Representative Office in Indonesia: Types, Permitted Activities, and Requirements

A representative office in Indonesia allows a foreign company to establish a local presence without incorporating a separate Indonesian limited liability company. The activities it can perform depend on its registration category. A general representative office can handle market research and liaison work, while specialized offices operate under separate rules for trading, e-commerce, construction, and electricity-support services.

Article 24(3) of Minister of Investment and Downstreaming/Head of BKPM Regulation No. 5 of 2025 identifies five categories of foreign-company representative offices within Indonesia’s OSS licensing framework: KPPA, KP3A, KP3A Bidang PMSE, BUJKA representative offices, and foreign electricity-support-services representative offices.

If your company is considering an Indonesian representative office, start with the work your local team will perform. That decision determines the appropriate registration category, permitted activities, documents, and ongoing compliance obligations.

What Is a Representative Office in Indonesia?

A representative office acts on behalf of an existing foreign company. The overseas company remains the parent organization, while the Indonesian office performs activities within the authority granted by its registration and any applicable sector-specific permits.

Consider a Singapore-based manufacturer assessing Indonesia as its next export market. The company wants someone in Jakarta to meet potential distributors, research purchasing behavior, and report back to headquarters. It is not ready to maintain local inventory or operate an Indonesian sales company.

A general foreign representative office, known as KPPA, may suit that initial scope.

The answer changes if the company wants its Jakarta team to run local commercial transactions or deliver paid services. In that situation, management should examine an appropriately licensed Indonesian operating structure or the relevant specialist representative-office category.

Indonesia’s representative-office licensing framework sits within Government Regulation No. 28 of 2025 on Risk-Based Business Licensing and its implementing regulations.

Government Regulation No. 28 of 2025 took effect on June 5, 2025, replacing Government Regulation No. 5 of 2021. Minister of Investment and Downstreaming/Head of BKPM Regulation No. 5 of 2025 took effect separately on October 2, 2025, and sets out the relevant OSS procedures discussed in this article.

Five Types of Representative Offices in Indonesia

Indonesia does not issue one representative-office license covering every foreign company’s activities. Article 24(3) of BKPM Regulation No. 5 of 2025 identifies five categories within its foreign-company representative-office licensing framework.

1. General Foreign Representative Office (KPPA)

KPPA stands for Kantor Perwakilan Perusahaan Asing. It is the general representative-office category for a foreign company seeking a local presence within defined non-commercial functions.

Under Article 270 of BKPM Regulation No. 5 of 2025, a KPPA can supervise, coordinate, maintain liaison, and manage the interests of its foreign parent company or affiliated companies. It can also prepare for the establishment and development of a foreign investment company in Indonesia.

For a foreign technology company, the work might involve interviewing potential clients, assessing local procurement practices, and identifying possible business partners.

The overseas management team can use that research to decide whether Indonesia warrants a local operating company.

Article 270(3) places several restrictions on a general KPPA:

• It cannot earn income from Indonesian sources.
• It cannot undertake the commercial sale-and-purchase transactions specified in the regulation between its foreign parent and Indonesian companies or individuals.
• It cannot participate in the management of an Indonesian company, subsidiary, or branch.
• Its office must be located in an office building in a provincial capital.

These are KPPA-specific restrictions. They should not be applied indiscriminately to specialized representative offices that operate under different sector rules.

2. Foreign Trading Company Representative Office (KP3A)

KP3A stands for Kantor Perwakilan Perusahaan Perdagangan Asing. This category is intended for foreign trading companies that require representation in Indonesia.

The office may perform trade promotion, market research, and permitted representative or agency functions within the scope of its authorization.

A foreign industrial-equipment manufacturer assessing Indonesian suppliers, for example, should examine whether its planned activities fall under KP3A rather than general KPPA representation.

Articles 271 and 272 of BKPM Regulation No. 5 of 2025 require a KP3A to obtain an NIB and a Surat Izin Usaha Perwakilan Perusahaan Perdagangan Asing, known as SIUP3A, through OSS.

The authority of a KP3A must also be checked against trade-specific rules, including Minister of Trade Regulation No. 10/M-DAG/PER/3/2006, as amended.

Certain representative or agency functions and export-related contracts on behalf of the appointing foreign company may be treated differently from prohibited domestic trading and sales transactions.

