Bali Freehold Changes 2026, Part II: Inside the PT PMA and KBLI Registration Squeeze
Since May 2026, new company registration has closed across roughly 18 business categories in Bali, and a June classification deadline has caused genuine confusion. Here is exactly what has shut, what remains open, and what it means if you already own.
Part II of II
New here? Start with Part I
Bali Freehold Changes 2026 covers the nominee-ownership crackdown and the HGB-versus-leasehold decision — the foundation for the PT PMA and KBLI mechanics covered below.
Ask five people in Bali what happened to foreign property investment in June 2026, and you will likely get five different answers — a freehold ban, a PT PMA shutdown, a licensing overhaul, or nothing much at all. The confusion is understandable. Three genuinely separate regulatory threads landed within a few months of each other: a provincial crackdown on nominee ownership in February, a closure of new company registration in a defined list of business categories from around May, and a routine national reclassification of business codes with an administrative deadline in June. Only one of those three is actually new and restrictive. The other two are being widely misdescribed.
This matters because the practical question for a foreign buyer — or a foreign owner already holding property through a PT PMA — is not "is freehold banned." It never was available in the first place, as Part I sets out. The real question is narrower and more useful: can a new PT PMA still be registered to buy Bali property today, in which business categories, at what scale, and what happens to a company that was set up before any of this started.
Below, we work through what closed, what is merely being reorganised, what the workarounds being used in practice actually look like, and — a question we are increasingly asked directly — what it means if you already hold a Bali property through a PT PMA and want to sell it on.
Key Takeaways
- New PT PMA registration has closed in roughly 18 lower-risk business categories since May 2026 — including general real estate (KBLI 68111) and hotels or villas under 6,000 m² — following a Bali Governor's letter of 28 January 2026. Existing PT PMAs and the HGB titles they hold are unaffected.
- 18 June 2026 is not an ownership deadline. It is the cut-off for Indonesia's national KBLI 2020→2025 business-classification system to finish migrating inside the OSS licensing platform — an administrative exercise, not a new restriction on foreign buyers. The practical risk is narrower: a company that fails to migrate its registration could see its NIB blocked for renewals and compliance filings.
- Workable routes remain. Larger-scale hotel development (broadly, 6,000 m² and above), registering under a business category that stays open, or acquiring an existing PT PMA that already holds a valid licence in a now-closed code, are all being used in practice — alongside continued use of Hak Pakai and leasehold structures that sit outside the PT PMA system entirely.
- If you already own via HGB through a PT PMA, your title has not been invalidated, and share-sale remains the established mechanism for transferring ownership to a new foreign buyer. That said, if a sale triggers a fresh OSS filing, the position is not fully settled in public guidance — worth confirming with a notary before you list.
What Actually Changed: The May 2026 OSS Closure
On 28 January 2026, Bali's Governor, I Wayan Koster, wrote to Indonesia's Ministry of Investment (BKPM), formally requesting that new foreign-company (PT PMA) registration be closed across a defined list of lower-risk business categories in Bali — the provincial government's stated aim being to protect small and medium Indonesian-owned businesses from being crowded out by foreign-owned entrants in sectors that were never intended for large-scale foreign capital. Roughly a month later, on 24 February, Perda 4/2026 criminalised nominee ownership arrangements (the subject of Part I). Then, from around the third week of May 2026, the OSS licensing system itself began rejecting new PT PMA applications across the requested categories.
The most complete public account of the affected list comes from ANTARA News Bali, Indonesia's state news wire, which reported the following 18 KBLI codes as closed to new foreign-company registration*:
| KBLI Code | Business Category |
|---|---|
| 55110 | Star-rated hotels, under 6,000 m² building area |
| 55120 | Non-star ("melati") hotels, under 6,000 m² building area |
| 55900 | Other short-term accommodation |
| 68111 | Real estate, self-owned or leased |
| 70209 | Other management consultancy activities |
| 70204 | Industrial management consultancy |
| 77100 | Motor vehicle rental |
| 77311 | Motorcycle and scooter rental |
| 47711 | Clothing retail |
| 47511 | Textile retail |
| 47249 | Other specialised food retail |
| 47991 | Mobile and itinerant food retail |
| 56303 | Cafés and bars |
| 56305 | Traditional medicine and herbal shops |
| 14120 | Tailoring and made-to-measure clothing |
| 93111 | Sports stadium and facility operation |
| 93116 | Fitness centres |
| 93191 | Sports event promotion and organisation |
*This list is corroborated by two independent sources: eight of the codes are named directly in Governor Koster's 28 January 2026 letter to the Ministry of Investment (BKPM), and all 18 appear in a second outlet's report (VOI, citing ANTARA News Bali). We have not verified them against the Ministry's own implementing order directly — confirm any specific code with a licensed consultant before relying on it.
