Bali PT PMA Restrictions 2026: 18 KBLI and New OSS Applications
What Bali’s Restrictions Mean for New PT PMA Licensing Applications
Before setting up a PT PMA, adding a business activity or committing money to a property in Bali, investors should check whether the proposed activity remains available for new foreign-investment licensing through OSS.
In its announcement published on 24 July 2026, the Bali Provincial Government confirmed restrictions on new PMA licensing applications across 18 KBLI categories classified as low risk or medium-low risk. According to the announcement, the restrictions have applied throughout Bali since the third week of May 2026, following approval from the Ministry of Investment/BKPM.
The affected activities include certain hotel categories, real estate, management consulting, vehicle rental, cafés and other specified businesses. The precise activity and any stated conditions matter: a broad description such as “tourism” or “property business” is not enough to establish whether a particular project is affected.
The announcement concerns access to new business licensing for the designated activities. It does not establish a blanket prohibition on foreign investment in Bali or announce the automatic cancellation of every existing PT PMA licence.
For an investor, the practical distinction is between incorporating a company, obtaining permission for its intended activity and maintaining compliance after operations begin. Before signing a lease, buying property or paying a non-refundable deposit, confirm the licensing route for the actual business and project location.
In its announcement published on 24 July 2026, the Bali Provincial Government confirmed restrictions on new PMA licensing applications across 18 KBLI categories classified as low risk or medium-low risk. According to the announcement, the restrictions have applied throughout Bali since the third week of May 2026, following approval from the Ministry of Investment/BKPM.
The affected activities include certain hotel categories, real estate, management consulting, vehicle rental, cafés and other specified businesses. The precise activity and any stated conditions matter: a broad description such as “tourism” or “property business” is not enough to establish whether a particular project is affected.
The announcement concerns access to new business licensing for the designated activities. It does not establish a blanket prohibition on foreign investment in Bali or announce the automatic cancellation of every existing PT PMA licence.
For an investor, the practical distinction is between incorporating a company, obtaining permission for its intended activity and maintaining compliance after operations begin. Before signing a lease, buying property or paying a non-refundable deposit, confirm the licensing route for the actual business and project location.
Which 18 Business Activities Are Listed in Bali’s Official Announcement?
The Bali Provincial Government lists the following 18 activities in its announcement on restricted PMA access to OSS:
1. Star-rated hotels with a building area below 6,000 square metres.
2. Non-star-rated hotels (hotel melati).
3. Real estate owned or leased.
4. Management consultancy activities.
5. Industrial management consultancy.
6. Rental of cars, buses, trucks and similar vehicles.
7. Motorcycle rental.
8. Clothing retail.
9. Textile retail.
10. Food retail.
11. Mobile retail of agricultural products.
12. Other accommodation.
13. Drinking establishments or cafés.
14. Traditional medicine shops or stalls.
15. Tailoring and made-to-order clothing.
16. Stadium facilities.
17. Fitness centre facilities.
18. Sports event promotion.
These English descriptions follow the activity names in the provincial announcement. The announcement does not provide a corresponding table of five-digit KBLI codes.
For a specific project, the activity description must therefore be checked against the applicable KBLI classification, the project’s risk category and the current OSS licensing requirements. Where KBLI 2025 changes the classification, the correspondence with the earlier code also needs verification.
In particular, broad entries such as “other accommodation” or “real estate owned or leased” should not be treated as a definitive answer for every villa, property rental or development project without checking its actual activity and licensing route.
1. Star-rated hotels with a building area below 6,000 square metres.
2. Non-star-rated hotels (hotel melati).
3. Real estate owned or leased.
4. Management consultancy activities.
5. Industrial management consultancy.
6. Rental of cars, buses, trucks and similar vehicles.
7. Motorcycle rental.
8. Clothing retail.
9. Textile retail.
10. Food retail.
11. Mobile retail of agricultural products.
12. Other accommodation.
13. Drinking establishments or cafés.
14. Traditional medicine shops or stalls.
15. Tailoring and made-to-order clothing.
16. Stadium facilities.
17. Fitness centre facilities.
18. Sports event promotion.
These English descriptions follow the activity names in the provincial announcement. The announcement does not provide a corresponding table of five-digit KBLI codes.