Permission to facilitate exports does not authorize a KP3A to sell goods or services domestically in its own name without the appropriate legal basis and licensing.

A foreign trading company should review the proposed contracts and actual activities before determining which permissions it needs.

3. Foreign E-Commerce Representative Office (KP3A Bidang PMSE)

A KP3A Bidang PMSE is the Indonesian representative of a qualifying foreign electronic-commerce operator, known as a PPMSE. It has a narrower representative function than a general-purpose trading or operating company.

Under Article 45 of Minister of Trade Regulation No. 19 of 2026, it may act for and on behalf of its appointing foreign PPMSE in matters concerning:

• Consumer protection.
• Initiatives to improve the competitiveness of domestic products.
• Dispute resolution.

Article 45(2) prohibits a KP3A Bidang PMSE from undertaking actions outside those specified functions.

This restriction matters when a foreign marketplace appoints an Indonesian representative. The representative’s authorization should match the duties established by the trade regulation, rather than giving the office an unrestricted mandate to operate the marketplace’s entire business.

When Is a Foreign E-Commerce Operator Required to Appoint a Representative?

Article 275 of BKPM Regulation No. 5 of 2025 and Article 22 of Minister of Trade Regulation No. 19 of 2026 establish the relevant criteria.

The thresholds are alternative, not cumulative. Within a one-year period, a foreign PPMSE may meet the representative-appointment criteria by satisfying at least one of the following:

• Conducting transactions with at least 1,000 consumers.
• Delivering at least 1,000 packages to consumers in Indonesia.
• Recording traffic or accessors equivalent to at least 1% of Indonesia’s domestic internet users.

The competent authorities’ assessment and the operator’s other PMSE obligations must also be considered.

The Foreign Operator and Its Indonesian Representative Hold Different Licenses

Under Articles 274 and 275 of BKPM Regulation No. 5 of 2025, the foreign PPMSE’s NIB and applicable SIUPMSE business licensing are distinct from the SIUP3A Bidang PMSE required by its Indonesian representative.

Article 274 also addresses operators that are exempt from particular business-licensing requirements. A foreign platform should confirm which provisions apply to its activities before assuming that every operator needs the same collection of permits.

One Representative, One Foreign PPMSE

Article 42 of Minister of Trade Regulation No. 19 of 2026 prohibits a KP3A Bidang PMSE from representing more than one foreign PPMSE.

With the appointing foreign PPMSE’s approval, the representative may open branch offices.

A KP3A Bidang PMSE may be located in a provincial capital and/or a regency or city across Indonesia. This location rule differs from the provincial-capital requirement applicable to a general KPPA.

Minister of Trade Regulation No. 19 of 2026 took effect on June 8, 2026, replacing Minister of Trade Regulation No. 31 of 2023.

4. Foreign Construction Services Representative Office (BUJKA)

BUJKA refers to Badan Usaha Jasa Konstruksi Asing, or a foreign construction-services business entity.

Qualifying foreign construction companies may establish a BUJKA representative office under Indonesia’s construction-services framework.

Article 276 of BKPM Regulation No. 5 of 2025 requires the representative office to meet the criteria for a large-qualified construction-services business.

The office must obtain an NIB through OSS. After receiving the NIB, it must establish the prescribed Kerja Sama Operasi (KSO), or operational cooperation arrangement, with an Indonesian construction-services business.

The cooperation must meet the regulatory principles concerning equivalent construction services and qualifications.

Article 276 treats the NIB as the BUJKA representative office’s licensing instrument for construction-services activities throughout Indonesia. It does not remove the separate requirement to establish the prescribed KSO.

The BUJKA representative-office NIB is valid for three years and may be extended.

A foreign contractor preparing to participate in an Indonesian infrastructure project should assess its construction qualifications and local cooperation arrangement before committing to the project.

5. Foreign Electricity-Support-Services Representative Office

Indonesia recognizes another specialized category for foreign companies providing electricity-support services.

Article 24(3) and Article 277 of BKPM Regulation No. 5 of 2025 refer to this category as Kantor Perwakilan Jasa Penunjang Tenaga Listrik Asing.

Article 277 requires the foreign company to meet the criteria for a large-qualified electricity-support-services business and obtain an NIB.

Article 277(4) also expressly requires the representative office to obtain the applicable business license, or PB, after receiving its NIB and before undertaking commercial or operational activities.

