The landscape for foreign investment in Indonesia has undergone a seismic shift as we enter 2026. For years, the “low-risk” loophole allowed many to operate in a legal gray area, but the implementation of Government Regulation (GR) 28/2025 has effectively closed those gaps.
If you are a property developer or business owner, you are likely feeling the heat of increased provincial scrutiny. The “build first, permit later” mentality is now a fast track to property sealing or immediate deportation, as authorities have digitized the entire enforcement trail to catch non-compliant entities.
The solution is a proactive transition to the new investor regulatory standards in Bali. This guide breaks down the structural overhaul of risk-based licensing Bali for investors to ensure your PT PMA remains protected, fully audited, and legally resilient in this new era of transparency.
Table of Contents
- The Transition from GR 5/2021 to the New GR 28/2025 Standard
- Consolidation and Standardization of Supporting Licenses (PB UMKU)
- Formalized SLAs and the Deemed Approval (Fiktif Positif) Mechanism
- Enhanced Post-Licensing Supervision and Risk-Based Audits
- Tighter Integration of Spatial (KKPR) and Environmental Approvals
- Cross-Departmental Digital Integration of OSS, Tax, and Immigration
- Mandatory Tourism Registration for All Short-Term Villa Rentals
- Real Story: Navigating the Regulatory Shift in Bingin
- FAQ's about 7 Key Changes in Risk-Based Licensing in Bali for Investors
The Transition from GR 5/2021 to the New GR 28/2025 Standard
The most significant change for any business actor this year is the full replacement of GR 5/2021 with GR 28/2025. This new regulation serves as the definitive legal backbone for all risk-based licensing Bali for investors, expanding the number of regulated sectors from 16 to 22. Notable additions include the creative economy and advanced electronic transaction operations, which are now under strict oversight.
For the international community, this isn’t just a change in paperwork; it’s a change in how the government views your presence. The Online Single Submission system has been upgraded to separate the “Business Initiation” phase from the “Operational” phase more clearly. This ensures that a PT PMA cannot begin commercial activity until every prerequisite, from land use to specific sectoral permits, is fully verified in the system.
Consolidation and Standardization of Supporting Licenses (PB UMKU)
One of the primary goals of the 2026 reform was to untangle the “permitting jungle.” GR 28/2025 has consolidated the previously fragmented list of over 1,000 supporting business licenses (PB UMKU) into roughly 357 standardized categories. This change forces investors to be much more precise when selecting their business field classification.
In the past, a general tourism code might have sufficed, but today, your corporate registration digit must reflect a specific “license family” that matches your actual day-to-day operations. If your PT PMA is operating a beach club but only holds a permit for a small café, the system’s automated cross-check will flag the discrepancy, making you a prime target for the newly established regional task forces.
Formalized SLAs and the Deemed Approval (Fiktif Positif) Mechanism
To combat bureaucratic delays, the government has introduced strict Service Level Agreements (SLAs) for technical approvals. For instance, wastewater and emission standards now have a maximum 30-day processing window. If a ministry fails to act within the SLA, the “fiktif positif” or deemed approval rule can be invoked, allowing the application to proceed automatically for approximately 258 specific business codes.
However, this is a “trust but verify” system. A deemed approval does not exempt you from foreign licensing compliance; it simply moves the burden of proof to the post-licensing stage. If an audit later finds that your environmental or building documents were deficient, your risk-based licensing Bali for investors can be revoked immediately, even if the system gave you an initial “green light.”
Enhanced Post-Licensing Supervision and Risk-Based Audits
The focus has shifted from “pre-approval” to “post-operational” supervision. Under GR 28/2025, regional authorities have been granted expanded powers to conduct incidental audits based on a company’s risk profile. If your business is categorized as Medium-High or High Risk, you should expect at least one formal inspection annually.
These audits check for more than just a valid Business Identification Number. Officials will verify if you are fulfilling your environmental management commitments (UKL-UPL) and if your building actually meets the Certificate of Functionality (SLF) standards. Non-compliance now leads to a graduated sanction system, moving quickly from written warnings to the temporary suspension of business activities and, ultimately, permanent closure.
Tighter Integration of Spatial (KKPR) and Environmental Approvals
In 2026, the KKPR (Zoning Approval) is the non-negotiable first step. The Bali RBA permit framework now locks your license application until a valid spatial plan compatibility is uploaded and verified. This prevents the common mistake of buying land in a “Green Zone” (agricultural) and attempting to apply for a hospitality license later.
