioned on the grounds that they are not aligned with the company’s purposes and objectives. Such discrepancies may also become findings when the company participates in tenders, undergoes compliance reviews, enters into business transactions, or is subject to legal due diligence by investors or other third parties.

2. Business Licensing Risk

The Risk-Based Business Licensing system issues licenses based on the business activities or KBLI classifications selected in OSS. Accordingly, if the activities actually carried out do not correspond to the recorded KBLI, the company may encounter difficulties when applying for a Standard Certificate, sectoral licenses, data updates, or other supporting permits. Such discrepancies may also be identified when technical agencies verify the company’s business activities.

3. Tax and Supervision Risk

KBLI may also be used as one of the references for profiling, supervision, and data exchange among government agencies. If the recorded business activity profile differs from the transactions, reports, or activities actually carried out, the company may be requested to provide further clarification. In a tax context, such differences do not automatically indicate a violation, but they may increase scrutiny during supervision, risk analysis, or compliance audits.

4. Investment and Financing Risk

In investment, financing, mergers and acquisitions, and strategic partnerships, investors, banks, and prospective partners generally review the consistency of a company’s business activities with its articles of association and OSS data. Any KBLI discrepancy may become a due diligence finding requiring correction, potentially delaying the transaction until the relevant legality and licensing issues are resolved.

5. Corporate Administration Risk

Companies must also ensure that their corporate data in AHU remains up to date and consistent with their business activities and licenses. The provisions concerning corporations that are administratively classified as inactive do not mean that a company automatically becomes inactive simply because it has not yet changed its KBLI classification. However, changes to data that are legally required must still be reported and updated to avoid administrative issues, data inconsistencies, or obstacles when the company requires corporate services in the future.

When Is an Adjustment Necessary?

If the change from the previous KBLI to KBLI 2025 is merely a code conversion without any change to the type, nature, or scope of the business activities, the company does not, in principle, need to amend its articles of association solely because the KBLI number has changed. Conversely, if the company changes its purposes and objectives, carries out activities that were not previously stated, or adds new business activities, it is necessary to assess whether amendments to the articles of association, updates to AHU and OSS data, and compliance with the relevant licenses or sector-specific requirements are required.

Recommended Steps for Companies

As a practical step, a company can compare the business activities it actually carries out against its articles of association and the KBLI classifications recorded in OSS. It should then determine whether the KBLI 2025 change is merely a code conversion or whether it substantively changes the scope of the business activities. If there is a substantive discrepancy, the necessary corporate data and licensing updates should be made. For business sectors subject to specific sectoral licensing, the company should also confirm whether the KBLI change affects its Standard Certificate, technical licenses, or other obligations imposed by the relevant ministry or government agency.

Conclusion

Companies should not view KBLI 2025 merely as an administrative change involving the replacement of codes. More importantly, they must ensure consistency among their actual business activities, articles of association, AHU data, NIB, OSS records, and sectoral licenses. Unresolved discrepancies may affect corporate legality, the smooth processing of licenses, compliance and tax supervision, as well as investment and financing processes. Therefore, an internal review of the company’s KBLI classifications and legal documents is an appropriate step before deciding whether a formal amendment is actually required.