For a property buyer, two lines matter most: 68111, the general real estate code, and the two accommodation codes, 55110 and 55120, both capped below 6,000 m² of building area. Together, they close off the straightforward route — register a small PT PMA, buy a villa, hold it as a real estate or accommodation business — that a large share of the market has used for years. It is worth restating plainly what this closure does not do: it does not touch a PT PMA that was already registered and licensed before the closure took effect, and it does not affect the HGB title that company holds. Existing structures carry on exactly as before.
Existing PT PMA-held villas and their HGB titles are unaffected by the 2026 closures — the restriction applies to new company registration, not to property already held.
The 18 June Deadline: What It Is, and Is Not
A great deal of the confusion around Bali's 2026 rules traces back to a single date — 18 June — being attached to the wrong story. That date is the deadline for Indonesia's KBLI 2025 business-classification system to finish integrating into the OSS platform, replacing the previous KBLI 2020 code set nationwide. It is a housekeeping exercise that has been years in the making, not a Bali-specific measure and not a new restriction on land or company ownership.
Where a business code has simply been renumbered with no change to its underlying activity, the migration happens automatically inside OSS and the AHU company-registry system — no amendment to a company's Articles of Association is required, and existing licences remain fully valid. Where a code's actual scope or substance has changed, a manual update is needed. Indonesian legal advisers tracking the rollout have not identified any scenario in which the migration itself blocks an existing, compliant PT PMA from operating.
There is a secondary, genuinely practical risk worth flagging, though public guidance on its scope is thin: a company that has not migrated its NIB (business registration number) by the deadline could, in principle, find that number blocked or flagged inside OSS for future filings — renewals, amendments, annual reporting. We have not found this specifically confirmed for Bali PT PMAs, but the sensible response for anyone holding a company through PT PMA is the same either way: confirm with your registered agent or notary that your NIB has been migrated to the KBLI 2025 classification, and keep the confirmation on file.
The headline correction worth making plainly: 18 June 2026 does not close the door on foreign property ownership in Bali, and it never opened one that had previously been shut. It is a classification-system deadline. The genuinely restrictive development is the May 2026 closure of new PT PMA registration in specific codes, described above — a different date, a different mechanism, and a considerably narrower effect than "freehold deadline" suggests.
Old KBLI Codes vs New: What Actually Changed
Separately from the May closures, the underlying business-classification system used across Indonesia was itself restructured, moving from the KBLI 2020 edition to KBLI 2025. For the accommodation sector specifically, the clearest documented change is the renumbering of standard villa short-stay rental activity:
| KBLI 2020 Code | KBLI 2025 Code | Activity | Migration Type |
|---|---|---|---|
| 55193 | 55203 | Villa (short-stay rental) | Renumbered — typically automatic where activity is unchanged |
We were not able to locate a published, comprehensive table of every KBLI 2020 → 2025 code change relevant to real estate and hospitality — the government circular describing the full migration does not appear to be publicly posted in a form we could access. Where a specific code matters to a transaction, confirm the current classification directly with a notary or licensing consultant rather than relying on any single published list, including this one.
It is worth being precise about what this renumbering is and is not. It is not the same event as the May 2026 closure of code 68111 and the sub-6,000 m² hotel codes — those are two separate developments that happen to have landed in the same window. The 55193→55203 renumbering is a reclassification exercise; whether the renumbered code itself remains open to new foreign registration is a separate question, and current guidance from Bali-focused corporate services firms suggests small-scale villa rental activity has, in practice, long sat within a category understood to be reserved for Indonesian-owned small businesses and cooperatives — a restriction that appears to predate the 2026 measures rather than originate from them. Anyone structuring a new villa-rental business through a PT PMA should treat this as an area requiring direct, current confirmation rather than assumption.
Workarounds Being Used in Practice
None of the routes below are loopholes in the sense of circumventing the rules — they are the paths that remain genuinely open within the current framework, and each is reported to be in active use by consultants and notaries working with foreign buyers in Bali today.