Furthermore, environmental approvals like AMDAL or UKL-UPL are now fully integrated into the digital trail. For developers in Bali, this means you can no longer treat environmental protection as an optional “add-on.” The system now allows for a single environmental document to cover multiple business field classifications, provided they are located within the same ecosystem expanse, which streamlines the process for large-scale integrated resorts.
Cross-Departmental Digital Integration of OSS, Tax, and Immigration
The digital licensing portal is no longer an isolated island; it is now a centralized data hub connected to the Directorate General of Taxes and the Directorate General of Immigration. This means that every move you make is visible to multiple agencies. If your PT PMA reports low investment activity while you are applying for multiple Investor KITAS permits, the system will flag the inconsistency.
This transparency extends to financial reporting. PT PMAs are now required to file quarterly investment reports (LKPM) that are cross-referenced with their corporate tax filings. For those managing luxury assets, it is essential to work with a trusted villa management company to ensure that your operational records, tax obligations, and licensing status are perfectly aligned and ready for any digital cross-check.
Mandatory Tourism Registration for All Short-Term Villa Rentals
The most significant “crackdown” in Bali today involves the short-term rental market. GR 28/2025 clarifies that any property accepting guests—including those on Airbnb or Booking.com—must have a valid tourism business license (TDUP or Pondok Wisata). Platform-level controls are now being tested to ensure that only licensed properties can remain active on these sites.
Operating without these permits is now considered a high-risk violation. Authorities have moved from simple fines to “sealing” properties (disegel) and even initiating tax back-assessments for years of unlicensed operation. For the foreign investor, this change effectively ends the era of informal “nominee” rentals, mandating a formal business structure and proper risk-based licensing Bali for investors to ensure long-term asset security.
Real Story: Navigating the Regulatory Shift in Bingin
Julian, an architect from Berlin, had spent two years building a stunning boutique retreat on the cliffs of Bingin. On paper, he was a “Consultant.” In reality, he was running a high-end guesthouse. The “low-risk” loophole of 2021 had served him well, until a neighboring property was abruptly sealed by the Satpol PP for KBLI non-compliance.
“The digital trail in 2026 is inescapable,” Julian realized. He wasn’t just hiding from inspectors anymore; he was hiding from a centralized system that linked his bank account, his visa, and his villa’s GPS coordinates.
Julian worked with a legal partner to navigate the GR 28/2025 transition. They didn’t just “fix the paperwork”—they restructured his business as a full PT PMA, secured the mandatory Pondok Wisata license, and verified his KKPR status against the updated 2026 Bali spatial plans.
The transition wasn’t just about avoiding fines. “Once I was 100% legal, I was able to partner with global booking luxury platforms that previously rejected me due to lack of a TDUP,” Julian explains. Today, he isn’t just a surfer running a villa; he’s a legitimate hospitality investor with a protected asset and a clear path to expansion.
FAQ's about 7 Key Changes in Risk-Based Licensing in Bali for Investors
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Does GR 28/2025 affect my existing PT PMA created under the old rules?
Yes. While your current license remains valid, you must update your OSS access rights and ensure your business activities match the new standardized KBLI codes and PB UMKU requirements.
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What is the "Deemed Approval" mechanism exactly?
If a ministry does not respond to your permit application within the set SLA (e.g., 30 days), the system automatically considers it approved so you can continue your operations without indefinite delays.
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Can I still use a nominee structure for my Bali property?
Nominee structures are increasingly dangerous in 2026. Data integration makes it easy for authorities to spot foreign-controlled assets hidden under local names, leading to asset seizure or tax fraud charges.
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How much is the minimum investment for a PT PMA in 2026?
The minimum total investment remains above IDR 10 billion (excluding land and buildings) per 5-digit KBLI, with a minimum paid-up capital of IDR 2.5 billion.
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What happens if I fail a post-licensing audit?
You will receive a written warning first. If the violations are not corrected, the government can suspend your operations, issue administrative fines, or revoke your Business Identification Number entirely.
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Do I need a separate environmental permit for every building?
Under the new rules, a single environmental approval can often cover multiple KBLI codes if the activities are integrated within the same property ecosystem.
