What Foreign Investors Need to Know Before Investing in Bali in 2026
Bali remains one of Indonesia’s most attractive destinations for foreign investment.
However, the regulatory environment for foreign-owned businesses in Bali is changing.
In 2026, the Government of Bali introduced a policy restricting access to Indonesia’s Online Single Submission (OSS) system for foreign-owned companies (PMA) seeking to operate in 18 selected business activities.
This is an important development for anyone planning to establish a PT PMA in Bali.
The key message for investors is simple:
Do not establish a PT PMA first and check the business restrictions later.
Your proposed business activity, KBLI, ownership structure, location, licensing requirements and investment structure should be reviewed before incorporation and investment.
WHAT HAS CHANGED IN BALI?
In July 2026, the Bali Provincial Government announced that access to the OSS system had been restricted for PMA in a number of business activities.
According to the Bali Provincial Government, the policy followed an evaluation of business licensing practices and was implemented after approval from the Minister of Investment and Hilirisation/Head of BKPM.
The restriction applies throughout Bali and has been in effect since the third week of May 2026.
The government explained that the policy was introduced after identifying indications that some PMA businesses were entering sectors traditionally occupied by local micro, small and medium enterprises (MSMEs), including through the use of low-risk business classifications and OSS registration mechanisms.
The government also highlighted concerns involving inappropriate use of KBLI classifications, virtual offices and businesses operating without the required underlying approvals.
THE 18 BUSINESS ACTIVITIES AFFECTED
The Bali Provincial Government identified 18 business activities for which OSS access for PMA has been restricted.
They include:
- Star-rated hotels with building area below 6,000 m²
- Non-star hotels / budget hotels
- Real estate owned or leased
- Other management consultancy activities
- Industrial management consultancy
- Rental of cars, buses, trucks and similar vehicles
- Clothing retail
- Textile retail
- Other food retail
- Mobile retail of agricultural food products
- Other accommodation
- Drinking houses / cafés
- Traditional medicine shops / outlets
- Tailoring and made-to-order clothing
- Stadium facilities
- Fitness centres
- Sports event promoters
- Motorcycle rental
The official announcement describes these as business activities where PMA access through OSS has been closed/restricted.
Important:
This list should not automatically be interpreted as a blanket statement that every existing foreign-owned business in these sectors is illegal.
The government has specifically stated that businesses that already hold licences remain subject to their existing obligations, including LKPM reporting. The practical situation therefore needs to be distinguished between:
NEW PMA APPLICATION
and
EXISTING PMA WITH VALID LICENCES
That distinction is critical for investors.
WHY DID BALI INTRODUCE THIS POLICY?
The policy should be understood in the broader context of Bali’s investment and licensing supervision.
According to BKPM, Bali recorded 19,262 PMA business actors and 55,458 projects during 2021–2025.
BKPM also reported that 47.55% of those projects were classified as low risk, meaning they generally did not require a standard certificate or additional licence under the applicable risk-based licensing framework.
The Bali Government had raised concerns that certain PMA businesses were using low-risk KBLI classifications to enter sectors traditionally dominated by local businesses.
The government specifically highlighted issues involving:
- inappropriate KBLI classification;
- PMA entering sectors considered appropriate for local MSMEs;
- use of virtual offices;
- businesses operating without appropriate underlying approvals;
- insufficient investment requirements;
- nominee arrangements;
- location and spatial-planning issues.
BKPM reported that during its 2025 supervision activities in Bali, 426 business actors were identified with indications of licensing violations and 423 were subjected to administrative sanctions.
This demonstrates that the 18-KBLI restriction is not an isolated policy. It forms part of a broader move toward more intensive investment supervision in Bali.
THIS IS NOT SIMPLY A “FOREIGNERS ARE BANNED” POLICY
Foreign investors should be careful with headlines suggesting that Bali has simply “banned foreigners from doing business.”
That description is too broad.
The official Bali Government announcement frames the policy as a restriction of OSS access for PMA in specified business activities.
At the same time, the government stated that Bali remains open to investment that is considered responsible, compliant and beneficial to the local economy.
Therefore, the more useful question for an investor is not:
“Can foreigners invest in Bali?”
The practical question is:
“Can my specific business model legally be operated by a PMA in Bali under the current regulatory framework?”
That question requires a much more detailed analysis.
WHY THIS MATTERS TO FOREIGN INVESTORS
1. YOUR BUSINESS IDEA MAY NOT BE THE SAME AS YOUR KBLI
One of the most important issues is the relationship between:
Business Model → Actual Activities → KBLI → PMA Eligibility → Licensing
A company cannot safely select a KBLI simply because the description appears similar to its intended business.
For example, an investor may describe a business as:
“Lifestyle consulting”
while the actual business may involve:
- management consultancy;
- property management;
- tourism services;
- accommodation;
- rental services;
- wellness services;
- retail;
- online sales.
Each activity may have a different regulatory treatment.
Therefore, the KBLI must reflect the actual substance of the business.
