Why Does the New IDR 2.5 Billion Deposit Requirement Matter?
It matters because these rules determine whether a PT PMA can retain its NIB and licences.
Figures from the Ministry of Investment put Indonesia's realised investment at IDR 498.8 trillion for the first quarter of 2026, up 7% year on year — confirmation that Indonesia remains one of Southeast Asia's most attractive destinations for foreign direct investment. In this blog, we discuss the five PT PMA paid-up capital rules every foreign shareholder must know. Each builds on our guide to the minimum capital of a PT PMA in Indonesia.
For foreign investors, the PT PMA (foreign-owned limited liability company) remains the vehicle of choice. October 2025 reshaped its capital framework. Under BKPM Regulation No. 5 of 2025, the floor for placed capital dropped to one quarter of its former level. The minimum moved from IDR 10 billion down to IDR 2.5 billion.
That easing came with strings attached. The same regulation keeps a larger investment-plan threshold in force. It also freezes deposited funds for a year and requires documentary evidence of every transfer. Misreading these PT PMA paid-up capital rules can trigger compliance notices, licence delays, or worse. Revocation of the Business Identification Number (NIB) is the ultimate penalty.
What Is the IDR 10 Billion Investment Threshold?
IDR 10 billion is the total investment value required per KBLI line — separate from the IDR 2.5 billion paid-up capital.
Total investment must exceed IDR 10 billion per five-digit KBLI line, excluding land and buildings. This investment-plan threshold under Article 26 of BKPM Regulation No. 5 of 2025 is separate from paid-up capital, which sits at IDR 2.5 billion. The gap is funded through capex, working capital, or retained earnings. Budgeting beyond the PT PMA setup cost in Indonesia 2026 keeps the OSS-RBA application credible.
How Must Paid-Up Capital Be Injected?
Paid-up capital travels directly from the registered shareholder's own account into the PT PMA's corporate account — never through intermediaries or unrelated third parties.
After the deed of establishment is approved and legal-entity status is granted, the full IDR 2.5 billion must be wired. It goes into the PT PMA's own Indonesian corporate bank account. An individual shareholder may remit the money straight from a personal account held in their own name. That direct route into the corporate account is the correct one. What the rules forbid is channelling funds through intermediaries, money changers, or accounts of anyone other than the registered shareholder. Such transfers cannot be traced to the investor, so they are not recognised as a qualifying capital injection.
The path from incorporation to an active licence runs in four steps:
- Incorporation: the Capital Statement Letter, signed by shareholders, directors, and commissioners, is lodged so that OSS registration can proceed
- Deposit: shareholders wire the IDR 2.5 billion into the company's corporate account
- NIB issuance: the Business Identification Number is then released through the OSS-RBA system
- Licence activation: certain business licences and permissions switch on only after the deposit evidence is verified
What Is Bukti Setor Modal and Why Is It Mandatory?
Bank slips or transfer confirmations on file prove the deposit and support activation of licences once the NIB is issued.
Bukti Setor Modal — the proof of the IDR 2.5 billion paid-up capital deposit, made up of bank slips or transfer confirmations — must be kept on file. It supports the lock-up declaration a PT PMA files through OSS at incorporation. The evidence does not itself establish the company's legal standing. That comes from the Ministry of Law and Human Rights (AHU) approving the deed of establishment. What the Bukti Setor Modal does is document that the IDR 2.5 billion deposit has actually reached the corporate account. The OSS-RBA system and BKPM verify this evidence when certain business licences and permissions are activated. That check happens after the Business Identification Number (NIB) has been issued.
How Long Is the Foreign Investment Lock-Up Period?
Capital stays locked for 12 months and can fund operations but not withdrawals, repatriation, or dividends.
Paid-up capital cannot be withdrawn for 12 months after deposit under Article 27 of BKPM Regulation No. 5 of 2025. During the foreign investment lock-up period, funds may still be spent on genuine operations. Permitted uses include:
- Office rental
- Staff salaries
- Equipment
- Construction
They may never be repatriated or taken as dividends. The rule gives the company first-year runway and screens shell entities. Breaches risk administrative sanctions and NIB revocation.