An NIB alone does not authorize the office to start those activities.

For example, a foreign electricity engineering company planning to provide paid services in Indonesia needs to identify the applicable electricity-support activity and confirm the sector licensing requirements before accepting the work.

What Activities Can a General KPPA Perform?

A general KPPA can perform the liaison, coordination, supervisory, and preparatory activities allowed under Article 270. The practical assessment starts with the employee’s actual responsibilities, rather than their job title.

A company may appoint someone as a business development representative, for example. If that person only researches demand and introduces potential customers to the foreign parent, the proposed work differs from a role that negotiates and concludes commercial sales.

One area that needs particular attention is overseas invoicing.

A foreign parent may invoice customers outside Indonesia while employees based in Jakarta perform work connected to those contracts. The offshore billing arrangement does not establish that the Indonesian employees’ activities fall within the KPPA’s permitted scope.

Management should examine who negotiates the contracts, who performs the services, and how the Indonesian team participates in revenue-generating activities.

These questions also matter for the foreign company’s Indonesian tax position.

Requirements for Setting Up a Representative Office in Indonesia

The documents depend on the office category. For a general KPPA, Article 270(2) of BKPM Regulation No. 5 of 2025 identifies the principal information and documents that applicants must submit through OSS.

KPPA OSS Documents and Information

For a general KPPA, Article 270(2) identifies at least the following OSS filing information and documents:

• Approval or validation of the foreign company’s constitutional documents under its home-country law.
• The deed of establishment or equivalent incorporation document.
• A duly signed and legalized letter appointing the head of the KPPA.
• A legally valid, current office lease between the KPPA and the owner or manager of the office building.
• A certificate or reference issued by the relevant Indonesian representative office in the foreign company’s country of origin.
• Information describing the proposed Indonesian activities.
• A self-declaration concerning security, safety, health, and environmental protection (K3L).

The appointment letter must satisfy the applicable legalization procedure.

For countries participating in the Apostille Convention, the regulation recognizes legalization through the competent authority under that convention. For other countries, the relevant Indonesian diplomatic or consular route applies.

Check the current OSS forms for additional required fields and document formats before filing.

Representative Office Head and Employment Requirements

The foreign company must appoint a person responsible for the KPPA’s operation in Indonesia.

Article 270(4) requires the head of a general KPPA to reside in Indonesia and take responsibility for the office’s operation.

The regulation also prohibits the appointed representative from undertaking activities outside the KPPA’s permitted scope or simultaneously serving as a company director or heading another KPPA.

Where the appointed KPPA head is a foreign national and/or the office employs foreign workers, Article 270(5) requires the KPPA to employ Indonesian workers in accordance with the applicable laws.

Immigration permissions and foreign-worker authorization must still be assessed separately for the relevant individuals.

A representative-office NIB does not replace an individual’s visa, stay permit, or employment authorization.

Under Article 270(6), a general KPPA’s NIB remains valid while the KPPA continues its activities. This differs from the three-year, extendable NIB period expressly stated for a BUJKA representative office.

Registered Office and Lease Requirements

A general KPPA must maintain an office in an office building located in a provincial capital.

Article 270(2) also requires a legally valid and current lease agreement between the KPPA and the office building’s owner or manager.

These requirements deserve attention when a foreign company is considering a virtual-office package.

A business address marketed as a virtual office does not establish that the proposed arrangement satisfies the KPPA’s lease, premises, and location requirements.

For a general KPPA, ask the address provider to confirm in writing whether the proposed package includes a legally valid lease between the KPPA and the office building’s owner or manager, and whether the premises are an office building in a provincial capital.

A virtual-office marketing label or business-address service alone is not proof that the Article 270 requirements are met.

Neither should a foreign company assume that every virtual-office arrangement is prohibited. The relevant assessment concerns the actual premises, contractual documents, and applicable regulatory requirements.

Additional Documents for KP3A and KP3A Bidang PMSE

A foreign trading company representative office has its own documentation requirements under Article 272.

The supporting material includes the relevant foreign-company documents, a legalized appointment letter, a statement concerning prohibited trading and sales activities, a certificate or reference from the relevant Indonesian trade attaché or representative office abroad, the appointed representative’s identity documentation, workforce details, business information, and the K3L self-declaration.