2. A PT PMA INCORPORATION DOES NOT MEAN THE BUSINESS IS AUTOMATICALLY READY TO OPERATE
This is one of the most important concepts for foreign investors in Indonesia.
There are several different stages:
Company Establishment
↓
Business Activity / KBLI
↓
PMA Eligibility
↓
Location & Spatial Requirements
↓
Basic Requirements
↓
Business Licensing
↓
Operational Requirements
↓
Commercial Operation
A PT PMA can be legally incorporated while the proposed business activity still faces licensing or location restrictions.
Therefore:
A company being established does not automatically mean that the proposed business can operate.
3. EXISTING PMA AND NEW PMA MUST BE ANALYSED DIFFERENTLY
This is particularly important for the 18 restricted activities.
Existing PMA
If a company already has valid business licences, the Bali Government has stated that the existing licence remains subject to its applicable obligations.
Existing companies must continue to comply with requirements such as LKPM reporting.
However, investors should not assume that an existing licence automatically gives unlimited rights to:
- expand;
- add new KBLI;
- change business activities;
- open new locations;
- restructure the business;
- add new projects.
Those actions may trigger a fresh regulatory review.
New PMA
For a new foreign investor, the situation is different.
If the proposed activity falls within the restricted categories, the investor should not assume that the normal OSS registration process will be available.
The restriction therefore needs to be checked before:
- paying for a property;
- signing a long-term lease;
- establishing a company;
- transferring investment funds;
- hiring employees;
- purchasing equipment;
- committing to a franchise;
- or launching the business.
4. VIRTUAL OFFICE HAS BECOME A MAJOR RISK AREA
The Bali Government has also focused on the use of virtual offices by PMA.
Earlier in 2026, the Governor of Bali sent a letter requesting the closure of PMA activities at low and medium-low risk levels and PMA operating through virtual offices in Bali.
The letter dated 28 January 2026, Number B.27.000/642/PM/DPMPTSP, referred to the large number of PMA projects in Bali and raised concerns regarding the use of low-risk classifications and virtual offices.
This means investors should not treat a virtual office simply as an inexpensive solution for establishing a PMA.
The critical question is:
Does the actual business activity legally permit the proposed location arrangement?
For businesses requiring a physical operating location, a virtual office cannot automatically substitute for the actual premises and related requirements.
5. THE NEW KBLI 2025 TRANSITION MAKES THE ANALYSIS EVEN MORE IMPORTANT
Another major development in 2026 is the implementation of KBLI 2025.
The Government issued a Joint Circular Letter concerning the implementation of KBLI 2025 in the risk-based business licensing system.
According to BKPM, licences issued before KBLI 2025 remain valid.
Where only the numerical code changes but the substance of the business does not change, the adjustment can be handled through the system.
However, where there is a substantive change in the business activity, further adjustment may be required.
This is particularly relevant to Bali investors because several business classifications have changed or been restructured under KBLI 2025.
Therefore, investors should not rely only on an old KBLI number from:
- an old company deed;
- an old NIB;
- an old consultant’s document;
- a previous investment structure;
- or a previous business proposal.
The current KBLI and its regulatory treatment should be verified.
THE BIGGEST MISTAKE: “JUST FIND ANOTHER KBLI”
When investors discover that their intended KBLI is restricted, a common reaction is:
“Can we just use another KBLI?”
This can create a much bigger compliance problem.
A KBLI should not be selected merely because it makes the licensing process easier.
The correct approach is:
Actual Business Model
↓
Identify Actual Business Activities
↓
Identify Appropriate KBLI
↓
Check PMA Eligibility
↓
Check Current Bali Restrictions
↓
Check Location
↓
Check Licensing
↓
Check Operational Requirements
If the proposed activity is not available to PMA, changing the KBLI on paper without changing the substance of the business does not solve the underlying issue.
WHAT ABOUT HOTEL, VILLA AND ACCOMMODATION INVESTORS?
This is one of the areas that deserves special attention.
The 18 restricted categories include several accommodation-related activities.
At the same time, Bali’s regulatory environment has become increasingly focused on:
- land use;
- spatial planning;
- accommodation classification;
- building approvals;
- environmental requirements;
- tourism licensing;
- actual business activity;
- PMA eligibility;
- and compliance between the registered business and the activity actually conducted.
For an investor planning a villa, hotel, guesthouse or other accommodation business, the correct sequence is therefore not:
Find land → establish PT PMA → register KBLI
A safer sequence is:
Business concept → regulatory feasibility → location → KBLI → PMA structure → licensing → investment
This can prevent an investor from committing substantial capital before discovering that the intended project cannot be licensed as planned.
WHAT ABOUT CAFÉS AND RESTAURANTS?
The restrictions also include drinking houses / cafés.
Therefore, a foreign investor planning a café business should not assume that simply establishing a PT PMA and registering a restaurant-related business activity will automatically result in an operationally valid business.
