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KBLI Navigator/Section H/52101
KBLI 52101

Warehouse Receipt System Operator

Pengelola Gudang Sistem Resi Gudang

🚚 Section H — Transportation & Storage

In Bali: open to a PT PMA

✅Open· 100% ForeignHigh RiskAggregated🏝️✅Registrable in Bali· medium conf.✓OSS-verified · KBLI 2025

Warehouse Receipts Need a Warehouse System, Not Just Storage

This activity covers the management of warehouse-receipt-system facilities, from safeguarding goods to issuing the receipts that represent them.

By the numbers
Foreign-ownership ceiling
100%
Open business scales
Mikro, Kecil, Menengah, Besar
National PMA basis
Perpres 10/2021, 49/2021
Bali status
Registrable in Bali
The practical Bali reading is not a moratorium barrier, but an activity whose large-scale operation sits in a higher-risk category.
What Changed

Renumbered/merged from KBLI 2020 52108 + fishery post-harvest services codes — activity scope from 52108, code number reused (corrected 2026-07-19 — the previous 'Direct 1:1 match... code and scope unchanged' label was a false narrative). BPS Vol.2 Lampiran 10 (image-verified p.389, render lampiran10_p403-403.png) documents a FIVE-parent merge: KBLI-2020 codes 03143, 03241, 03243, 03263 (fishery post-harvest/production services) and 52108 (same-title SRG warehouse manager) all map to KBLI-2025 52101 — the false same-digit self-reference ['52101'] previously left in pp28_sources is now corrected to this true 5-parent ancestor list (residual fix, 2026-07-19).

What You Need

Nationally, this business field is fully open to 100% foreign ownership. In Bali, the island-wide moratorium (in force since 13 May 2026) only halts PMA registrations for Low and Medium-Low risk lines — this KBLI's large-scale (Besar) risk class is higher, so it is not caught: PMA registration in Bali remains possible.

Who This Is For

Foreign entrepreneurs looking to run sophisticated commodity warehousing with integrated receipt financing systems, though they must look outside Bali for now.

Licensing Overview
Risk LevelTinggi
License TypeNIB + Izin
Foreign Ownership100% Open
Processing3 working days
2020 → 2025
Previous codes (KBLI 2020): 03143, 03241, 03243, 03263, 52108
BPS crosswalk
Official BPS 2020 → 2025 crosswalk ancestors: 03143, 03241, 03243, 03263, 52108

Source: the BPS 2020↔2025 conversion table, mechanically extracted and acceptance-gate verified. It shows which 2020 codes map to this 2025 code — provenance only, not a licensing claim: the regulatory regime of these predecessor codes has not been adjudicated as transferring.

Regulatory Divergence

The licensing previously shown for 52101 was removed because its source could not be verified as applying to this activity. Here is what the sources actually say — with citations.

