Bali PMA restrictions: the 18 KBLI codes

The distinction is practical, not semantic.

On 23 July 2026, the Bali Provincial Government published an official announcement stating that, for business locations across Bali, OSS access had been closed to new PMA business-licensing applications in 18 designated low-risk and medium-low-risk activity categories. The province said the restriction had operated since the third week of May 2026 after central-government approval.

The public record supports a targeted administrative restriction on new PMA licensing applications. It does not support the broader claim that Bali has prohibited every form of foreign investment, property ownership structure or villa project.

A business's real activity, KBLI, enterprise scale, licence status, property structure and operating model remain separate questions.

What changed

A KBLI is the code used to classify an Indonesian business activity. It is not the company, the land title, the building approval or the operating licence by itself.

ANTARA reported the following 18 KBLI 2020 codes and Indonesian activity descriptions. The English wording below is an editorial translation of that report, not an official English annex. ANTARA reports the 6,000 m² threshold for both hotel codes. The official Bali release expressly states that threshold for star-rated hotels, but lists non-star hotels without publishing a numbered annex.

Important code-version warning. The reported list uses KBLI 2020, while the government scheduled KBLI 2025 implementation across OSS and AHU by 18 June 2026. BPS conversion tables show that the mapping is not always one-to-one. Hotel code 55110 split into 55101 to 55105, 55120 became 55106, broad real-estate code 68111 split across multiple residential and non-residential activities, 70204 moved to 70202, and 70209 split between 70203 and 70209. A current file must therefore be mapped by actual activity and checked in live OSS.

KBLI 2020	Activity as reported by ANTARA under KBLI 2020
55110	Star-rated hotel, where the relevant building area is below 6,000 m²
68111	Real estate owned or leased
55120	Non-star hotel, where the relevant building area is below 6,000 m²
70209	Other management consulting activities
77100	Rental of cars, buses, trucks and similar vehicles
47711	Clothing retail
47511	Textile retail
77311	Motorcycle rental without a purchase option
47249	Other food retail
47991	Mobile retail of agricultural food commodities
55900	Other accommodation provision
56303	Drinking places and cafés
56305	Traditional medicine houses or shops
14120	Tailoring and made-to-order clothing production
93111	Stadium facilities
93116	Fitness centre facilities
93191	Sports activity promoters
70204	Industrial management consulting activities

What this does not automatically mean

It is not a ban on all foreign investment in Bali

The restriction concerns identified KBLI and new PMA applications through OSS. Other activities are not automatically covered by this 18-code list.

It does not automatically cancel every existing licence

The public announcement does not say that existing licences are automatically cancelled. It says companies that already hold licences must continue filing LKPM. That does not settle how amendments, expansions, renewals or conversion to KBLI 2025 will be treated. Each case requires a live OSS check and written advice.

It does not answer land or property-right questions by itself

Nothing in the announcement itself cancels a lease or land right. The announcement addresses access to business licensing. On its face, it does not address title or contract law. Whether a particular project can continue operating is a separate question.

Using a substitute KBLI does not make the structure compliant

The code should follow the real business. Contracts, revenue, daily operations and the service actually supplied all matter.

Low risk does not mean open to foreign investment

Risk classification and foreign-investment eligibility are separate tests. A low-risk activity may have a simple licensing pathway while still being unavailable to a PMA because of investment, enterprise-scale, location or sector-specific rules.

Why this matters for villa and residence projects

The reported KBLI 2020 list includes small hotel categories, other accommodation, owned or leased real estate and management consulting. Those activities can sit close to structures used around property holding, leasing, accommodation operation, residence management and advisory services.

A property project can involve several distinct roles: owner, lessor, developer, accommodation operator, property manager and consultant. Treating those roles as interchangeable can create licensing risk.

Why a social-media summary is not enough

The public account evolved over several months. On 9 July, ANTARA quoted a provincial official referring to 56 low-risk and medium-low-risk KBLI. The official Bali announcement published on 23 July identifies 18 activity categories, and ANTARA separately reported the corresponding 18 KBLI 2020 codes. No public source found in this review formally reconciles the earlier 56-code statement with the later 18-code announcement, so the article does not claim that one definitively superseded the other.

Owner checklist

What an owner or investor should verify

Pull the current NIB and complete OSS licensing profile.
Identify the activity that actually generates revenue.
Map each activity to the current KBLI.
Determine whether the proposed step is a new application, an amendment, an expansion or the continuation of an existing licence.
Verify the live OSS availability and obtain written guidance where unclear.
Separate property rights, building approvals and operating licences.
Review the contracting and payment flow between owner, operator, manager and guest.
Obtain Indonesian legal and tax advice before commitment.

The investor lesson

This change does not mean that every foreign-backed Bali project has become impossible. It does mean that structures whose activities, licences and contracts do not align are becoming harder to defend.

Taken together, the announcements suggest an administrative focus on the activity a business actually performs, its relationship to the local economy and whether its licence matches its operation.

A company name, a broad consulting code or an automatically issued NIB is not enough. The activity, enterprise scale, property documentation, licences, contracts and actual operation need to agree with one another.

What we are watching next

We are watching for a public numbered annex or central-government instrument, clearer guidance on the KBLI 2025 equivalents, live OSS behaviour by activity and project location, and the treatment of amendments, expansions, extensions and other changes to existing licences. These are case-specific legal questions, not reasons to overstate the public announcement.

Sources and update record

Official record and corroborating reporting.

This Field Note reflects public information checked on 27 July 2026. It explains the published record and does not determine the legal position of a particular company, licence, land right, contract or transaction. OSS availability and administrative practice can change. Obtain Indonesian legal and tax advice before commitment.

Bali's 18-KBLI PMA restriction: what the public record supports.