The investor should verify:
- current KBLI classification;
- PMA eligibility;
- OSS availability;
- location;
- building requirements;
- environmental requirements;
- food and beverage requirements;
- tourism/business licensing requirements;
- investment requirements;
- and any Bali-specific restrictions.
The precise business model matters.
A café inside a hotel, a standalone café, a restaurant, a food manufacturing operation and a retail food business are not necessarily regulated in the same way.
WHAT ABOUT MOTORCYCLE RENTAL?
Motorcycle rental has become one of the clearest examples of the policy.
The Bali Government specifically included motorcycle rental among the restricted PMA activities.
Local officials also reported that OSS data showed approximately 150 licensed PMA motorcycle-rental businesses, while field checks in tourist areas such as Canggu and Kuta identified more than 500 PMA motorcycle-rental operations.
For a foreign investor considering this sector, this means the issue is no longer simply whether the business can obtain an NIB.
The investor must consider whether the activity is currently available to PMA in Bali.
WHAT DOES THIS MEAN FOR INVESTMENT PLANNING?
For foreign investors, the most important change is a shift in the way a PMA project should be evaluated.
Previously, investors might ask:
“What KBLI should I use?”
The better question is:
“Is my entire business model legally and commercially compatible with the current PMA framework in Bali?”
That requires reviewing at least eight elements:
01 — OWNERSHIP
Who will own the company?
02 — BUSINESS MODEL
What will the company actually do?
03 — KBLI
Which current KBLI accurately describes the actual activity?
04 — PMA ELIGIBILITY
Is the activity available to foreign investment under the current rules?
05 — LOCATION
Can the business legally operate at the proposed location?
06 — LICENSING
What licences and approvals are required?
07 — CAPITAL & INVESTMENT
Does the investment structure satisfy the applicable PMA requirements?
08 — COMPLIANCE
Can the company continuously comply with LKPM, tax, corporate, licensing and operational obligations?
WHAT SHOULD AN INVESTOR DO BEFORE ESTABLISHING A PT PMA?
We recommend conducting a Pre-Investment Regulatory Check before committing significant capital.
The review should cover:
BUSINESS ACTIVITY
What will you actually sell or provide?
KBLI
Does the current KBLI accurately represent your business?
PMA ACCESS
Is the activity available to foreign investment?
BALI RESTRICTIONS
Is the activity included in a current Bali restriction or OSS access limitation?
LOCATION
Can the proposed business legally operate at the proposed address?
BASIC REQUIREMENTS
Are spatial, environmental and building requirements satisfied?
INVESTMENT
Does the proposed investment structure satisfy the applicable requirements?
LICENSING
What licences and certifications will be required?
OPERATIONS
Can the business legally commence commercial operations?
ONGOING COMPLIANCE
What reporting and compliance obligations will continue after establishment?
THE PmaDoctor APPROACH
At PmaDoctor, we believe that foreign investors should not start with paperwork.
They should start with diagnosis.
Our approach is:
DIAGNOSE
Understand the business model and identify regulatory issues.
STRUCTURE
Build the appropriate company, ownership and business structure.
LICENSE
Identify the correct KBLI, location and licensing requirements.
COMPLY
Maintain corporate, tax, investment and operational compliance.
GROW
Build the business on a structure that can support future development.
This is the philosophy behind the PmaDoctor PMA Health Check.
PMA HEALTH CHECK FOR BALI INVESTORS
If you already operate a PT PMA in Bali, a regulatory review can examine:
OWNERSHIP
↓
BUSINESS ACTIVITY
↓
KBLI
↓
LOCATION
↓
LICENSING
↓
TAX
↓
LKPM
↓
CORPORATE DOCUMENTS
↓
OPERATIONS
The objective is not to create unnecessary concern.
The objective is to identify issues before they become expensive problems.
FINAL MESSAGE FOR FOREIGN INVESTORS
The Bali investment environment is not closed to foreign investment.
But the regulatory approach is becoming more selective and more closely supervised.
The 18-KBLI restriction demonstrates an important change:
Having a PT PMA and an NIB is not the same as having a fully compliant business.
Foreign investors should therefore evaluate the entire investment structure before committing capital.
The most important question is no longer:
“Can I establish a company in Bali?”
It is:
“Can my specific business legally operate in Bali through a PT PMA under the rules that apply today?”
That answer depends on the business activity, KBLI, PMA eligibility, location, licensing, investment structure and current regulatory restrictions.
For investors entering Bali in 2026, regulatory due diligence should come before investment commitment.
NEED TO KNOW WHETHER YOUR BUSINESS IS ELIGIBLE?
DON’T ESTABLISH FIRST. DIAGNOSE FIRST.
PmaDoctor helps foreign investors and PT PMA owners review:
PMA Setup • KBLI • Licensing • Location • Compliance • LKPM • Business Structure
BOOK A PMA HEALTH CHECK
Your Business. Your Compliance. Your Peace of Mind.
Diagnose Before You Invest.
Structure Before You Operate.
Comply Before You Grow.
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