Invest in Bali: New KBLI Closures and What Foreign Investors Must Do Now

The rules for foreign direct investment in Bali changed significantly in 2026. Entrepreneurs looking to invest in Bali through a PT PMA must now navigate a tightened regulatory environment, where several KBLI OSS codes are no longer available for foreign-owned companies in the province.

This is not a minor policy adjustment. It is a structural shift, backed by two official letters from the Bali Governor and now actively enforced at the OSS registration level.

What Just Happened: Bali’s KBLI Closure Explained

Starting May 2026, new PT PMA business setups using low-risk and medium-low-risk KBLI codes are being blocked in Bali’s OSS system. This includes both brand-new registrations and amendments or expansions of existing companies into the Bali province area.

The change stems from two formal letters submitted by Governor Wayan Koster to Indonesia’s Minister of Investment and the Head of BKPM, dated December 10, 2025 and January 28, 2026. Both letters requested the closure of specific KBLI categories and the use of virtual offices for PT PMA in Bali.

Key points from the Governor’s letters:

• Bali had recorded 19,262 PMA business actors between 2021 and 2025, representing roughly 40% of all national PMA NIBs.
• Of 55,458 total projects registered, 47.55% were classified as low-risk requiring no standard certificates or additional licenses.
• Many PT PMA entities used their NIB only as a residency tool, with no actual economic activity, no land purchase, no facility construction, and no environmental permits.
• This scheme has led to lost regional tax revenue, unplanned population density, weak environmental oversight, and minimal local employment absorption.

Pro Tip: The closures are being implemented at the OSS level, meaning applications are being rejected automatically at the system level, not just by a manual review. There is currently no announced end date for this restriction.

The 9 KBLI Codes Now Blocked for PT PMA in Bali

The Governor’s January 2026 letter specifically named nine KBLI codes that were most commonly misused by PT PMA companies in Bali. These are now blocked in the OSS system for new PMA registrations at Bali province addresses:

Beyond these nine, any other KBLI classified as low-risk or medium-low-risk is also now blocked for PT PMA registration under a Bali province address.

Why These Sectors Were Targeted

These KBLI categories share one common characteristic: they all fall under low-risk and medium-low-risk classifications, meaning they require only a NIB to operate and no additional standard certificates or sector-specific permits.

That made them highly attractive for misuse. According to the Governor’s December 2025 letter, PT PMA entities using KBLI 70209 (Other Management Consulting Services) were the most documented case, using the NIB as a legal residency gateway for foreign nationals without any genuine productive economic activity.

The consequences of this misuse, as outlined in the official letters:

• Loss of regional income from taxes and levies.
• Unplanned growth in the foreign resident population without spatial planning considerations.
• Weakened environmental monitoring capacity.
• Minimal absorption of local labor.
• An unhealthy investment climate that undermines genuine foreign direct investment.

The second letter also referenced a violation of the minimum PMA investment requirement of IDR 10 billion, as set under Presidential Regulation No. 10/2021 (amended by No. 49/2021) and Government Regulation No. 28/2025.

What This Means If You Already Have a PT PMA in Bali

For existing PT PMA companies already registered and operating under low or medium-low risk categories in Bali, the current guidance is that risk depends on the specific situation. A genuine operation with a real commercial address and actual revenue carries a lower compliance risk.

The first practical step for existing businesses is an LKPM (Investment Activity Report) review to assess compliance. Companies that have been genuinely operating within the scope of their KBLI registration, using a real physical office address and generating actual revenue, are in a meaningfully different position from those that registered purely for residency access.

What existing PT PMA holders should do now:

• Conduct a full review of their KBLI registration against current business activities.
• Ensure the registered business address is a real commercial location, not a virtual office.
• Submit all outstanding LKPM reports to demonstrate genuine capital realization.
• Seek legal advice on whether a KBLI amendment or restructuring is appropriate.
• Avoid any new amendments that expand operations into Bali under restricted KBLI codes.

Pro Tip: The OSS system’s blocking mechanism applies to new setups AND to companies being amended or expanded into Bali. Even if a Jakarta-registered PT PMA tries to add a Bali branch under a restricted KBLI, that application will now be blocked at the system level.

What Is Still Open: PT PMA Options That Remain Available in Bali

The closures target low-risk and medium-low-risk KBLI categories. This means the door remains open for medium-high and high-risk business activities, which by nature require more documentation, more regulatory oversight, and a genuine operational commitment.

This is, in fact, a deliberate policy direction: Bali is moving toward quality-driven foreign investment, not volume-driven registration.

KBLI categories still open for PT PMA in Bali (medium-high and high-risk examples):

• KBLI 55110 – Star-rated hotel accommodation (high-risk, requires environmental and building permits)
• KBLI 56101 – Full-service restaurant activities
• KBLI 86901 – Wellness, spa, and health services
• KBLI 62010 – Computer programming and software development (100% foreign ownership eligible)
• KBLI 93199 – Sports and recreation facilities
• KBLI 41012 – Real estate development (construction and development, not just rental)

These sectors require an environmental license (AMDAL or UKL-UPL), multiple supporting permits, and a demonstrated investment plan. That is precisely what separates a genuine Bali investment from a license-of-convenience structure.

Pro Tip: Medium-high and high-risk KBLI codes require additional documents before applying for OSS verification, including environmental assessments and building permits. Working with an experienced legal and compliance team from the outset will save significant time and prevent costly errors.

