Who owns, sells, builds, receives payment and operates your Bali villa?

Start with the named legal entities

“The developer” is not a complete counterparty map.

For an off-plan project, identify at least six roles separately:

1. landholder: controls the underlying land/right;
2. developer: assembles and directs the project;
3. seller, lessor or assignor: grants the right you acquire;
4. agent or marketer: introduces or markets the product within its mandate and applicable intermediary rules;
5. contractor: builds the defined work;
6. operator: sells stays and runs the completed property.

Then identify the project company, payment recipient, guarantor and each licensed professional. One company may hold several roles. Several companies may share one logo. What matters is not the number of entities; it is whether each promise has a named debtor, authority, evidence and remedy.

Roles a brochure may combine

What each party does and what to request

Where the intermediary activity falls within Permendag 33/2025 and KBLI 68200 P4, the framework includes an Indonesian-domiciled legal entity, NIB, relevant verified Standard Certificate, competent/certified brokers and a written service agreement; receiving a deposit or down payment requires the seller/owner's consent within the applicable function. Broker compliance does not prove the developer's compliance or capacity, the land rights, project approvals, project finances, payment protection or delivery.

SIRENG and the related housing-developer rules are useful evidence within their proper scope, but a registry result is not government approval of a private villa project. It does not prove land rights, solvency, payment protection, delivery, quality or safety. The current coverage of SIRENG for a private Bali villa project should be confirmed with Indonesian housing counsel or the competent ministry. A business identification number (NIB) likewise confirms business registration only; it does not answer the land, contract, building or counterparty questions.

Map the promises and the money separately

Who made each promise?

For every material promise, fill one row:

An empty debtor cell is not a drafting detail. It means nobody has yet been identified as legally responsible for the promise.

Who receives and controls the money?

Draw the actual flow:

investor → reservation recipient → seller/lessor/developer → contractor and consultants → operator → guest or booking-platform payment recipient → revenue account → costs/tax/reserve → investor

For each transfer ask:

• Why does this party receive the money?
• Is it principal, rent, purchase price, construction advance, fee, deposit or revenue?
• Who controls the account and release?
• What invoice, receipt, tax and reporting treatment applies?
• Is the recipient holding money for itself or on behalf of another?
• What happens if the relevant condition is not met?

This map often reveals that the entity receiving the deposit is not the landholder, delivery obligor or future operator. That can be legitimate. It must be documented, not guessed.

When can one group company cover another?

Example: one brochure, four contracts

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

The Hypothetical Project Alpha deck carries one logo. The reservation form asks payment to PT Marketing A. The land is held by an Indonesian individual. PT Development B promises the design and handover. CV Contractor C builds. PT Operations D promises a three-year fixed return.

Calling all four “Project Alpha” hides the essential questions.

1. Land counsel confirms whether the individual can grant the exact right and term to the investor or project structure.
2. PT Marketing A's authority to collect, hold and refund the reservation is written rather than inferred from an email address.
3. PT Development B's delivery obligation contains the plans, price, milestones, longstop and remedies. Its rights to enter/build on the land are evidenced.
4. CV Contractor C's contract and qualification are reviewed, but the investor does not assume a direct claim unless an assignment/warranty creates one.
5. PT Operations D's fixed-return obligation is modelled on its own accounts and security. Development B's assets do not support it unless Development B expressly joins or guarantees it.
6. The brochure's “group guarantee” is removed unless a named entity executes a real instrument.

The project may be perfectly capable. The map simply ensures that capability sits behind the promises the investor is paying for.

Limits of this map

It does not:

• decide the legal form of your transaction;
• verify a land right, company, power of attorney, licence or signature;
• make an affiliate responsible without a valid instrument;
• confirm SBU, SKK or other construction requirements for a specific package;
• decide who is the operator, the entity contractually responsible for collecting guest payments, or taxpayer without the contracts and facts;
• value a guarantee or predict recovery;
• replace conflict checks and independent professional appointments.

Name the parties before you map the payments

Use the Bali property due diligence guide to organise the land, company, project and operating evidence. Read operator and project-party roles before accepting an operator label. If the project company or PT PMA route is unclear, review its business activities and licensing basis.

A serious review does not begin by asking whether the people seem trustworthy. It begins by writing the full legal name beside every asset, promise, payment and remedy. Trust then has a structure it can safely sit on.

Official sources and date consulted

Official sources consulted on 15 July 2026. Limited official anchors: Permen PKP 18/2025, Permen PUPR 24/2018, SE 05/SE/Dp/2026, SE 06/SE/Dp/2026, Permendag 33/2025 official PDF, Company Law 40/2007 official PDF, PP 16/2021 building framework, and Permen PU 6/2025 construction framework.

Before relying on the role map, ask Indonesian counsel to identify the legal entity behind each role and examine every contract. Obtain current land, PPAT and company searches. Have the architect, engineer and construction lawyer check the technical appointments and qualifications for the relevant work package. Ask the licensing and tax professionals to state exactly which issues they examined, their conclusion and the date. Reopen the official sources and confirm that the rules still apply to the project.