KBLI 2025 for Bali villas: owning, operating and managing for others are not the same business

Indonesia's 2025 Standard Classification of Business Fields, known as KBLI, now separates four activities that Bali proposals often blur together. It also exposes a common mistake: finding the code that describes an activity does not prove that the chosen company is allowed to use it.

KBLI 2025 itself took effect in December 2025. The BPS publication of 14 July 2026 clarifies tourism-sector implementation and OSS integration; it does not enact a new version of KBLI.

If an eligible Indonesian micro, small or medium enterprise operates its own villa for short tourist stays, 55203, Aktivitas Vila, describes that activity. A new PT PMA cannot use 55203 under the current OSS matrix because that code has no large-enterprise route. If a company genuinely manages another owner's accommodation, controls daily operations on that owner's behalf and earns a management fee, 55901, Aktivitas Jasa Manajemen Akomodasi, may be the closer fit. A booking intermediary, residential property manager and long-term landlord each sit somewhere else. The code follows the activity, but access to the code follows a second set of rules.

Start with five facts, not five digits

“Property management” can describe almost anything in Bali: replying to guests, collecting rent, supervising repairs, running staff, marketing a villa, managing an estate, or taking the entire commercial risk under a lease. KBLI does not classify the label on the proposal. It classifies what the company does.

Before anyone recommends a code, answer these questions:

• Who signs or is legally responsible for the guest stay?
• Who receives the room revenue?
• Who bears vacancy, refund and operating risk?
• Who controls rates, staff, check-in and daily decisions?
• Is the company paid rent, room revenue, commission or a management fee?

Those answers matter more than whether the website calls the business a villa operator, asset manager or hospitality platform.

The decision table

This is a starting map, not a licence opinion. A lease-plus-management contract, guaranteed owner return, mixed revenue share or split staff arrangement can change the answer and needs to be read as a whole.

55203: operating your own villa

The official definition of KBLI 55203, Aktivitas Vila, is unusually clear. It covers short-term accommodation for the public in private houses specifically rented to tourists, with their facilities, managed by the owner. The old 55193 Vila maps directly to 55203 under the official BPS conversion table.

The legal answer appears only when four official records are read together:

1. The activity. The official KBLI and OSS description says 55203 covers short-term tourist accommodation in a private house, with its facilities, managed by the owner.
2. The enterprise scale. The current public OSS matrix for 55203 contains micro, small and medium lines. It contains no large-enterprise line.
3. The investor's status. Article 1(4) of Law 20/2008 includes foreign businesses and joint ventures within the definition of a large enterprise. A PT PMA therefore does not enter through a micro, small or medium line.
4. The allocation and conversion. Appendix II of Presidential Regulation 49/2021 placed old 55193 Vila among activities allocated to cooperatives and UMKM. The official BPS table then converts 55193 directly into 55203.

Plain-language conclusion: KBLI 55203 is a valid activity, but it is not available as a new registration route for a PT PMA. It can describe an eligible domestic micro, small or medium enterprise operating its own villa. The missing large-enterprise line is decisive for a new PT PMA.

How a careful reader can still reach the wrong answer

The texts answer different questions. Reading only one of them produces a plausible but incomplete conclusion.

• “The code exists, so my company can use it.” No. KBLI defines the activity; OSS and the investment rules determine which enterprise scale can register it.
• “The activity is medium-low risk, so it is open to foreign investment.” No. Risk determines the licensing pathway. It does not create an enterprise scale or remove an investment restriction.
• “My investment exceeds Rp10bn, so I qualify as a large operator.” No. A high investment value cannot create a large-enterprise line that OSS does not provide for that activity.
• “BPS converted 55193 to 55203, so the old UMKM allocation disappeared.” No. The conversion changes the classification number; it does not, by itself, enlarge who may use the activity.
• “An old licence remains valid, so a new PT PMA can obtain the same one.” No. A transition rule can preserve an existing valid authorisation without opening the route to a new applicant.

The point is not that villa activity is prohibited in absolute terms. The point is that the correct activity description and the correct applicant eligibility are separate gates. This is precisely why a five-digit code should never be presented as a complete licence opinion.

55901: managing accommodation for another owner

The genuinely useful addition is KBLI 55901, Aktivitas Jasa Manajemen Akomodasi.

It covers a third party responsible for the business and operational performance of accommodation, directly involved in daily operations and managerial decisions, acting on behalf of the property owner and receiving a management fee.

That description is much closer to a real villa-management company than a generic consultancy or real-estate code. Unlike 55203, the current public OSS matrix for 55901 includes a large-enterprise line. That makes 55901 capable of being tested for a large company, but it is not automatic PT PMA approval: the actual service, investment access, location, risk tier and licence path must still be confirmed for the applicant. Save a dated OSS result before making project-specific claims.