Correction note — verbatim, with source locators

KBLI 2025 code 52101 'Pengelola Gudang Sistem Resi Gudang' (warehouse-receipt-system / SRG warehouse manager) carries canonical status_mapping='MATCH_LANGSUNG' and intel_2026.whatChanged='Direct 1:1 match from KBLI 2020 — code and scope unchanged.' — both FALSE. This code was enrolled as a Lot 2 innocence CONTROL; the lane flagged it and the conductor image-verified BPS Vol.2 Lampiran 10 p.389 (render lampiran10_p403-403.png, Lot 2 conductor gate report §3.3, 2026-07-18) BY EYE: 52101-2025 is a FIVE-parent MERGE — KBLI-2020 codes 03143, 03241, 03243, 03263 (fishery post-harvest/production services) AND 52108 (same-title SRG warehouse manager) all map to KBLI-2025 52101 — not a direct 1:1 continuation. Its per_skala (8 rows) is HEALTHY OSS-native licensing, verified byte-for-byte against live OSS by the Lot 2 seat, and is NOT detached by this cure ('action':'metadata_only' — per_skala stays completely untouched regardless of its non-empty state). status_mapping corrected to 'MATCH_CON_AGGREGAZIONE' (the merge-aware enum value, already used 195+ times elsewhere in the dataset); intel_2026.whatChanged corrected to name the true parents. pp28_sources REMAINS ['52101'] UNCHANGED — a bare-number cross-vintage collision (the PP28 I.G row for '52101' describes the 2020 meaning, general warehousing/Rendah/NIB, not the 2025 SRG-manager/Tinggi-risk regime): fixing it would require an independent re-hunt of the PP28 corpus under the 5 true 2020 parents to establish a verified replacement source, which has NOT been performed in this session — forcing a pp28_sources change here without that provenance would violate rule #9 (no new values without provenance). This compiler's pp28_sources_correction capability (added in this same PR, first used on 10433 below) is therefore deliberately NOT applied to 52101; recorded here as a known follow-up, not silently left undocumented. Lot 2 conductor gate (second signing), 2026-07-18. BPS Vol.2 sha 29f17b3b. RESIDUAL FIX (2026-07-19, M5 lane, field-vs-note contradiction closure, conductor comment on PR #2777): pp28_sources corrected from the false same-digit self-reference ['52101'] to the true 5-parent list ['03143','03241','03243','03263','52108'] this note already asserted. The rule-9 caution above (an independent PP28-corpus re-hunt) is resolved by conductor ruling: this is a FALSITY correction of the crosswalk pointer using the SAME already-image-verified BPS Lampiran 10 p.403/389 citation already cited above, not a fresh independent PP28-corpus hunt — same class as the #2754/56101 precedent (correct falsity in the pointer list; incompleteness alone would only warrant a note). status_mapping and whatChanged's substance were already correct from #2777; only whatChanged's closing sentence ('pp28_sources remains unchanged') is updated here to match the now-corrected field. aggregation_note (currently null/None) is intentionally left untouched by this residual fix — cure_canonical_collisions.py's metadata_only action does not write that field (same as it did not for 46100/52101 in #2777); flagged here, not silently left undocumented, as a possible follow-up for a future pass.

BPS Peraturan 7/2025 (KBLI 2025 classification)

Sources & Verification

Each data layer below traces to a government source with its KBLI vintage — or is declared as a gap. Nothing in these layers is silently filled in.

Activity definition
BPS Peraturan 7/2025 + PP 28/2025VerifiedKBLI 2025

Title and scope as defined by the KBLI-2025 classification.

locator: OSS_RBA_2025_id_version_fff4053d

Risk & licensing
OSS RBA risk scope (ruang lingkup)VerifiedKBLI 2025

Risk category and licensing rows are KBLI-2025-native from the OSS Risk-Based Approach catalog.

locator: OSS_RBA_resiko_2025

Foreign ownership (PMA)
Perpres 10/2021, 49/2021Audit pendingKBLI 2020

The investment-list annexes predate KBLI 2025; the per-code crosswalk audit of this layer is in progress. The value shown is the annex text, disclosed with its vintage.

Bali status
Bali province blocks ALL Low + Medium-Low risk KBLI for PMA (island-wide, permanent) (effective 2026-05-13)Audit pending2026 overlay

Conservative posture derived from the risk tier · confidence MEDIUM.

Dataset last updated 2026-07-26 · KBLI 2020 and KBLI 2025 reuse code numbers for different activities — cross-vintage rows are labeled, never merged silently.

Common Questions
Can foreigners operate a warehouse receipt system operator business in Indonesia?
Yes. KBLI 52101 (Pengelola Gudang Sistem Resi Gudang) is TERBUKA — open to 100% foreign ownership via PT PMA. No local Indonesian partner required. (Source: Perpres 10/2021 as amended by Perpres 49/2021 — the investment-list annexes predate KBLI 2025; per-code crosswalk audit in progress.)
What license is required for KBLI 52101?
KBLI 52101 has a Tinggi risk classification. Required license: NIB + Izin. Processing time: 3.
What is KBLI 52101?
KBLI 52101 is the Indonesian business classification code for "Pengelola Gudang Sistem Resi Gudang" (Warehouse Receipt System Operator). It falls under Section H of KBLI 2025, the Indonesian Standard Industrial Classification updated by BPS (Regulation 7/2025). The June 2026 KBLI 2025 transition window has closed; operators should verify the code's current OSS/NIB treatment before relying on it for licensing, reporting, or amendments.
How did KBLI 52101 change from KBLI 2020 to 2025?
KBLI 52101 was mapped from previous codes 03143, 03241, 03243, 03263, 52108 (KBLI 2020). Multiple 2020 codes were merged into this single 2025 code. The June 2026 KBLI 2025 transition window has closed. If an NIB still relies on legacy KBLI 2020 mappings, treat the migration as overdue and verify/remediate the OSS record before new license applications, amendments, LKPM, import approvals, or investor/worker sponsorship.

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