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KBLI Navigator/Section K/64330
KBLI 64330

Trust, Estate & Agency Services

Aktivitas Trust, Warisan, dan Keagenan

🏦 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

Trusts, Estates and Agency: Nationally Open, Closed to Bali PMA

This activity can be wholly foreign-owned nationally, yet a foreign investor cannot register it at a Bali address under the province-wide PMA moratorium.

By the numbers
Maximum foreign ownership
100%
Open scales
Mikro, Kecil, Menengah, Besar
PMA source
Perpres 10/2021, 49/2021
Bali status
Closed (Bali moratorium)
National openness and full foreign ownership do not override Bali’s island-wide PMA restriction.
What Changed

KBLI 2020→2025 mapping: code renumbered.

What You Need

This code covers trusts, estates, and agency activities — legal entities holding securities, estates, or other financial assets on behalf of shareholders or beneficiaries, without managing them. 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 entrepreneurs seeking a passive holding structure for inheritable wealth or securities, but note that Bali's moratorium prevents PMA registration.

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

Regulatory Divergence

The licensing previously shown for 64330 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 64330 'Aktivitas Trust, Warisan, dan Keagenan' (trusts, estates, and agency activities — legal entities holding securities/estates/other financial assets on behalf of shareholders or beneficiaries, without managing them) 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 SAME cited 2020 source as 64320 above (verified this session: both codes' kbli_2020_source and pp28_sources are the identical single value '64300' at the same [high] confidence tag). 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. Seat-disagreement note (Lot 3 gate report §3.3): this code is part of the D1-CLEAN-vs-D5-PROBLEM divergence group (60103, 60311, 64110, 64330) — the seats' verdicts genuinely disagree; quarantined by the plan §3 preregistered divergence rule with D5's blind image-grounded category (source_absent_in_vault). 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 trust, estate & agency services business in Indonesia?
Nationally yes — but NOT in Bali. KBLI 64330 (Aktivitas Trust, Warisan, dan Keagenan) 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 64330?
We cannot yet show a verified licensing basis for KBLI 64330: 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 64330?
KBLI 64330 is the Indonesian business classification code for "Aktivitas Trust, Warisan, dan Keagenan" (Trust, Estate & Agency Services). 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 64330 change from KBLI 2020 to 2025?
KBLI 64330 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

64320Section K

Non-Money Market Investment Fund

Aktivitas Dana Investasi Bukan Pasar Uang

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

Money Market Fund

Aktivitas Dana Pasar Uang

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🏝️❓Bali status not classifiable — verify✅Open· 100% Foreign
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Financial Leasing

Aktivitas Sewa Guna Usaha Finansial

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🏝️✅Registrable in Bali✅Open· 100% ForeignHigh Risk
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International Trade Financing

Aktivitas Pembiayaan Perdagangan Internasional

→
🏝️🚫Closed in Bali (2026 moratorium)✅Open· 100% nat'l · blocked in Bali
64930Section K

Factoring Services

Aktivitas Anjak Piutang

→
🏝️✅Registrable in Bali✅Open· 100% ForeignHigh Risk
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Conduit Financing

Aktivitas Pembiayaan Conduit

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