For a specific project, the activity description must therefore be checked against the applicable KBLI classification, the project’s risk category and the current OSS licensing requirements. Where KBLI 2025 changes the classification, the correspondence with the earlier code also needs verification.
In particular, broad entries such as “other accommodation” or “real estate owned or leased” should not be treated as a definitive answer for every villa, property rental or development project without checking its actual activity and licensing route.
Can an Existing PT PMA Continue Operating in an Affected Business Category?
An existing PT PMA should distinguish between continuing an already licensed activity and applying for permission to undertake a new activity or project.
The provincial announcement restricts new PMA licensing applications for the designated categories. It also states that companies already holding licences must continue submitting their investment activity reports (LKPM) and remain subject to enforcement for licensing violations.
This does not amount to automatic cancellation of every existing licence. Equally, the announcement should not be treated as unconditional protection for any business incorporated before the restrictions began.
A review of an existing company should establish:
The company’s incorporation date alone does not answer these questions. A company may have existed for years while a particular activity, location or licensing application remains incomplete.
Before expanding, adding a location or changing an affected activity, the company should confirm how OSS and the competent authority will process that specific application. The provincial announcement does not provide a comprehensive procedure for every type of amendment.
For an existing operator, the practical approach is to review the issued licences and actual operations first, then assess the proposed change separately.
The provincial announcement restricts new PMA licensing applications for the designated categories. It also states that companies already holding licences must continue submitting their investment activity reports (LKPM) and remain subject to enforcement for licensing violations.
This does not amount to automatic cancellation of every existing licence. Equally, the announcement should not be treated as unconditional protection for any business incorporated before the restrictions began.
A review of an existing company should establish:
- which business activities and project locations are recorded in OSS;
- which licensing documents have actually been issued;
- whether any required approvals or verification steps remain outstanding;
- whether the activity carried out matches the registered activity;
- whether the company has met the conditions attached to its licences;
- whether applicable reporting obligations have been fulfilled.
The company’s incorporation date alone does not answer these questions. A company may have existed for years while a particular activity, location or licensing application remains incomplete.
Before expanding, adding a location or changing an affected activity, the company should confirm how OSS and the competent authority will process that specific application. The provincial announcement does not provide a comprehensive procedure for every type of amendment.
For an existing operator, the practical approach is to review the issued licences and actual operations first, then assess the proposed change separately.
What Should a PT PMA Check Before Changing Its KBLI, Directors or Shareholders?
Adding a business activity, updating a KBLI classification and replacing a director are different corporate actions. They should not automatically be treated as the same type of application under Bali’s restrictions.
Before making changes, the company should identify exactly what is being amended and whether the change also requires a new business licensing application.
Adding or replacing a business activity
If the company proposes to add an affected activity, it should confirm whether a new licensing application is available through OSS for that activity and project location. The fact that the company already holds an NIB should not be treated as confirmation that the additional activity can be licensed.
Updating an existing KBLI classification
A classification update should accurately reflect the business actually carried out. Where an update involves a different activity description, risk category or licensing requirement, the company should verify how its existing records and approvals will be treated.
Selecting a different code merely because it appears available in OSS can create a mismatch between the registered activity and actual operations.
Changing directors or commissioners
The provincial announcement does not expressly impose a blanket prohibition on changes to directors or commissioners. However, it also does not explain how every related AHU or OSS update will be processed. The company should identify which records require amendment and whether the planned filing includes any separate change to business activities or licensing.
Changing shareholders
A shareholder transaction requires its own review, particularly if it changes the company’s investment status. The parties should confirm the implications for the company’s activities and licences before signing binding transfer documents or paying the purchase price.
For each proposed change, prepare a clear comparison of the current records, the intended amendment and the filings required. Where treatment is unclear, seek confirmation from the competent authority before proceeding.
For a closer look at classification changes and consistency between company records, see our guide to KBLI 2025 for existing PT PMA companies and the checks to make in AHU and OSS.
Before making changes, the company should identify exactly what is being amended and whether the change also requires a new business licensing application.
Adding or replacing a business activity
If the company proposes to add an affected activity, it should confirm whether a new licensing application is available through OSS for that activity and project location. The fact that the company already holds an NIB should not be treated as confirmation that the additional activity can be licensed.
Updating an existing KBLI classification
A classification update should accurately reflect the business actually carried out. Where an update involves a different activity description, risk category or licensing requirement, the company should verify how its existing records and approvals will be treated.
Selecting a different code merely because it appears available in OSS can create a mismatch between the registered activity and actual operations.
Changing directors or commissioners
The provincial announcement does not expressly impose a blanket prohibition on changes to directors or commissioners. However, it also does not explain how every related AHU or OSS update will be processed. The company should identify which records require amendment and whether the planned filing includes any separate change to business activities or licensing.
Changing shareholders
A shareholder transaction requires its own review, particularly if it changes the company’s investment status. The parties should confirm the implications for the company’s activities and licences before signing binding transfer documents or paying the purchase price.
For each proposed change, prepare a clear comparison of the current records, the intended amendment and the filings required. Where treatment is unclear, seek confirmation from the competent authority before proceeding.
For a closer look at classification changes and consistency between company records, see our guide to KBLI 2025 for existing PT PMA companies and the checks to make in AHU and OSS.
What Should Investors Check Before Leasing or Buying Property in Bali?
Before committing to property for a business project, investors should establish whether the intended operator can obtain the licences required for the proposed activity at that location.
A seller or landlord may provide land documents, building approvals or details of an existing business licence. Each document should be reviewed for what it actually covers. Do not assume that it confirms the licensing position of a different company, a new project or a changed use.
As a practical due diligence step, establish:
The transaction documents should address these uncertainties before substantial payments become due.
Depending on the deal, the parties can negotiate a due diligence period, conditions that must be satisfied before completion, staged payments, and a defined refund or termination mechanism if a specified approval cannot be obtained. The agreement should identify the required evidence, the responsible party and the deadline for satisfying each condition.
If the property has already been leased or purchased, review the existing contract alongside the licensing position. Check any statements about permitted use, cooperation with applications, payment obligations and termination rights. Do not assume that a licensing obstacle automatically creates a right to cancel the transaction or recover money.
For villa projects involving an operating company, the review should also examine the operator’s actual responsibilities, its licensing position and the agreement with the property owner. A proposed operating arrangement should be assessed on its substance before it is relied upon.
For the property checks that should accompany this licensing review, see our guide to property due diligence in Bali before signing a lease or purchase agreement.
A seller or landlord may provide land documents, building approvals or details of an existing business licence. Each document should be reviewed for what it actually covers. Do not assume that it confirms the licensing position of a different company, a new project or a changed use.
As a practical due diligence step, establish:
- who will operate the business and apply for the relevant licences;
- which KBLI classification accurately describes the intended activity;
- whether that activity falls within the announced restrictions;
- whether the project involves an existing issued licence or a new application;
- whether the proposed use is compatible with the property’s zoning and building documentation;
- which approvals remain outstanding;
- what happens financially if the intended licensing route is unavailable.
The transaction documents should address these uncertainties before substantial payments become due.
Depending on the deal, the parties can negotiate a due diligence period, conditions that must be satisfied before completion, staged payments, and a defined refund or termination mechanism if a specified approval cannot be obtained. The agreement should identify the required evidence, the responsible party and the deadline for satisfying each condition.
If the property has already been leased or purchased, review the existing contract alongside the licensing position. Check any statements about permitted use, cooperation with applications, payment obligations and termination rights. Do not assume that a licensing obstacle automatically creates a right to cancel the transaction or recover money.
