For foreign investors and property developers, the transition to Government Regulation (PP) No. 28 of 2025 has created significant confusion.
Many villa owners operate under the assumption that their pre-2024 permits are sufficient, unaware that the property permitting framework has shifted.
The new rules explicitly revoke the previous PP 5/2021 regime, introducing a centralized system that locks every aspect of property development into the Online Single Submission (OSS) network.
Ignoring these updates is a direct threat to your asset’s viability. The “build first, fix later” mentality is being dismantled by authorities armed with new supervision tools.
Under the new “continuous compliance” model, failure to align with the updated Bali real estate licensing requirements can lead to frozen business identification numbers (NIBs), sealed construction sites, and even revocation of operating rights.
The solution lies in understanding the mechanics of PP 28/2025 before you sign a lease. This regulation streamlines the risk-based approach but demands strict adherence to spatial planning (KKPR) and Operational Suitability (SLF) standards.
This guide breaks down exactly how the new law impacts your projects, providing a clear roadmap to keep your property authorization in Bali secure and compliant.
Table of Contents
- What PP 28/2025 Does for Property in Bali
- Core Changes to KKPR and Zoning
- The New PBG and SLF Regime
- OSS RB The Single Front Door
- Real Story: The "Algorithmic Shock" in Uluwatu, Bali
- Step-by-Step Licensing Flow 2026
- Continuous Compliance and Supervision
- Key Risks and Penalties to Avoid in Bali
- FAQs about PP 28/2025
What PP 28/2025 Does for Property in Bali
Government Regulation No. 28 of 2025 is now the supreme legal framework governing business activities in Indonesia. It formally replaces PP 5/2021. For the property sector, this regulation reinforces the centralization of all permits through the OSS Risk-Based Approach, removing much of the discretionary power previously held by local district offices regarding property authorization in Bali.
The regulation introduces a shift from licensing as a “one-off event” to licensing as a process of “continuous compliance.” This means obtaining initial permits is just the beginning.
The system monitors your property permitting framework compliance throughout the lifecycle of the project. Developers must regularly update their data and prove compliance with technical standards, or risk automatic flags that can halt operations.
Core Changes to KKPR and Zoning
The Kesesuaian Kegiatan Pemanfaatan Ruang (KKPR) remains the gatekeeper for all property projects. Under PP 28/2025, the issuance of KKPR is tightly integrated with the District Spatial Plan (RDTR) of each regency.
The regulation introduces simplified pathways for low-risk activities but strictly enforces formal verification for commercial projects like villas and hotels.
For investors, property authorization in Bali is now inextricably linked to the specific zoning of your land plot. You can no longer rely on a general designation; you must secure a formal KKPR that explicitly allows for your specific Business Classification Code (KBLI).
Attempting to use “micro business” exceptions to bypass formal KKPR for a commercial villa project is a high-risk strategy that the new regulation targets for enforcement.
The New PBG and SLF Regime
While PP 28/2025 focuses on business licensing, it firmly entrenches the building approval system within the OSS framework. The Structural Safety Permit (PBG) and Operational Suitability (SLF) certificate are mandatory prerequisites for obtaining a valid business license.
The regulation clarifies that no commercial activity can commence until the building has been certified as safe.
In the context of Bali real estate licensing, this ends the era of operating with just an IMB while ignoring modern safety standards.
The regulation mandates that existing buildings undergoing changes in function must obtain a new PBG and SLF. This ensures that all properties meet strict codes before they can legally welcome guests, making property authorization in Bali contingent on physical safety.
OSS RB The Single Front Door
The Online Single Submission (OSS) system is the single “front door” for licensing. Under PP 28/2025, every actor in the real estate sector must register via OSS Indonesia.
The system categorizes your project into Low, Medium, or High risk based on your KBLI code and scale, which is crucial for any Foreign-owned entity setup.
For Bali real estate licensing, this risk categorization determines your path. Low-risk projects might only need an NIB, while Medium and High-risk projects require a verified Standard Certificate.