PT PMA Capital Requirements at a Glance
| Capital Rule | Requirement | Key Figure |
|---|---|---|
| Minimum paid-up capital | Wired to the company's Indonesian corporate bank account | IDR 2.5 billion |
| Investment plan | Total value per five-digit KBLI line, excluding land and buildings | Above IDR 10 billion |
| Proof of capital | Bank slips or transfer confirmations filed with OSS-RBA and AHU | Bukti Setor Modal |
| Lock-up period | No withdrawal, repatriation, or dividends; operations spend allowed | 12 months from deposit |
| Capital reporting | LKPM filings on the BKPM-linked OSS portal | Quarterly |
How Often Must LKPM Capital Reports Be Filed?
The LKPM turns deposited capital into a documented track record BKPM can verify each quarter.
The IDR 2.5 billion paid-up capital and the broader IDR 10 billion plan must be reported quarterly. The filing channel is the LKPM on the BKPM-linked OSS portal. The Investment Activity Report (LKPM) documents how that capital translates into real activity. Reported categories include:
- Capex
- Working capital
- Operating spend
Late or missing filings flag the company for BKPM compliance checks and can freeze licence upgrades. Accurate, on-schedule reporting protects foreign ownership rights. It also keeps the compliance record clean for future KITAS work-permit applications. Each approval still rests with the relevant authorities.
Underfunding, indirect transfers, missing deposit evidence, early withdrawals, and late LKPM filings top the list.
IDR 2.5 billion wired correctly is only the start. The most common shareholder capitalization mistakes are practical and avoidable:
- Underfunding the investment plan — wiring the IDR 2.5 billion minimum alone is not a breach. The gap to the IDR 10 billion plan can be funded through capex, working capital, or retained earnings. The mistake is failing to realise that remaining investment as declared.
- Routing the deposit through intermediaries, money changers, or any third-party account. A registered shareholder's own personal account is an allowed source; unrelated accounts are not.
- Failing to keep Bukti Setor Modal bank slips and transfer confirmations on file
- Withdrawing or repatriating capital during the 12-month lock-up
- Filing LKPM reports late or omitting capital-realization figures
Each of these mistakes invites BKPM scrutiny and can stall licence activation.
Why Does Capital Compliance Matter?
Compliant capital records protect ownership rights, speed up NIB issuance and licence activation, and support KITAS approvals.
From the IDR 2.5 billion deposit to the 12-month lock-up, capital compliance is what keeps a PT PMA's licences alive. Under BKPM Regulation No. 5 of 2025, breaches of the deposit, lock-up, or reporting rules trigger administrative sanctions. These can escalate to revocation of the Business Identification Number (NIB), stalling operations and every licence tied to it. A clean compliance record also reassures banks and partners before they extend credit or contracts. It likewise smooths the path for foreign-worker KITAS applications.
Ready to Fund Your PT PMA Correctly?
Our Corporate Professional Advisors structure capital deposits, Bukti Setor Modal filings, and LKPM reporting for foreign investors.
Frequently Asked Questions
IDR 2.5 billion under BKPM Regulation No. 5 of 2025, reduced from IDR 10 billion, deposited into the company's Indonesian corporate bank account.
Yes, as the total investment value required per five-digit KBLI line per project location, excluding land and buildings in most sectors, declared through the OSS investment plan.
It is proof of the capital deposit — bank slips or transfer confirmations — kept on file to support the lock-up declaration filed through OSS. The OSS-RBA system and BKPM verify it when licences are activated after the NIB is issued. Legal standing itself comes from AHU approval of the deed of establishment.
12 months from deposit. Funds may be spent on operations, asset purchases, and construction, but cannot be withdrawn, repatriated, or paid as dividends.
Late or missing quarterly LKPM filings invite BKPM compliance checks, licence delays, and possible administrative sanctions, including risks to the NIB.
Abigail Yu
Author
Abigail Yu oversees executive leadership at 3E Accounting Group, leading operations, IT solutions, public relations, and digital marketing to drive business success. She holds an honors degree in Communication and New Media from the National University of Singapore and is highly skilled in crisis management, financial communication, and corporate communications.