Virtual Offices: No Longer Acceptable for PT PMA in Bali

The Governor’s December 2025 letter made a clear demand: the closure of virtual office use for PT PMA registrations in Bali province. As of May 2026, this is being enforced.

Foreign investors must now register their PT PMA using a real commercial address that correctly corresponds to the applicable spatial zoning. This is not just a paperwork requirement. Local authorities in Bali conduct physical site visits before issuing the KKKPR (Spatial Conformity Certificate) through the OSS system.

Address requirements for PT PMA in Bali:

• Must be a real, physical commercial address.
• Yellow-zoned areas (residential with commercial potential) are being closely monitored and subject to direct site visits before KKKPR is issued.
• Co-working spaces and dedicated office spaces are acceptable alternatives to leasing standalone offices.
• Virtual office addresses will be rejected at the OSS level.

A practical alternative: For entrepreneurs who want to maintain a Jakarta legal entity while having physical presence in Bali, it is possible to register the PT PMA with a Jakarta address and add a Bali branch location. However, this still requires actual physical presence in Bali, such as a genuine Balinese residential address, a Balinese employee on staff, or both.

Bali Investment in Numbers: The 2026 Context

Understanding why these closures are happening requires looking at the scale of the issue. The numbers from the Governor’s January 2026 letter tell a clear story about how Bali’s investment registry had grown beyond the province’s absorptive capacity:

By the numbers (2021 to 2025):

• 19,262 PMA business actors registered in Bali, around 40% of all national PMA NIBs.
• 55,458 total investment projects recorded.
• 47.55% of those projects were low-risk activities requiring no standard permits.
• Bali’s total investment realization in 2025: IDR 42.81 trillion, with IDR 25.60 trillion from foreign direct investment alone.

These figures reflect genuine economic activity alongside a significant volume of registration-for-residency structures. The 2026 closures are a direct response to that disparity.

For investors who approach Bali with a real business plan, adequate capitalization, and a compliant operational structure, the fundamentals remain strong. The island continues to draw over six million international visitors annually, with tourism, hospitality, and digital services driving sustained commercial demand.

How to Register a PT PMA in Bali Under the New Rules

With the OSS blocking mechanism now active, the process for setting up a PT PMA in Bali requires careful preparation before even approaching the registration portal.

Step-by-step for compliant Bali PT PMA registration in 2026:

1. Identify a compliant KBLI code. Confirm the intended business activity falls under a medium-high or high-risk category. Cross-reference against the current blocked list for Bali province addresses.
2. Prepare a real commercial address. Secure a physical office or co-working space. Confirm the address is correctly zoned for commercial use.
3. Prepare the investment plan. Total investment per KBLI per project location must exceed IDR 10 billion (excluding land and buildings), as required under existing PMA regulations.
4. Prepare incorporation documents. Articles of association, shareholder documents, and director appointments must be completed and notarized before OSS submission.
5. Register through OSS. Submit via oss.go.id to obtain the NIB and applicable sector licenses. Medium-high and high-risk registrations will require supporting environmental and sectoral permits.
6. Deposit paid-up capital. Minimum IDR 2.5 billion must remain in the company account for 12 months from the date of deposit.
7. Begin LKPM reporting. Quarterly investment activity reports are mandatory for almost all PT PMA entities under BKPM Regulation No. 5/2025.

The Real Challenge: Getting This Right Without Missteps

Many of the compliance problems now surfacing in Bali trace back to decisions made at the point of registration. KBLI selection, address registration, and investment planning are not administrative formalities. They are the foundation of whether a PT PMA is structurally sound or legally vulnerable.

The specific problems that have led to today’s closures, including virtual office use, low-risk KBLI misclassification, and dormant entities with no capital realization, are entirely avoidable with proper guidance. Business Hub Asia has worked with foreign investors across Bali and Indonesia on exactly these structural questions, helping clients select the right KBLI, secure a compliant address, and build a registration that withstands scrutiny.

Where foreign investors most commonly go wrong:

• Selecting a low-risk KBLI for convenience rather than accuracy.
• Using a virtual office or residential address instead of a commercial location.
• Failing to plan for the IDR 10 billion total investment threshold per KBLI.
• Ignoring the 12-month capital lock-up requirement after paid-up capital is deposited.
• Not submitting quarterly LKPM reports, leaving the company exposed to automatic administrative sanctions.
• Attempting to add a Bali branch to an existing PT PMA under a restricted KBLI.

A thorough compliance review before registration is significantly less disruptive and less costly than a restructuring exercise after the fact.

Summary: What to Do If You Want to Invest in Bali in 2026

The window for quick, low-friction PT PMA registration in Bali using low-risk KBLI codes is now closed. That is the clearest takeaway from the May 2026 OSS blocking implementation.

What remains is a more demanding, but also more credible, path to foreign investment in Bali. The province continues to be one of Southeast Asia’s most dynamic markets for hospitality, wellness, food and beverage, digital services, and sustainable development. None of that has changed.

What has changed is the minimum standard of commitment required to enter that market as a foreign investor. Real premises. Real business activities. Real capital. Real compliance.

Investors who meet that standard will find Bali’s investment environment as rewarding as ever. Those who were relying on low-risk KBLI shortcuts now need to reassess and recalibrate.

Quick checklist before moving forward: