Before your next off-plan payment in Bali

Before you pay

Before releasing the next material payment on an off-plan project, you should be able to answer eight separate questions:

What transaction are you entering? A house sale/PPJB, ordinary contractual lease, assignment of an existing lease, land lease plus construction, development-service contract, share deal or unresolved hybrid? If tourist accommodation is intended, assess the operating business separately; it does not change the legal form of the underlying property transaction.
Who owes you each promise? The landholder, developer, seller/lessor, contractor, operator and agent may be different parties.
Does the promised site exist on the same land file? Rights, boundaries, access, authority and encumbrances must reconcile.
Can the specific project be designed, built and used as planned and modelled? Spatial, environmental, PBG/SLF and operating questions are different gates.
What exactly must be delivered? Approved drawings, specifications, programme, furniture, utilities, commissioning and opening documents need a controlled baseline.
What evidence makes the next instalment due? A date on a calendar is not evidence that the corresponding work exists and conforms.
What happens when the project changes or slips? Variations, extensions of time, retention, defects, suspension, termination and refund mechanics must work before a dispute.
What will you control at handover and exit? The secure term, asset/right, warranties, operating route and transfer rights must match the financial model.

The conclusion should not be “safe to buy”. It should be a dated list called:

Documents, confirmations and decisions required before your next payment.

First, identify the transaction

“Off-plan leasehold villa” describes a commercial story. It does not, by itself, identify the legal transaction.

The same phrase may be used for very different structures:

Possible structure	What the investor may receive	First professional question
Sale of a house/unit through a housing PPJB route	A future transfer or sale instrument for a qualifying house/unit	Does the housing and PPJB framework apply to this project and transaction?
Ordinary contractual lease	Contract rights granted by a lessor for a defined property and term	Does the lessor control the underlying land/right and have authority to grant the promised use and full term?
Assignment of an existing lease	The assignor's existing lease rights, subject to the original lease and any required consent	Is the lease valid, what remains of its term, is it assignable and has every required consent been obtained?
Land lease plus construction contract	A lease right plus a separately procured building	Who owns the work as it is built, who carries construction risk and what happens at lease end?
Development-service agreement	A promise to design/build/deliver for the investor	Is the scope a construction/development service rather than a property sale, and what licences and security apply?
Share acquisition	Shares in a project company	What assets, liabilities, licences, contracts and related-party balances sit inside that company?
Hybrid	Several of the above	Do all documents describe the same economics, dates, parties and remedies?
Connected tourist-accommodation layer	A proposed operating use attached to one of the primary routes above	Who is the operator, what authorises the location and activity, and who receives guest revenue and bears operating/tax obligations?

Indonesia has specific housing-development and PPJB rules. They matter when their scope applies. They must not be pasted automatically onto every Bali villa marketed as “leasehold”. A contractual label does not decide this question; counsel must test the substance, asset, parties and intended transfer.

Where the housing rules in PP 12/2021 apply, they provide three separate protections that should not be blended together. First, the buyer must have at least seven business days to study the preliminary sale and purchase agreement (PPJB) before signing it as a notarial deed. Second, the PPJB stage depends on specified conditions, including land status, the agreed subject matter, the building approval (PBG), planned infrastructure and construction progress. For detached or row houses, the 20% construction test concerns at least 20% of all planned units and the availability of the planned infrastructure, facilities and utilities. For an apartment building, it concerns 20% of the building's construction volume. It is not 20% of the buyer's individual villa and it is not a universal payment milestone. Third, the developer may not collect more than 80% before the relevant PPJB conditions are satisfied. That separate 80% limit is not a statutory escrow account. Indonesian transaction counsel should confirm that this housing regime applies to the exact product and contract before any of these thresholds is used.