Applicants should follow the current OSS checklist and trade-ministry verification process.

A KP3A Bidang PMSE requires additional information specific to the foreign electronic-commerce operator it represents.

Article 275(4) of BKPM Regulation No. 5 of 2025 and Article 43 of Minister of Trade Regulation No. 19 of 2026 establish the relevant requirements, including:

• Corporate documentation of the appointing foreign PPMSE.
• A duly legalized appointment letter.
• Relevant electronic-system registration documentation.
• The foreign PPMSE’s website address and/or application name.
• Consumer-complaint contact information.
• Identification and workforce information for the representative office.
• The applicable K3L self-declaration.

Minister of Trade Regulation No. 19 of 2026 requires the specified constitutional documents and appointment letter to be translated into Indonesian by a sworn translator.

The appointment letter must address the representative’s authority concerning consumer protection, domestic-product competitiveness, and dispute resolution.

These document and translation requirements are specific to the KP3A Bidang PMSE application. They should not be copied into every representative-office checklist without checking the relevant regulation.

Specialist Requirements for Construction and Electricity Services

A BUJKA representative-office application must address the foreign company’s construction qualifications and the required government non-tax revenue payment, or PNBP.

After receiving its NIB, the BUJKA representative office must establish the prescribed KSO arrangement with an Indonesian construction-services business.

A foreign electricity-support-services representative office must satisfy the qualification requirements under Article 277 and obtain the applicable sector business license before commencing commercial or operational activities.

For both categories, confirm the proposed service activity and sector requirements before preparing the final application.

How to Register a Representative Office Through OSS

Foreign representative-office licensing is processed through Indonesia’s Online Single Submission system. The procedure differs by category, but a general KPPA applicant can prepare the filing in the following sequence.

Step 1: Define the Indonesian Office’s Activities

Write a practical description of the work your Indonesian representative will perform.

For a general KPPA, that might include market research, meetings with potential partners, reporting to the parent company, and coordination of preparatory investment activities.

If the planned work includes trading, e-commerce representation, construction, or electricity-support services, review the relevant specialized requirements first.

Step 2: Prepare the Parent Company’s Documents

Collect the foreign company’s incorporation records and any required corporate approval or validation documents.

Prepare the appointment letter and complete the applicable legalization process.

Obtain the required supporting letter or certificate from the relevant Indonesian representative office in the foreign company’s country of origin.

Step 3: Appoint the Representative and Secure the Office

Confirm the representative’s eligibility and responsibilities.

Secure a lease that satisfies the general KPPA’s office-building and provincial-capital requirements.

If the representative will be a foreign national, assess the person’s immigration and employment authorization before work begins.

Step 4: Submit the Application Through OSS

Complete the appropriate OSS registration and submit the supporting documents.

For a general KPPA, Article 270 provides for automatic NIB issuance through OSS after the applicant completes the required information and document submission.

A KP3A needs both its NIB and SIUP3A. Specialized offices follow their applicable licensing procedures.

The government’s official OSS guide for KPPA registration provides a reference for the general representative-office application.

Step 5: Complete Post-Registration Administration

After receiving the applicable registration, arrange the office’s tax administration, employment records, and other operational requirements.

Depending on the company’s circumstances, these may include NPWP registration, payroll administration, immigration documentation, and accounting arrangements.

Keep copies of the appointment letter, lease, NIB, and other relevant records accessible to the parent company and its Indonesian representative.

Ongoing Compliance for Representative Offices

Registration is the starting point of the foreign company’s Indonesian compliance obligations. Management should assign responsibility for reporting, tax administration, and personnel matters before the office begins its activities.

LKPM Reporting Frequency and Deadlines

LKPM stands for Laporan Kegiatan Penanaman Modal, or Investment Activity Report.

Articles 294 through 296 of BKPM Regulation No. 5 of 2025 establish the reporting requirements for foreign-company representative offices.

For KPPA, KP3A, and KP3A Bidang PMSE, Article 295(2), read together with Article 286(3)(a), establishes the six-month reporting periods.

The first-semester LKPM is generally due by July 15 of the same year. The second-semester report is due by January 15 of the following year.

Article 296 sets an annual January 15 deadline for BUJKA and foreign electricity-support-services representative offices.

Check official OSS notices for adjustments to a submission window when it coincides with a national holiday.

