A date on the calendar is not proof of progress
A date can trigger a reminder. A payment should be tied to an obligation.
For each material instalment, the file should show:
- the contractual milestone;
- the approved drawings/specification and measurable scope behind it;
- current site evidence and measurement;
- inspection by a competent architect, engineer or quantity surveyor whose appointment and possible conflicts have been checked;
- the effect of defects, incomplete work, materials off site and previous overpayment;
- approved variations and time consequences;
- the correct invoice, tax, account and release authority;
- the balance and security remaining for completion, handover and defects.
The investor is not trying to micromanage a building site. The objective is simpler: do not let cash run materially ahead of verified value, control and remaining remedies.
Measurements that answer different questions
| Term | What it should mean | What it is often confused with |
|---|---|---|
| Payment calendar | Forecast or fixed dates under a contract | Evidence of completed work |
| Physical progress | Measured work completed to an agreed baseline | Percentage of time elapsed or money spent |
| Cost incurred | Contractor/developer expenditure | Value correctly installed for the investor |
| Material on site | Identified material delivered, protected and allocated | Completed, conforming work |
| Practical completion | Defined level allowing agreed possession/use despite scheduled minor items | Perfect completion, SLF, opening or final account |
| Handover | Transfer of defined possession, control, documents and risk | Automatic release of every remaining sum |
| Retention | Contractually withheld amount with release rules | A universal statutory percentage or full protection |
| Warranty/defects period | Time and process for correcting covered defects | Proof the responsible party will remain solvent and perform |
| Independent certificate | Opinion within a named appointment and scope | Guarantee of title, legality, cost, all quality or future performance |
Match each payment to evidence
| Payment basis | Evidence quality | Main risk | Better release rule |
|---|---|---|---|
| Date only | No site condition | Cash can lead work substantially | Do not convert a date into progress; add a measurable condition or consciously price the advance risk and security |
| Developer's percentage | Self-reported | Method, conflicts and baseline unknown | Require supporting measurement and agreed independent review |
| Milestone name only (“structure complete”) | Ambiguous scope | Parties measure different work | Define inclusions, exclusions, tests, drawings and evidence |
| Measured work, no quality gate | Quantity evidenced | Defective work can still be paid in full | Add inspection, test and defect treatment |
| Measured conforming work | Stronger | Prior overpayment, variations and completion funding may remain | Reconcile cumulative earned value, amounts paid and cost to complete |
| Materials off site | Ownership/control risk | Double sale, loss, non-delivery or incompatibility | Treat as payable only if the signed contract permits a defined ownership, identification, insurance, storage and delivery mechanism and the buyer accepts it with full knowledge; otherwise exclude |
| Handover certificate | Delivery point evidenced | Missing documents/licences/retention may be overlooked | Split physical, documentary, operational and final-account releases |
There is no universal “correct” percentage schedule. A bespoke villa, a multi-unit estate, a land lease plus build and a completed-unit sale do not carry the same risks. What can be universal is the discipline: define the trigger, evidence it, reconcile the money, preserve enough leverage to finish.
For a transaction that falls within the housing PPJB rules in PP 12/2021, keep two thresholds separate. The 20% construction test is one of the conditions that must be satisfied before the PPJB stage. For detached or row houses, it concerns at least 20% of all planned units plus 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 villa and not a standard payment milestone. Separately, the developer may not collect more than 80% until the relevant PPJB conditions are satisfied. That limit is not a statutory escrow account. Counsel must first confirm that the housing PPJB rules apply to the transaction.
Agree the baseline before measuring progress
You cannot measure a render.
The payment baseline should include, as applicable:
- signed contract and complete party/capacity details;
- issued-for-construction architectural, structural and MEP drawings;
- specification and approved material/equipment schedule;
- bill of quantities, schedule of values or other measurement basis;
- programme with critical approvals, utilities, procurement and commissioning;
- responsibility matrix;
- approved contract price and contingency treatment;
- definition of each milestone and required evidence;
- inspection, notice, payment and dispute timetable.
If the design remains intentionally incomplete, the contract must expose that uncertainty. It should not present a fixed price and fixed delivery date while leaving the most expensive details to later “client upgrades”.
Five checks before payment
- Written request: amount due, contractual milestone, invoice, payee, bank account, supporting documents and cumulative payment position.
- Site evidence: dated inspection record, photographs tied to locations, test results, delivery records and an updated schedule.
- Independent review: a competent architect, engineer or quantity surveyor checks only the work covered by their written appointment and states any exclusions or conflicts.
- Contract check: confirm the milestone, approved changes, delay notices, outstanding defects, security and the estimated cost and time still needed to finish.
- Payment record: pay only to the verified contractual account after the authorised decision-maker approves it, then retain the certificate, invoice, payment confirmation and conditions for the next instalment.
Changes: when a fixed budget stops being fixed
A variation should answer five questions before work, except under a tightly defined emergency procedure:
- What changed, and why?
- Who had authority to instruct it?
- What drawing/specification replaces the old one?
- What is the price basis and tax effect?
- What is the programme and completion impact?