Build at Scale: The 6,000 m² Threshold
The closure of codes 55110 and 55120 applies specifically to hotels below 6,000 m² of building area. Developments at or above that threshold are understood to sit within a different, still-open licensing tier — consistent with the government's stated aim of curbing small-scale foreign-owned guesthouses and villas rather than blocking genuine hotel and resort investment. For a developer with the capital and ambition for a hotel-scale project, this remains a functioning route to a PT PMA-held HGB title, though it is a materially different proposition from buying a single villa.
Structure Under an Open Code
The 18-code closure list is specific, not general — a PT PMA can still be registered today under any business category not on that list, provided the company's actual activity genuinely matches the code applied for. Consultants report continued use of the higher-risk licensing pathway for activities that were always classified there, and — as noted in Part I — using an accommodation-management code (KBLI 55901, managing a property on an owner's behalf rather than operating it directly as an accommodation business) as one legitimate route still available for rental-focused buyers.
Acquire an Existing PT PMA
Because the closure applies to new registration rather than to companies already licensed, one response gaining traction in the market is acquiring an existing, often dormant, PT PMA that already holds a valid NIB in one of the now-closed codes, rather than incorporating a new one. This is reported as an emerging area of activity among Bali corporate-services firms, with inactive companies increasingly being marketed for resale. It carries its own diligence requirements — confirming the company's tax history, any outstanding liabilities, and that its licence and land-use record are genuinely clean — but it is a structurally sound route precisely because it does not require new OSS registration in a closed code.
Work With a Specialist, Not a Generalist
Every route above depends on getting the classification right the first time. The cost of a wrong KBLI code, an application filed the week before or after a closure took effect, or a company structured under an address that does not match where the business actually operates, has risen considerably in 2026 — Indonesian advisers have specifically warned against using a nominal registered address in a different province simply because a code remains open there nationally while closed in Bali; regulators are understood to be alert to exactly this pattern. A notary or investment consultant who tracks OSS in real time, rather than one relying on guidance from earlier in the year, is now a meaningfully more important part of any PT PMA structuring decision than it was in 2025.
Worth flagging plainly: the 18-code closure list, the scope of the 6,000 m² threshold, and the practical treatment of dormant-company acquisitions are all areas where public documentation is thinner than we would like for a topic this consequential. Treat everything in this section as a starting point for a conversation with a licensed Indonesian notary or investment consultant, not as a substitute for one.
Demand for Bali has not slowed alongside the licensing changes — the market is adjusting around them, not away from them.
If You Already Own: Selling On Your HGB Asset
We are increasingly asked a version of this question by existing owners: if my villa is held through a PT PMA in a business category that is now closed to new registration, can I still sell it to another foreign buyer? The short answer is yes, in principle — but the mechanism, and one open question within it, are both worth understanding before you list.
Your PT PMA's licence and NIB, and the HGB title it holds, were issued before the 2026 closures and remain valid; nothing in the closures retroactively cancels an existing, compliant structure. The established route for transferring ownership to a new foreign buyer is a share sale: the incoming buyer purchases the shares of your existing PT PMA rather than the company applying for a fresh licence, with the change notified to BKPM. Historically, this has been treated as a notification rather than a fresh approval process, and has typically taken a small number of months to complete.
The open question is narrower, and worth being honest about rather than glossing over: some corporate advisers note that certain changes to a PT PMA — depending on exactly what is amended and how — can trigger a fresh OSS filing, and any such filing would need to be structured under a currently open KBLI code. Whether a straightforward share transfer, with the company's licensed activity unchanged, counts as triggering that kind of filing does not appear to be spelled out in public guidance we could locate. In practice, this means the safest position for a seller is to have your notary confirm, before you go to market, exactly what a transfer will and will not require to file — rather than assuming, either way, that a sale will be entirely uneventful or that it will be blocked.
| Your Position | What the 2026 Closures Mean for You |
|---|---|
| Existing, compliant PT PMA with HGB title | Unaffected — licence and title remain valid; no action required to continue holding |
| Selling to a new foreign buyer via share transfer | Confirm first — established route, but check with a notary whether your specific transfer triggers a fresh OSS filing |
| Buyer wants to register a brand-new PT PMA to purchase | Closed if the intended activity falls in real estate (68111) or sub-6,000 m² accommodation — buyer needs an alternative structure |
| Buyer acquires your existing PT PMA outright (share sale) | Open — this is precisely the route that sidesteps new-registration closures |
For sellers, this is arguably good news dressed up as bad news: because new PT PMA registration has narrowed in exactly the categories most villa buyers would otherwise use, an existing, clean, compliant PT PMA holding a genuine HGB title has, if anything, become a more valuable and more straightforward route into the market for a new foreign buyer — not a less valuable one. The value is in the company being already licensed, not despite it.