Tax Registration and Permanent Establishment Exposure

A representative office’s licensing restrictions and its tax position are separate questions.

A KPPA’s prohibition on earning Indonesian-source income does not, by itself, determine whether the foreign enterprise has a permanent establishment, known as Bentuk Usaha Tetap or BUT, or other Indonesian tax obligations.

Minister of Finance Regulation No. 35/PMK.03/2019 addresses the determination of permanent establishments, including representative offices as a possible form of a fixed place of business.

The factual activities carried out in Indonesia, the applicable domestic tax rules, and any relevant tax treaty must be examined.

Activities that are solely preparatory or auxiliary may qualify for an exception under the applicable rules and treaty provisions. That conclusion requires an assessment of what the Indonesian office does.

Invoicing customers from overseas does not, by itself, resolve the issue.

For foreign companies that need assistance with ongoing administration, InvestinAsia’s Indonesia tax compliance services can support the post-registration arrangements.

Personnel and Immigration Compliance

Foreign nationals working at a representative office need the appropriate immigration and employment authorization for their activities.

Employing Indonesian staff also creates payroll and employment-related obligations under the applicable rules.

Before assigning personnel to the office, confirm the proposed roles, employment arrangements, and the requirements associated with each individual’s circumstances.

Representative Office vs PT PMA: Understanding the Difference

A general KPPA and a PT PMA serve different purposes.

A KPPA provides a representative presence for the foreign parent within the activities permitted under its registration. A PT PMA is a separate Indonesian limited liability company established for foreign investment.

An appropriately registered and licensed PT PMA can undertake commercial activities within its authorized business scope.

The general PT PMA minimum issued and paid-up capital and minimum investment value are different tests.

Article 26 of BKPM Regulation No. 5 of 2025 sets a general minimum issued and paid-up capital of IDR 2.5 billion per limited liability company and a separate total-investment threshold above IDR 10 billion, generally assessed per five-digit KBLI business activity and project location, excluding land and buildings.

The regulation provides specific calculation rules and exceptions for particular sectors and activities.

The investment-value threshold should not be described as a requirement to deposit IDR 10 billion as paid-up capital.

For a detailed explanation of the incorporated structure, read our article on what a PT PMA company can do in Indonesia.

When a Foreign Company Outgrows Its Representative Office

A foreign company may begin with a general KPPA while studying Indonesia and later decide to establish a commercial operation.

The change often becomes apparent when the Indonesian team’s responsibilities expand.

Consider a foreign industrial-equipment supplier with a representative in Jakarta.

During the first year, the representative meets prospective buyers, gathers technical requirements, and reports market findings to headquarters.

The supplier then decides to hold inventory in Indonesia, provide paid installation services, and invoice Indonesian customers.

Those proposed activities require a different licensing assessment. The original general KPPA registration does not authorize unrestricted local commercial operations.

A PT PMA may provide the appropriate incorporation route, subject to foreign investment eligibility and the applicable sector requirements.

The company should assess its intended activities against Indonesia’s Standard Industrial Classification, known as KBLI, before incorporation.

The transition requires its own corporate-registration exercise. The foreign company should not assume that it can convert the KPPA’s existing NIB into a PT PMA registration without establishing the required Indonesian company.

For foreign parent companies preparing to make that transition, our guide to registering a PT PMA in Indonesia explains the incorporation process.

Investors planning their expansion budget should also review the PT PMA minimum capital requirements, including the distinction between paid-up capital and the total investment plan.

Preparing Your Representative Office Registration With InvestinAsia

Foreign companies considering a representative office should resolve three practical questions before filing: which category fits the planned activities, whether the parent company can supply the required documents, and whether the proposed Indonesian office arrangement satisfies the applicable rules.

For companies that need a general KPPA, InvestinAsia provides Representative Office setup services in Indonesia.

InvestinAsia is the market entry arm of vOffice Group. Its Indonesia market-entry work is supported by vOffice and IZIN.co.id for corporate legal, licensing, and workspace-related services.

The Representative Office service page provides information about the published KPPA setup packages and their stated inclusions. Foreign companies considering specialized trading, e-commerce, construction, or electricity-support-services representation should confirm the relevant service scope separately.

If your company is considering the package that includes virtual-office support, confirm that the proposed lease and premises satisfy the general KPPA requirements before proceeding.