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KBLI Navigator/Section K/64320
KBLI 64320

Non-Money Market Investment Fund

Aktivitas Dana Investasi Bukan Pasar Uang

🏦 Section K — Financial & Insurance Activities

In Bali: a PT PMA cannot register this code

National procedure — does not apply to a PT PMA in Bali

In Bali this activity is blocked for a PT PMA under the 13 May 2026 moratorium. The national procedure below applies only to non-PMA operators.

✅Open· 100% nat'l · blocked in BaliRenumbered🏝️🚫Closed in Bali (2026 moratorium)· needs review· low conf.❓Not classifiable — divergence documented

Investment Funds Beyond the Money Market: Open Nationally, Closed in Bali

This activity is nationally open to foreign investment, yet Bali’s permanent PMA moratorium prevents registration at a Bali address.

By the numbers
Foreign-ownership ceiling
100%
Open business scales
Mikro, Kecil, Menengah, Besar
National PMA source
Perpres 10/2021, 49/2021
Bali registration status
Closed (Bali moratorium)
Nationally open does not mean registrable in Bali: the permanent PMA moratorium is decisive at a Bali address.
What Changed

KBLI 2020→2025 mapping: code renumbered.

What You Need

This code covers non-money-market investment funds — collective investment schemes that issue shares or units and invest chiefly in financial assets. The licensing rows shown here earlier cited a regulatory source we could not verify in the official document set, so they have been removed from this page pending re-verification; the correct licensing is not yet reliably confirmed in our verified sources. Before registering or investing, confirm the current requirements with the Bali Zero team. **Risk tier under review.** The licensing rows this code's risk tier was read from have since been set aside as unverifiable for KBLI 2025, so we cannot currently re-derive it. Where this page states a risk tier or a scale-based requirement, treat it as provisional pending re-derivation, and verify the current classification at oss.go.id before acting on it.

Who This Is For

Foreign fund managers or investment firms aiming to launch a publicly offered investment fund in Indonesia that focuses on longer-term assets rather than money market instruments.

2020 → 2025
Previous codes (KBLI 2020): 64300— Agent mapping: 64300 (Trust, Pendanaan dan Entitas K...) [high]

Regulatory Divergence

The licensing previously shown for 64320 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 64320 'Aktivitas Dana Investasi Bukan Pasar Uang' (non-money-market investment funds — collective investment schemes issuing shares/units, investing chiefly in financial assets other than short-term/non-financial assets) carries canonical status_mapping='CODICE_RINUMERATO', kbli_2020_source='64300', pp28_sources=['64300'], mapping_note 'Agent mapping: 64300 (Trust, Pendanaan dan Entitas K...) [high]'. The pinned PP28 corpus records ABSENT for code 64300 across all 21 lampiran files (11,208 pages, text-hunt) — the cited source row is not retrievable from the pinned corpus as hunted. Chain-of-custody note (Lot 3 gate report §3.2, same split pattern as 60201): the D1 seat for this code ALSO independently flagged mapping_metadata_false; the conductor ruled source_absent_in_vault PRIMARY (same ruling as 60201: the PP28 pointer failure is the harm blocking any licensing basis, the metadata finding is concomitant and recorded). CROSS-CHECK (verified this session): 64330 (this same spec, below) cites the IDENTICAL kbli_2020_source/pp28_sources value ('64300') at the same [high] confidence — two distinct 2025 codes both claiming the same single 2020 code as a 1:1 renumbering source, which is itself a red flag consistent with an unverifiable/misattributed pointer rather than two genuine independent 1:1 matches. per_skala detached, preserved under the disputed key for audit; a future image-grade lampiran sweep may restore it WITH provenance. Lot 3 conductor gate (second signing), run wf_c00a9ec4-c61, 2026-07-19.

The detached licensing rows (source unverified for this activity)1 row

These rows were previously shown on this page and have been detached — the correction note above documents, with source locators, why their source could not be kept for the activity this page describes. They are preserved here as the audit trail of the divergence.

Mikro, Kecil, Menengah, BesarLow RiskNIBAuthority: Menteri/ Kepala Badan
BPS Peraturan 7/2025 (KBLI 2025 classification)PP 28/2025 (risk-based licensing annexes)OSS RBA ruang-lingkup — no KBLI-2025 scope retrievable via the OSS API (404)

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
Detached — source could not be verifiedDeclared gap—

The previously-served rows were removed because their source could not be verified as applying to this activity. See Regulatory Divergence above for the documented correction note.

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 LOW.

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 non-money market investment fund business in Indonesia?
Nationally yes — but NOT in Bali. KBLI 64320 (Aktivitas Dana Investasi Bukan Pasar Uang) is TERBUKA (100% foreign ownership) at the national level, but in Bali it is blocked for a PT PMA under the 13 May 2026 moratorium. [derivation under review] Nationally TERBUKA but the Besar scale is 'Rendah' -> blocked by the Bali PMA moratorium (Gov. letter B.27.000/642, 13 May 2026: all Rendah/Menengah Rendah blocked for a Bali address). [NB-3 28 June 2026] — NOTE: the licensing rows this verdict's risk tier was read from have since been set aside as unverifiable for KBLI 2025, so the verdict cannot currently be re-derived; verdict pending re-derivation from the true risk tier (GARUDA-FILIERA). Outside Bali it is open to a PT PMA with no local 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 64320?
We cannot yet show a verified licensing basis for KBLI 64320: the licensing previously associated with this code was removed because its source could not be verified as applying to this activity. See the Regulatory Divergence section on this page for the documented sources, and verify the current OSS treatment before relying on any licensing assumption.
What is KBLI 64320?
KBLI 64320 is the Indonesian business classification code for "Aktivitas Dana Investasi Bukan Pasar Uang" (Non-Money Market Investment Fund). It falls under Section K 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 64320 change from KBLI 2020 to 2025?
KBLI 64320 was mapped from previous code 64300 (KBLI 2020). Agent mapping: 64300 (Trust, Pendanaan dan Entitas K...) [high] The code was renumbered but the business activity scope is essentially unchanged. 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.

Related Codes

64330Section K

Trust, Estate & Agency Services

Aktivitas Trust, Warisan, dan Keagenan

→
🏝️🚫Closed in Bali (2026 moratorium)✅Open· 100% nat'l · blocked in Bali
64310Section K

Money Market Fund

Aktivitas Dana Pasar Uang

→
🏝️❓Bali status not classifiable — verify✅Open· 100% Foreign
64910Section K

Financial Leasing

Aktivitas Sewa Guna Usaha Finansial

→
🏝️✅Registrable in Bali✅Open· 100% ForeignHigh Risk
64220Section K

Conduit Financing

Aktivitas Pembiayaan Conduit

→
🏝️🚫Closed in Bali (2026 moratorium)✅Open· 100% nat'l · blocked in Bali
64920Section K

International Trade Financing

Aktivitas Pembiayaan Perdagangan Internasional

→
🏝️🚫Closed in Bali (2026 moratorium)✅Open· 100% nat'l · blocked in Bali
64210Section K★

Holding Company

Aktivitas Perusahaan Induk

→
🏝️🚫Blocked in Bali (risk-class moratorium)✅Open· 100% nat'l · blocked in BaliLow Risk
🏢

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