For villa projects involving an operating company, the review should also examine the operator’s actual responsibilities, its licensing position and the agreement with the property owner. A proposed operating arrangement should be assessed on its substance before it is relied upon.
For the property checks that should accompany this licensing review, see our guide to property due diligence in Bali before signing a lease or purchase agreement.
What Should You Do if OSS Does Not Accept Your Application?
If OSS does not accept an application, first identify the exact message and the stage at which the process stops. A blocked submission, an incomplete application and a request for additional verification may require different responses.
Do not assume that every unsuccessful submission is caused by Bali’s restrictions on the 18 business categories.
Keep a record of:
Use this information to ask OSS support or the competent licensing authority whether the issue concerns the restriction, inconsistent company data, an outstanding requirement or a technical problem.
Where the response refers to a restricted activity, ask whether it applies to the particular application being made: a new project, an additional location, an amendment or the completion of an earlier submission. Retain any written response with the company’s licensing records.
Avoid changing the activity code solely to make the application proceed. The selected classification should describe the business that will actually operate. Likewise, a different registered address should not be treated as a solution without checking the requirements for the actual project location.
If licensing remains unresolved, review any approaching contractual deadlines before making further commitments. A pending OSS application should not be presented to a landlord, seller, investor or customer as an issued licence.
The objective is to establish a documented route for the proposed activity, including any outstanding requirements, before relying on the application in a commercial decision.
Do not assume that every unsuccessful submission is caused by Bali’s restrictions on the 18 business categories.
Keep a record of:
- the full message displayed by OSS;
- the application or project reference number;
- the selected KBLI code and activity description;
- the project location;
- the company’s investment status;
- the application type and submission date;
- any documents or approvals already issued.
Use this information to ask OSS support or the competent licensing authority whether the issue concerns the restriction, inconsistent company data, an outstanding requirement or a technical problem.
Where the response refers to a restricted activity, ask whether it applies to the particular application being made: a new project, an additional location, an amendment or the completion of an earlier submission. Retain any written response with the company’s licensing records.
Avoid changing the activity code solely to make the application proceed. The selected classification should describe the business that will actually operate. Likewise, a different registered address should not be treated as a solution without checking the requirements for the actual project location.
If licensing remains unresolved, review any approaching contractual deadlines before making further commitments. A pending OSS application should not be presented to a landlord, seller, investor or customer as an issued licence.
The objective is to establish a documented route for the proposed activity, including any outstanding requirements, before relying on the application in a commercial decision.
A Practical Checklist Before Your Next PT PMA Commitment
Before incorporating a company, changing its activities or committing money to a Bali project, bring the commercial plan and licensing documents together in one review.
1. Define the actual business activity
Describe what the business will do, who its customers will be and how it will earn revenue. Use that description to verify the appropriate KBLI classification.
2. Check the project location and restriction
Compare the proposed activity with the categories in Bali’s official announcement. Verify any relevant conditions, risk classification and current treatment of the application through OSS.
3. Separate existing approvals from new applications
Identify which licences have already been issued, what they cover and which approvals are still needed. Treat proposed additions or changes as separate questions requiring verification.
4. Review the company’s records
Compare the relevant corporate documents, AHU records and OSS project data. Identify inconsistencies and outstanding compliance matters before submitting changes.
5. Protect the financial commitment
Review deposits, payment deadlines and completion obligations. Where licensing remains uncertain, negotiate clear conditions, evidence requirements and consequences if an essential approval cannot be obtained.
6. Keep evidence of the licensing route
Retain issued documents, application records and written responses from the competent authorities. Record unresolved questions, who will address them and when a decision is needed.
This checklist is a practical review framework. It does not replace the requirements applicable to a particular activity or establish that a project is eligible for approval.
1. Define the actual business activity
Describe what the business will do, who its customers will be and how it will earn revenue. Use that description to verify the appropriate KBLI classification.
2. Check the project location and restriction
Compare the proposed activity with the categories in Bali’s official announcement. Verify any relevant conditions, risk classification and current treatment of the application through OSS.