What This Means for Buyers Today
Put together, the practical position in August 2026 is more workable than the "freehold deadline" headlines suggest, provided the right structure is used from the outset. A buyer wanting a single villa for personal or family use has Hak Pakai (if eligible on a residence permit) or a well-negotiated leasehold, neither of which touches the PT PMA system at all — see Part I for the full comparison. A buyer wanting a rental-income property through a company structure has three realistic paths: acquire an existing, compliant PT PMA rather than registering a new one; structure a new PT PMA under a genuinely open code, most practically as an accommodation manager rather than an accommodation operator; or commit to hotel-scale development above 6,000 m², where standard licensing remains open. What no longer works, reliably, is registering a brand-new, small-scale PT PMA under a general real estate or small-hotel code and expecting it to be approved — that door closed in May 2026, and the confusion around 18 June should not be read as either a wider closure or a reprieve.
Featured Bali Properties
A selection of current Polarius listings across Bali, shown in ascending order of asking price. Most are freehold-marketed HGB properties held via existing, licensed PT PMA companies — precisely the kind of asset this article's "acquire an existing company" route is designed to make more, not less, attractive to a new foreign buyer. One (the Uluwatu residence) is offered on a leasehold basis, illustrating the alternative route set out in Part I.
Modern Tropical Villa, Tumbak Bayuh
Tumbak Bayuh, Canggu
Freehold Villa, Bingin Hills
Pecatu
Freehold Villa, Nuanu
Tabanan
Luxury Freehold Villa, Ubud
Ubud
Ultra-Contemporary Freehold Villa, Kedungu
Kedungu, Tabanan
Alexis Dornier Architectural Villa, Uluwatu
Uluwatu
Freehold Villa, Gianyar
Gianyar
Cliff-Top Villa with Ocean Views, Bukit
Badung
Opulent Freehold Mansion, Canggu
Canggu
For an exclusive look at Bali's finest properties, click here.
Sources and References
- Governor of Bali, Letter No. B.27.000/642/PM/DPMPTSP, 28 January 2026, on the restriction of new PT PMA licensing across designated business categories in Bali Province.
- ANTARA News Bali, "18 bidang usaha dengan penanaman modal asing (PMA) di Bali ditutup demi jaga usaha lokal," 2026 — the 18-code list summarised above.
- ANTARA News (English), "Bali blocks foreign investment in 18 business categories," 2026.
- Bali Provincial Government (baliprov.go.id), official statement on OSS access restrictions for PMA across designated KBLI categories.
- The Jakarta Post, "Bali cracks down on foreign-owned small businesses amid concerns over local economy," 25 July 2026.
- Kompas (money.kompas.com and denpasar.kompas.com), coverage of Bali's foreign investment restrictions, July 2026.
- Schinder Law Firm, "Implementation of KBLI 2025 in the OSS System: Timeline, Adjustment Requirements and Legal Implications," 2026.
- Emerhub, "Indonesia Confirms KBLI 2025 Migration Will Be Automatic" and "Bali Closes Low-Risk and Medium-Low-Risk PMA Licensing in OSS," 2026.
- Bali Provincial Government, Regional Regulation (Peraturan Daerah) No. 4 of 2026 on the Control of Productive Land Conversion and the Prohibition of Nominee Land Ownership, 24 February 2026.
This article summarises publicly available Indonesian legal, regulatory and news sources for general information purposes. Several details — including the complete list of restricted business categories and the precise treatment of company-ownership transfers under the 2026 measures — were not confirmed against primary government documentation at the time of writing and are flagged accordingly throughout. This is not legal, tax or investment advice. Foreign buyers and sellers should always obtain independent legal counsel from an Indonesia-qualified notary (PPAT) or lawyer before entering into any land, property or company transaction.
Structure Your Bali Purchase — Or Sale — Correctly
Whether you're buying through an existing PT PMA, weighing up a new company structure against Hak Pakai or leasehold, or exploring how to sell an existing HGB asset in light of the 2026 changes, our team can connect you with the right on-the-ground legal and notarial partners.
