How to Invest in Bali: The No-Headache Way

A practical, step-by-step path using Indonesia’s new law of licensing PP 28/2025

Bali is still one of the most compelling places to invest in hospitality and real estate—if you treat compliance as a design constraint, not an afterthought.

Indonesia’s new Government Regulation No. 28/2025 (PP 28/2025) tightens and clarifies the risk-based licensing regime, replacing GR 5/2021 and aligning permits inside the OSS system.

Done right, it gives you clearer steps, firmer timelines, and “deemed approval” safeguards. Done wrong, it exposes you to stop-work orders, fines, even forced closures.

The Bali Investor’s Path (PP 28/2025 applied)

1) Start with the map, not the brochure

➡️ Confirm zoning first, then design your project around it. For Bali, use the provincial spatial plan (Perda Bali No. 2/2023) and the latest RTRW/RDTR layers before you even think “booking engine.” Green zones (protected agriculture, conservation) are non-starters for tourism projects.

➡️ In OSS, your KKPR (Conformity of Spatial Utilization) will formalize this fit; PP 28/2025 treats KKPR as part of pre-licensing “persyaratan dasar.”

2) Pick the right vehicle from Day One

➡️ Foreign investors typically use a PT PMA. Current rules require issued capital of at least IDR 10 billion (and an investment plan per KBLI that’s > IDR 10 billion excluding land/buildings). This sits outside PP 28/2025 but is enforced via OSS and BKPM/Ministry of Investment practice.

➡️ Tip: Under-capitalizing or “parking” capital informally will haunt you at banking, immigration, audits, and LKPM reporting.

3) Lock in the Persyaratan Dasar (pre-licensing basics)

PP 28/2025 codifies a clean sequence for foundational approvals, commonly:

✅ KKPR (spatial)
✅ Environmental approval (AMDAL/UKL-UPL → Persetujuan Lingkungan)
✅ PBG (Building Approval), and
✅ SLF (Operational Worthiness).

These are the footing under your license, especially for accommodation and F&B-adjacent assets.

4) Get your NIB and the right risk-based license

Under PP 28/2025, licensing matches your risk tier:

– Low risk → NIB only
– Medium risk → NIB + Standard Certificate (self-declare or verified)
– High risk → NIB + License (explicit approval)

You’ll also use PB-UMKU (supporting licenses) where your operations need them. All of this runs through OSS.

Heads-up: PP 28/2025 orders an OSS upgrade deadline (by 5 October 2025) to reflect the new regime—expect UI/process tweaks and take advantage of the streamlined flows.

*In Indonesia’s risk-based approach to licensing, the Business Identification Number (NIB) isn’t optional… it’s essential*.

5) Build legally; open safely (PBG → SLF)

Whatever you construct—villas, resort, beach club—PBG replaces the old IMB, and SLF proves your building is fit for use. No soft opens without SLF; insurers and banks increasingly check it.

6) Operate like a grown-up (post-licensing discipline)

◎ LKPM reporting (investment activity) through OSS—quarterly for most PMA companies—keeps you on the right side of the Ministry of Investment; deadlines are actively policed. oss.go.id

◎ Keep taxes, manpower permits (e.g., RPTKA), sector standards, and OSS data current when you add lines of business, expand locations, or change capacity.

7) Respect community & adat from the outset

Not a “permit,” but in Bali it’s a permit-multiplier. Early MOU/engagement with banjar/adat leaders reduces social friction that can otherwise spill into complaints, padlockings, and delays. Build waste, water, access, and noise into design.

A Bali-specific due-diligence checklist

Land & Zoning

➔ Title chain (HGB/HP/Right of Use; avoid SHM workarounds), encumbrances, and zoning matches planned KBLI & use. jdih.baliprov.go.id

Corporate & Capital

➔ PT PMA with correct shareholders, IDR 10B paid-up, board composition, and bankable governance. ABNR – Counsellors at Law

Licensing stack (in order)

KKPR → 2. Environmental (AMDAL/UKL-UPL) → 3) NIB → 4) Risk-based PB/PB-UMKU → 5) PBG → 6) SLF.

Operations

➔ OSS updates on scope/location, LKPM on time, sector standards (tourism), and tax registrations aligned. oss.go.id

Common shortcuts that create big problems

1. Nominee land schemes

Putting freehold (SHM) under an Indonesian “nominee” for a foreign investor is a legal smuggling tactic routinely voided in court and contrary to the Basic Agrarian Law—don’t do it. Use lawful rights (HGB/HP) via PT PMA. Putusan Mahkamah Agung

2. Building in the wrong zone

Green/agricultural areas are tempting—and the fastest path to padlocks and demolition orders. Follow Perda 2/2023 and RDTR layers; let zoning lead your design, not the other way around. jdih.baliprov.go.idtarubali.baliprov.go.id

3. “We’ll fix the paperwork later”

Operating without SLF, skipping environmental approvals, or mis-declaring your KBLI breaks the PP 28/2025 chain and risks immediate enforcement. The regulation also strengthens timelines and fiktif-positif (deemed approval) within the rules, not as a license to skip them.

Why PP 28/2025 actually helps good investors

📌 Single source of truth: PP 28/2025 centralizes the logic in OSS and replaces GR 5/2021, so your roadmap is clearer.

📌 Predictable timelines: Clearer SLAs and deemed-approval guardrails reduce uncertainty for compliant applications.

📌 Sector-by-sector risk clarity: Matching NIB/Standard Certificate/License to risk keeps low-risk projects light and high-risk properly vetted.

Bottom line

If you follow the steps—zoning first, capitalized PT PMA, complete persyaratan dasar, correct risk-based license, PBG→SLF, and disciplined LKPM—you can build and operate in Bali without issues.

PP 28/2025 is designed to reward exactly this behavior. But if you try to circumvent the system—nominee ownership, green-zone builds, no SLF, no LKPM—issues are inevitable: stoppages, fines, project write-downs, and reputational damage. The choice is yours; the path is now codified.

Sources :

1. InsightPlus BakerMcKenzie – Indonesia: The government has finally codified and streamlined the business licensing process and requirements in Indonesia

2. Allen & Gledhill – Indonesia’s GR 28/2025 : Faster Licenses, Clearer Rules for Businesses

3. Bali Provincial Government Legal Documentation and Information Network

4. Status RTRW dan RDTR di Provinsi Bali