3. Separate existing approvals from new applications
Identify which licences have already been issued, what they cover and which approvals are still needed. Treat proposed additions or changes as separate questions requiring verification.
4. Review the company’s records
Compare the relevant corporate documents, AHU records and OSS project data. Identify inconsistencies and outstanding compliance matters before submitting changes.
5. Protect the financial commitment
Review deposits, payment deadlines and completion obligations. Where licensing remains uncertain, negotiate clear conditions, evidence requirements and consequences if an essential approval cannot be obtained.
6. Keep evidence of the licensing route
Retain issued documents, application records and written responses from the competent authorities. Record unresolved questions, who will address them and when a decision is needed.
This checklist is a practical review framework. It does not replace the requirements applicable to a particular activity or establish that a project is eligible for approval.
Frequently Asked Questions
Has Bali banned all new PT PMA companies?
No. The provincial announcement concerns restrictions on new PMA business licensing applications through OSS for 18 specified KBLI categories. It does not announce a blanket ban on incorporating foreign-investment companies or on all foreign investment in Bali. Investors should verify whether their intended activity and project location have an available licensing route.
When did the restrictions on the 18 KBLI categories begin?
According to the Bali Provincial Government’s announcement published on 24 July 2026, the restrictions have applied throughout Bali since the third week of May 2026. The publication date should therefore be distinguished from the stated start of implementation.
Do the restrictions automatically cancel existing PT PMA licences?
The announcement does not state that all existing licences in the affected categories are automatically cancelled. It confirms that companies already holding licences must continue fulfilling applicable LKPM reporting obligations and remain subject to enforcement for licensing violations. Existing operators should review the scope and conditions of their issued licences before relying on them for continued operations or expansion.
Can an existing PT PMA add one of the restricted activities?
An existing company should not assume that its incorporation or NIB allows it to obtain a new licence for a restricted activity. The company should confirm how the proposed addition will be processed through OSS for the relevant project location. The provincial announcement does not provide a complete procedure for every type of amendment.
Do the restrictions prevent changes to directors or shareholders?
The provincial announcement does not expressly impose a blanket prohibition on changes to directors or shareholders. Each transaction should nevertheless be reviewed to determine which corporate and licensing records require amendment, whether the company’s investment status changes and whether any new business licensing application is involved.
Are all villa businesses covered by the restrictions?
The official list includes certain hotel activities, other accommodation and real estate owned or leased. These descriptions alone do not establish the position of every villa project. The actual operating activity, applicable KBLI classification, risk category, location and existing licences should be checked before drawing a conclusion.
Can a different KBLI code be used if OSS rejects the application?
A different code should be selected only where it accurately describes the actual business activity. Changing the code solely to make an application proceed can create inconsistencies between company records and operations. First establish why OSS is not accepting the application and seek clarification of the appropriate classification and licensing route.
Does signing a property lease or purchase agreement guarantee business licensing?
No. A property agreement should not be treated as confirmation that the intended operator can obtain the required business licences. Before committing funds, verify the proposed activity, project location and licensing position. Where approvals remain uncertain, consider negotiating conditions, payment stages and clear consequences if an essential approval cannot be obtained.
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Planning a New Business or a Change to Your PT PMA in Bali?
Before committing to a property, adding a business activity or submitting an OSS application, clarify how Bali’s restrictions may affect your proposed project.
Business Consulting Bali can help review your intended activities, company records, existing licences and contractual commitments, identify questions requiring confirmation with the relevant authorities, and determine the next practical steps.
Send us a short description of your project, its location and whether you already have a PT PMA and issued business licences. We can then discuss the scope of an initial review.
Business Consulting Bali can help review your intended activities, company records, existing licences and contractual commitments, identify questions requiring confirmation with the relevant authorities, and determine the next practical steps.
Send us a short description of your project, its location and whether you already have a PT PMA and issued business licences. We can then discuss the scope of an initial review.
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