This makes 55901 a candidate classification to test for a genuine third-party accommodation manager. It is not a project-specific licensing recommendation, and the facts must match:

• there should be a real management mandate;
• the company should act for the owner rather than pretend to be an agent while trading entirely for its own account;
• daily authority and reporting should be documented;
• the management fee, guest revenue, payroll and expense flows should match the contract;
• the party shown to guests, online travel agencies (OTAs), staff, tax authorities and OSS should be consistent across every record.

If the company leases the villa, sells stays in its own name and bears the entire commercial risk, it may no longer be merely managing accommodation for the owner. Calling the payment a “management fee” does not decide the classification.

A management company is not automatically the principal supplier of the guest stay. The operator, property right, guest contract, OTA merchant, staff, tax, APOA and customer risk still need to be assigned coherently.

A manager's licence does not regularise the villa it manages

This is the point most likely to be lost in the excitement around 55901.

A properly licensed manager does not automatically cure an owner's wrong zoning, missing PBG or SLF, unlicensed accommodation activity, tax gap or invalid commercial use of the property. The official definition says the manager acts on the owner's behalf. It does not say the underlying accommodation disappears from the compliance chain.

The questions still include:

• Is tourist accommodation allowed at that parcel?
• Do the building approval and fit-for-use certificate match the completed asset and its use?
• Is the underlying accommodation/operator correctly licensed for the actual model?
• Which entity is legally responsible for collecting guest revenue?
• Who registers and pays the applicable taxes?
• Who employs staff and reports foreign guests?

Our full PP 28/2025 villa-licensing note covers those physical, operating and tax layers. The management KBLI is one layer, not the whole stack.

55400 and 68292: two businesses often called management, but not the same one

KBLI 55400 is accommodation intermediation. It covers matching clients and providers for a fee or commission, including booking services through digital or non-digital channels. That fits a marketplace or introducer. It does not fit a company that controls staff, guest service and the daily operation.

KBLI 68292 is residential real-estate management for a fee or contract. Its official definition is about maintenance, repairs, budgets, charges and residential rules. Think estate or residential management, not nightly hospitality.

One group may genuinely perform more than one activity. If each activity earns revenue, it needs to be reflected correctly in the company objects, OSS projects, contracts, accounts and investment reporting. Multiple codes do not turn overlapping paperwork into permission to do anything.

68112: residential rental is not short-stay accommodation

KBLI 2025 separates residential development/sale under 68111 from rental and operation of owned or leased residential property under 68112.

The broader division 68 definition excludes hotels, holiday homes and other accommodation for stays of less than one year, sending them to division 55. That makes 68112 a poor answer to a nightly or weekly tourist-villa business, even if “property rental” sounds right in English.

That missing matrix is itself a reason for caution. The current public OSS page for 68112 shows the definition, but it does not provide a usable risk and business-licence matrix. A reader should therefore not treat the code as automatically “NIB only” or automatically available to a PT PMA. The applicant’s actual profile and live OSS result still need to be checked.

Why a hotel or apart-hotel code is not a workaround

A real non-star hotel, apart-hotel or cottage business can have a different classification. That does not make those codes substitutes for a private villa.

The classification follows the premises, service model, standards and operation. A large-business line on one hotel code does not allow an investor to relabel a villa to solve a restriction. The same principle applies to “other short-term accommodation.” A code chosen against the facts tends to survive only until a serious bank, buyer, platform or regulator compares the paperwork with the asset.

The Rp10 billion myth, in three separate numbers

The market is currently combining three unrelated tests.

1. Paid-up capital: generally Rp2.5 billion per PT PMA

Since Investment Ministry/BKPM Regulation 5/2025, the general minimum placed and paid-up capital is Rp2.5bn per PT PMA, unless a sector requires more. Company-law rules also require at least 25% of authorised capital to be subscribed and fully paid.

So the practical minimum is the highest of Rp2.5bn, 25% of authorised capital and any higher sector minimum. If authorised capital is Rp20bn, 25% is Rp5bn: paying only Rp2.5bn would not be enough.

2. Project investment: generally more than Rp10 billion

Separately, a PMA project generally needs a planned investment strictly greater than Rp10bn per five-digit KBLI and project location. For property operation and short- or long-term accommodation, land and buildings can enter the calculation under the detailed rules.

This is an investment plan, not a universal instruction to park Rp10bn cash in the bank on incorporation. The regulation recognises equity, loans, reinvested profit and share premium as funding sources, and recognises relevant assets, construction, equipment, project costs and working capital as uses.

A pure management company cannot casually count villas owned by its clients as its own investment.