Documents that answer different questions

What you are shown	What it may establish	What it does not establish
Architectural render	Design intention	Land authority, approval, buildability, specification or completion
Land certificate scan	A document to verify	That your counterparty controls it, that the plotted site matches it, or that your transaction is registrable/enforceable
Company deed or NIB	A company/registration starting point	That this company owns the land, is your seller, holds every project permission or can perform every promised activity
Developer registration result	A regulatory data point within its applicable system	A universal government whitelist, project guarantee or substitute for project due diligence
PBG	An approved building plan/function within its exact file	Construction completion, conformity of the as-built work or fitness for use
SLF	A fitness-for-use result for the building/function in its file	Title, seller authority, tourism licence or investment performance
Site photograph	Visible activity on a date	Percentage completion, concealed-work quality, title, approval or contractual compliance
“70% complete” message	A claim	The measurement method, approved baseline, quality, stored materials or cost to complete
Guaranteed yield	A payment promise of some kind	That the payer is solvent, the formula is gross/net, or the promise is secured and enforceable
Completion certificate	A document with a defined issuer and scope	Automatic handover, defect closure, SLF, operational readiness or right to withhold no further sums

PBG and SLF are especially easy to collapse into one reassuring word: “permit”. Under Indonesia's building framework they perform different functions. A project still needs an architect/engineer to match the exact approval file to the exact parcel, drawings, built work and intended function.

Eight document sets to request

Transaction: reservation, draft and final agreement, document index and a written explanation of whether the deal is a sale, lease, assignment, construction arrangement, share deal or hybrid.
Parties and authority: current company records, signatory powers, mandates, guarantees and the legal name of every entity that makes or receives a promise.
Land and access: current land or lease evidence, parcel reconciliation, access rights, encumbrances, consents and the full chain supporting the promised term.
Planning and building: zoning or spatial-use evidence, environmental requirements, building approval (PBG), the route to the certificate of proper function (SLF) and written confirmation of who must obtain each document.
Design and budget: signed drawings, specifications, inclusions and exclusions, programme, priced scope, contingency and an updated estimate of the cost still needed to finish.
Payment and progress: complete payment ledger, verified account details, cumulative progress report, photographs tied to dated inspections, approved variations and independent certification where the contract requires it.
Changes, delay and remedies: variation register, delay notices, revised completion date, refund or termination rights, cure periods and the security supporting any advance.
Handover, operation and exit: completion and inspection records, defects list, warranties, operating licences and contracts, guest-payment flow, transfer or extension rights and the documents needed at exit.

The point is not to collect a large folder. It is to obtain the documents that answer the decision due before the next payment.

Decide what must happen before payment

What you have	What it establishes	What to do before payment
No answer yet	No answer or supporting document has been provided	Ask the precise question; do not infer absence, compliance or non-applicability
Statement only	A marketing statement, answer, undated screenshot or self-certified percentage	Ask for the document or measurement that supports it; do not count the point as satisfied
Document mentioned but not provided	A document or check is referred to, but its contents cannot be examined	Obtain the document and have the appropriate professional examine it
Document received but not checked	You have the file, but its issuer, date, relevance and match to the property or entity remain unconfirmed	Ask the appropriate lawyer, architect, engineer, accountant or tax adviser to check it; possession alone proves only that the file was received
Checked for a defined question	A named professional has stated what was checked, for which property or entity, from which source and on what date	Use the conclusion only for the question examined; do not describe it as an independent verification
Independently checked	A suitably independent second check supports that defined conclusion	Continue with the remaining contract, technical, payment and dependency checks
Contradiction	Documents, parties, parcel details, promises or public records conflict	Identify who must resolve it, what evidence is required and by when; pause the affected payment or decision
Out of date	The document or professional conclusion is no longer current on the decision date	Obtain an updated document or confirmation before relying on it
Unavailable	A required item cannot presently be obtained	Keep the gap explicit; unavailable does not mean non-applicable
Not applicable	The appropriate professional confirms that the exact rule or document does not apply to this transaction and explains why	Keep the written reasoning, the professional's name and the date; never use this label merely to avoid a control

This is not a red-flag score. One unresolved right-to-build issue can matter more than twenty uploaded documents.

Example: a villa sold on plan under a 30-year lease

All names, entities, figures and facts in this worked example are fictional and illustrative.

An investor is offered a villa for USD 480,000. The deck says “30-year leasehold”, “8% guaranteed return for three years” and “handover in twelve months”. The payment schedule is 30% on signing, then 30%, 30% and 10% on dates four months apart.

The useful analysis is not whether the brand looks credible.

Transaction: counsel determines that the investor is taking a contractual lease from one entity plus a build/delivery promise from another. It is not assumed to be a house-sale PPJB.
Term: the lease starts on signing, so the twelve-month build consumes part of the marketed 30 years. Extension wording is an option to negotiate, not secured tenure.
Authority: the lessor's authority over the land and the developer's authority to build must be separately evidenced.
Baseline: the render omits the signed MEP specification, drainage design and furniture schedule. The second instalment cannot yet be tested against a complete scope.
Progress: “foundation complete” is replaced with an agreed measurable milestone, engineer/QS inspection, test records and defect schedule.
Variation: a retaining-wall redesign is priced and time-assessed before it is instructed; it does not disappear inside “site conditions”.
Return: the 8% is traced to the actual payer, formula, start trigger, costs, tax treatment, shortfall funding and default remedy.
Handover: the final 10% is split between practical completion, documentary/operating conditions and release of retained sums and defect provisions under the signed contract, after legal review.

This checklist does not tell the investor to proceed, withdraw or pay. It organises the documents, unanswered questions, responsibilities and decisions that the investor and their advisers must resolve. A polished render remains an illustration, not evidence.

Limits of this checklist

It does not:

certify that a project is legal, safe, investment-grade or profitable;
value the land, lease, shares or completed villa;
replace a current land search, survey, counsel opinion, technical inspection or tax analysis;
prove that a developer will remain solvent;
decide that housing/PPJB rules apply merely because the product is a villa;
treat the developer register as a whitelist;
make escrow, retention or a guarantee mandatory or effective in every transaction;
predict completion, occupancy, ADR, resale value or enforcement outcome;
rescue funds already paid under a weak agreement.

It does one important job: it turns a broad reassurance into a list of decisions that named professionals can verify.

Prepare the decision before the deadline

Start with the Bali property due diligence guide to organise the land, planning, building, operating and exit evidence. Review the leasehold term and exit assumptions when construction time, extension assumptions or resale rights affect the model. If a PT PMA or project company is proposed, verify its business activities and licensing basis.

If you already have a reservation, contract or next-payment notice, the useful next step is not a sales call. It is a one-page project evidence brief showing what is evidenced, what remains an assertion, who must review it and what must be resolved before the payment deadline.

Official sources and date consulted

Official sources consulted on 15 July 2026. Primary sources used for the limited regulatory statements above:

Permen PKP No. 18/2025: official JDIH record and official PDF: housing-sector risk-based standards, reporting, supervision and sanctions within scope.
Permen PUPR No. 24/PRT/M/2018: housing-developer certification/registration framework; its current relationship with SIRENG requires expert confirmation.
SE Dirjen Kawasan Permukiman No. 05/SE/Dp/2026: implementation of the developer-registration information service and its stated monitoring context.
SE Dirjen Kawasan Permukiman No. 06/SE/Dp/2026: formats/mechanisms for obligations and administrative sanctions within scope.
PP No. 12/2021: housing-development/marketing and PPJB framework; applicability must be determined, not assumed.
PP No. 16/2021 and official SIMBG portal: building framework, including distinct PBG and SLF functions.
Company Law No. 40/2007: official PDF: company identity, organs, shares and authority baseline, as amended and subject to current counsel confirmation.
Permen PU No. 6/2025: official PDF: current construction-business/workforce certification framework; exact SBU/SKK applicability is package-specific.

Before relying on this checklist, ask Indonesian counsel to classify the transaction and confirm the land rights and corporate authority. Obtain parcel-specific confirmation of the planning position, PBG and SLF. Agree the payment protocol with the architect, engineer or quantity surveyor and counsel. Identify the operating company, its OSS licences, taxes and payment flows. Reopen every official source on the decision date because the rules and public records may have changed.

Price, scope and the next commitment

A €150,000 villa in Bali: good value or an incomplete budget?Comparing construction quotations in Bali: price the same project first

From information to a project decision

Is this question part of a real Bali residence project?

Share the site, capital and decision context in a private brief. DALLEAU will identify the most useful owner-side next step; regulated legal, tax, immigration and notarial matters remain with authorised advisers.

Start a private brief