Legally in Force — But Not Yet Fully Licensable?
What Bali Investors Must Understand Before Building Villas, Glamping Sites, or Serviced Apartments
Indonesia’s tourism accommodation sector has entered a technical transition phase that is already affecting how villa projects, eco-retreats, serviced apartments, and glamping developments are licensed across Bali.
Under BPS Regulation No. 7 of 2025, the Government of Indonesia has formally introduced an updated Indonesian Standard Industrial Classification (KBLI 2025/2026), which now includes specific accommodation activity codes such as:
▪ KBLI 55203 – Villa Activity
▪ KBLI 55106 – Non-Star Hotel
▪ KBLI 55204 – Serviced Apartment
▪ KBLI 55209 – Glamping
▪ KBLI 55202 – Youth Hostel
▪ KBLI 55400 – Property Management
These classifications are now legally binding and must be adopted by all business actors and regulators within six months of promulgation.
However, there is an important operational distinction investors must understand: These new accommodation KBLI codes are legally valid — but their full integration into Indonesia’s OSS Risk-Based Licensing System (OSS-RBA) is still ongoing.
A Classification Exists
But Licensing Must Still Be Mapped. Indonesia’s Risk-Based Business Licensing regime, implemented through Government Regulation No. 28 of 2025, requires all tourism accommodation activities to be licensed through the OSS-RBA platform based on:
▪ Risk classification
▪ Business scale
▪ Activity-specific technical standards
While KBLI 2025/2026 defines the type of tourism business statistically, licensing requires that each activity be:
1. Assigned a risk level
2. Linked to the relevant permit structure
3. Mapped into sectoral business standards
4. Technically integrated into OSS workflows
This mapping is carried out through Ministerial Regulations in the tourism sector — not through Presidential Decree — and is currently in progress.
As a result: Many newly introduced accommodation activities now exist in law, but do not yet appear as selectable licensing pathways within OSS-RBA.
What Happens in Practice?
In the absence of finalized OSS integration, business actors applying for licensing today may be:
▪ Assigned to legacy or general accommodation KBLI clusters
▪ Directed toward the “nearest available” tourism activity code
▪ Issued NIBs or Standard Certificates under temporary mappings
This can create a situation where:
✔️ The business appears licensed in OSS
✔️ A valid KBLI has been selected
✔️ A Standard Certificate has been auto-issued
But:
❌ The actual operational activity (e.g. villa rental or glamping) does not yet correspond to the finalized risk classification or tourism business standards expected under PP 28/2025.
This becomes particularly relevant during:
▪ Operational permit verification
▪ Tourism business standard audits
▪ TDUP issuance
▪ Environmental approvals
▪ License renewals
▪ OSS interoperability checks across AHU, taxation, PBG, or SLF systems
In such cases, licensing obtained under temporary or approximate mappings may be subject to:
▪ Reclassification
▪ Standardization requirements
▪ Technical verification
▪ Or administrative sanctions
once final ministerial mapping is implemented.
Bali Adds an Additional Layer: Spatial Planning
Even where OSS licensing is granted, tourism accommodation activities must still comply with:
▪ KKPR (Spatial Utilization Activity Conformity)
▪ RDTR zoning regulations
▪ Tourism designation requirements
▪ Local infrastructure approvals
▪ Environmental impact controls
This means that a project may hold:
▪ A valid KBLI
▪ An active OSS-issued NIB
… and still be denied operational feasibility if zoning alignment cannot be verified at the regency level.
Across Bali, this has already begun to affect:
▪ Villa clusters in residential zones
▪ Glamping sites near LP2B-protected land
▪ Serviced apartments in mixed-use areas
▪ Eco-retreats located in plantation or conservation buffers
This spatial filter will likely impact nature-based accommodation formats most strongly — including the medium to high-end eco-resort segment currently in highest investor demand.
A Market Dividing Line Is Emerging
As OSS-RBA integration progresses under PP 28 of 2025, the accommodation market is likely to separate into two distinct operator categories:
Structurally Prepared Projects
▪ KBLI aligned with updated classifications
▪ Zoning verified through KKPR prior to development
▪ Operational structure matched to business activity
▪ Future-proofed against OSS remapping or audits
Legacy-Mapped Projects
▪ Licensed under temporary or general accommodation codes
▪ Dependent on auto-issued Standard Certificates
▪ At risk during enforcement or licensing renewal
▪ Potentially subject to reclassification upon verification
As OSS interoperability expands, inconsistencies between declared activity and actual use may be detected automatically through cross-system integration.
Advisory Note
The current transition is not a legal vacuum, but a period of technical and normative alignment between:
▪ Statistical classification (KBLI 2025/2026)
▪ Risk-based licensing (PP 28/2025)
▪ Tourism business standards
▪ And OSS implementation
In this environment:
The primary licensing risk is not operating without a KBLI — but operating under one that does not yet correspond to your intended tourism activity. Projects initiated today under temporary mappings may require adjustment once final sectoral standards are implemented.
How Seven Stones Can Assist
Seven Stones Indonesia provides advisory support for:
▪ KBLI alignment under the 2025/2026 classification
▪ OSS-RBA activity mapping
▪ KKPR and spatial conformity checks
▪ Tourism business standard compliance
▪ Licensing pathway strategy for accommodation operators
Each project must be evaluated individually to ensure that statistical classification, zoning, and licensing structure
are aligned prior to development.
Seven Stones Indonesia
Bringing Structure to Bali’s Evolving Accommodation Market