Maintain one register:
| ID | Instruction | Scope | Price | Time | Status | Evidence |
|---|---|---|---|---|---|---|
| V-01 | Drainage redesign | Revised civil drawing | Pending QS review | +? days | Not approved | Site/engineer note |
| V-02 | Stone substitution | Named equivalent | IDR … | 0 | Approved | Sample + signed order |
“Included in next invoice” is not a variation process. Nor should the investor be asked to approve price after the replacement is already concealed in the work.
Money withheld until completion, and other security
Retention can preserve money until defined completion and defect gates. It is only as good as its drafting:
- percentage/base;
- cap;
- who holds it;
- first release trigger;
- second/final release trigger;
- right to apply it to uncorrected defects;
- insolvency and termination treatment;
- interaction with bonds, guarantees and final account.
It is not always present and no percentage should be described as universally required.
Likewise, an advance-payment guarantee, performance bond, bank guarantee, escrow or parent guarantee must be read as an instrument, not as a label. Check issuer, beneficiary, amount, expiry, reduction, demand conditions, defences, governing law and whether the security survives the period when risk exists.
Handover has four separate parts
| Release | Possible conditions | Why separate it? |
|---|---|---|
| Practical/physical completion | Inspected work substantially complete; punch list defined | Possession may be possible before every minor defect is fixed |
| Documentary completion | As-builts, manuals, warranties, test records, approvals/SLF route as applicable | An undocumented villa is expensive to operate, insure, repair and sell |
| Operational readiness | Utilities, staff/vendor handover, operator/licensing/tax/merchant dependencies | A finished building may not be a functioning accommodation business |
| Final account/defects release | Final variations settled; defects corrected; retention conditions met | Keeps the close-out dispute from contaminating possession and opening |
The contract may structure these differently. The analytical point is that one signature should not accidentally certify four different things.
Example: replace six calendar payments with five evidenced stages
All entities, percentages, dates and facts in this worked example are fictional and illustrative.
The brochure proposes:
- 20% reservation/signing;
- 20% after 60 days;
- 20% after 120 days;
- 20% after 180 days;
- 15% at “completion”;
- 5% at key handover.
The reviewed structure might instead distinguish:
- Initial release: transaction/land authority, reviewed contract, baseline and essential pre-construction conditions satisfied; any true advance separately secured or consciously priced.
- Substructure gate: measured and tested foundations/substructure under approved structural documents, with cumulative certificate.
- Weather-tight structure gate: defined structure, roof and envelope complete to specification; concealed tests/inspections filed.
- MEP and finishes gate: first/second fix and finishes measured by package; commissioning dependencies and variations reconciled.
- Handover and close-out: physical completion release, separate documents/operational conditions, then retention/defect release.
Dates remain in the programme and longstop remedies. They stop pretending to be evidence of construction.
Limits of this payment check
It does not:
- create a right to withhold, inspect, enter the site or terminate if the contract lacks it;
- decide which housing/PPJB or construction rules apply to your transaction;
- make the certifier independent or liable without a proper appointment;
- detect hidden defects without the required inspections/tests;
- guarantee completion, funding or contractor solvency;
- make escrow, bonds, retention or milestone payments universally mandatory;
- replace land, permit, tax, insurance or operating due diligence;
- determine the tax invoice/withholding/VAT answer without the exact parties and supply.
Build a record for the next payment
Use the Bali property due diligence guide to organise the project evidence before assessing a payment request. Review construction quotes and scope, then test how the construction period and remaining leasehold term affect the exit assumptions.
Before the next transfer, ask for one complete, well-organised file containing the cumulative certificate, current site evidence, the approved variation register, payment reconciliation, an updated cost and completion forecast, and the conditions that must be met before the following payment. This is a standard request for evidence.
Official sources and date consulted
Official sources consulted on 15 July 2026. Official anchors: PP 16/2021 for the building system and distinct PBG/SLF functions; Permen PU 6/2025 for the current construction-business/workforce certification framework; Permen PKP 18/2025 for housing-sector business standards within scope; Permen PUPR 24/2018 for its housing-developer certification/registration framework; SE 05/SE/Dp/2026 for the SIRENG service and its stated government-assisted/financed/incentivised housing monitoring context; SE 06/SE/Dp/2026 separately for formats/mechanisms of applicable housing-business obligations and sanctions; PP 12/2021 for the housing/PPJB framework where it applies. The relationship between Permen PUPR 24/2018, SE 05/2026 and current SIRENG coverage requires confirmation from the relevant Indonesian professionals. No registry result should be treated as project approval, a whitelist or proof of title, solvency, payment protection, delivery, quality or safety.
The milestone, retention, variation, security and handover measures above are contractual safeguards, not a claim that Indonesian law imposes one universal model. Before using them, have Indonesian counsel examine the transaction and contract, agree the inspection and payment procedure with the appointed architect, engineer or quantity surveyor, confirm the construction qualifications required for each work package, obtain Indonesian tax advice on the payments, and have every bank instrument or security examined. Reopen the official sources on the decision date.
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 firstTwo questions to explore next
Is this question part of a real Bali residence project?
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