The system cross-references data with the Ministry of Agrarian Affairs and the tax office, making it impossible to hide non-compliant assets regarding your property status.
Real Story: The "Algorithmic Shock" in Uluwatu, Bali
James (42, Perth) thought his Uluwatu villa portfolio was flying under the radar. He had been operating for years using residential licenses for what was clearly a commercial hotel business, relying on the “grandfather clause” myth.
He wasn’t caught by a human inspector; he was caught by an algorithm. In early 2026, the OSS system automatically cross-referenced his tax returns (showing commercial income) with his zoning permits (showing residential usage).
The mismatch triggered an instant, automated suspension of his NIB, freezing his ability to do business.
James realized too late that in the eyes of the new system, an old permit is not a shield—it’s a target. He was locked out of payment gateways and faced potential closure because his asset compliance pathway was blocked.
Desperate to unlock his assets, James contacted our team. We conducted a forensic audit of his property permitting framework status and guided him through the complex process of upgrading his titles.
It involved securing retrofitted SLF certificates and paying back-taxes, but after three months, his NIB was reactivated. James now operates a fully compliant PT PMA, safe from the digital dragnet.
Step-by-Step Licensing Flow 2026
Navigating the new landscape requires a disciplined approach. The default flow for securing valid property authorization in Bali under PP 28/2025 involves four distinct stages.
- Land and Spatial Compliance: Verify the District Spatial Plan. Apply for a KKPR via OSS. If the land cannot be commercially zoned, moving forward is impossible.
- Building Approval: Submit drawings to the SIMBG system for the Structural Safety Permit (PBG). This must be done before construction begins.
- Functional Worthiness: Once construction is complete, apply for the Operational Suitability (SLF) certificate. This involves a physical inspection.
- Business Licensing: Upload your KKPR, PBG, and SLF to the OSS system to activate your NIB and finalize your Bali real estate licensing.
Continuous Compliance and Supervision
The most radical change introduced by PP 28/2025 is supervision. Authorities are legally mandated to monitor your activity. This involves administrative checks and field inspections.
The regulation empowers agencies to conduct spot checks to ensure the reality matches the data in your Foreign-owned entity setup file.
For villa owners, maintaining property authorization in Bali requires ongoing effort. You must submit Investment Activity Reports (LKPM) on time and ensure safety certificates are renewed. “Silent” modifications are explicitly targeted.
The system is designed to detect these anomalies, leading to sanctions that can invalidate your permits.
Key Risks and Penalties to Avoid in Bali
The penalties for non-compliance are severe. Initial violations result in written warnings via the OSS system. If ignored, authorities can suspend business activities.
For property businesses, this means you cannot legally rent out your asset, rendering your property permitting framework useless.
The ultimate sanction is the revocation of the license and potentially demolition orders. A common mistake is assuming old licenses protect you.
Transition rules specify that new activity triggers new requirements. Failing to adapt your Bali real estate licensing strategy puts your investment capital in jeopardy.
FAQs about PP 28/2025
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Does PP 28/2025 apply to existing villas regarding property authorization in Bali?
Yes. While existing valid licenses are respected, any change in business activity, expansion, or modification requires compliance with the new risk-based system.
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Can I get an NIB without a Structural Safety Permit (PBG)?
You can get an NIB, but it will likely be "unverified." To operate legally and activate your Standard Certificate, you must upload a valid PBG and SLF.
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Is the Operational Suitability (SLF) certificate mandatory for all rental villas?
Yes. Under PP 28/2025, any building used for business purposes must have an SLF to prove it is safe, which is a key part of Bali real estate licensing.
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Can I use a residential permit for a commercial villa?
No. Property authorization in Bali rules require your building permit function to match your actual business use. You must convert your residential permit to a commercial one.
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How do I upgrade my license to the new system?
You need to log into your OSS account, update your business data (migration), and fulfill missing commitments to ensure your asset compliance pathway is current.