3. E28A investor visa: at least Rp10 billion of the applicant's shares

Immigration applies a separate threshold for the E28A investor visa: the applicant currently needs evidence of at least Rp10bn in shares in the sponsoring company. A Rp10bn shareholder loan is debt, not shares. A Rp10.5bn OSS project plan is not proof that the individual owns Rp10bn of equity.

The differences between owning the company, supervising it and working in its daily operation are covered in our E28A note and work-permit note.

Can the acquisition funds pass through the company?

Yes, provided that “pass through” describes a real company transaction rather than a temporary bank balance.

A clean structure can involve shareholders contributing documented equity and/or a shareholder loan, the PT acquiring the relevant asset or right in its own name, and the PT paying the project costs from its bank account. The deed, shareholder register, bank trail, purchase documents, invoices, accounts and LKPM reporting should agree.

The paid-up capital carries a 12-month retention commitment, but the current regulation expressly allows it to be used for company asset purchases, building construction and company operations. The money is not required to sit idle.

What does not work is sending money into the PT, taking a screenshot and returning it the next day without a legitimate asset purchase, operation, loan basis or corporate record. A transfer is not automatically capital. Cash in the bank is not automatically realised investment. Substance and documentation matter.

What happens to an existing 55193 or 68111 company?

BPS says existing licences remain valid. When only the KBLI number changes and the underlying activity does not, OSS/AHU performs the conversion automatically; no new licence or constitutional amendment is required merely for the code change.

If the actual purpose, scope or activity changes, the business must update OSS/AHU and, where applicable, its deed and licences.

This transition protection must not be read backwards. It preserves an authorisation that was already valid; it does not prove that the same route is available to a new PT PMA, and it does not cure a licence that was never valid for the holder or activity. A legacy file should be checked for its issue date, original holder and shareholding, authorised activity and address, later ownership changes, and any change from owner-operation to third-party management. A change of substance requires more than an automatic code conversion.

That distinction is important:

• old 55193 to new 55203 is a direct villa recoding;
• old 68111 is split into more specific 2025 activities, so the correct successor depends on what the company really does;
• moving from operating your own accommodation to managing third-party accommodation is a substantive business-model question, not clerical renumbering.

The practical review before taking a booking

Ask the adviser to provide a written table with:

• actual activity and contract model;
• old and new KBLI mapping;
• business sizes available in the company's current OSS record;
• PMA restriction or condition;
• risk tier and required Business Licence/Standard Certificate;
• supporting zoning, environmental, building, sanitation and tourism requirements;
• investment-plan unit and whether land/buildings count;
• paid-up capital and funding documents;
• guest revenue, management fees, payroll, tax and investment-activity reports (LKPM);
• named responsibility for each action and renewal.

If one written review cannot reconcile those records, the structure is not ready.

Questions we get asked directly

Can my PT PMA use KBLI 55203 to rent its own villa nightly? Not as a new registration route under the current OSS matrix. 55203 provides micro, small and medium lines but no large-enterprise line, while a PT PMA is treated as a large enterprise. A genuinely pre-existing licence is a separate transition question and must be reviewed on its own record.

Does an old 55193 or automatically converted 55203 record prove that new PT PMAs can use the code? No. Continuity protects an existing valid authorisation when the activity has not substantively changed. It does not create a new entitlement for another company, address, ownership structure or business model.

Can I solve that by hiring a 55901 management company? Not automatically. 55901 can license the genuine management activity of the manager. It does not erase the underlying accommodation, owner, property, building, tax or operating requirements.

Is 55901 the new property-management code? It is the explicit code for operational management of accommodation on behalf of an owner for a management fee. Residential property management, booking intermediation and rental for the operator's own account remain different activities.

Do I need to deposit Rp10bn on day one? Not as a universal current capital rule. The general paid-up-capital floor is Rp2.5bn per PT PMA, subject to 25% of authorised capital and higher sector rules. The more-than-Rp10bn figure is generally the project investment plan. E28A uses a separate Rp10bn personal shareholding threshold.

Does a low or medium-low risk code mean it is open to PT PMA? No. Risk tier determines the licensing pathway. Enterprise scale and foreign-investment eligibility are separate tests.

sources checked: 20 July 2026

Related: Bali property due diligence before a deposit · PT PMA vs nominee · What PP 28/2025 does · E28A investor visa

Sources: BPS KBLI 2025; official KBLI 2020 to 2025 conversion table; BPS tourism and OSS clarification, 14 July 2026; OSS pages for 55203, 55901, 55400, 68112 and 68292; Presidential Regulation 49/2021 and its official Appendix II; Law 20/2008, including the large-enterprise definition in Article 1(4); Investment Ministry/BKPM Regulation 5/2025; Government Regulation 28/2025; Tourism Ministry Regulation 6/2025; and Immigration E28A. Checked 20 July 2026. This note provides general information, not Indonesian legal, tax, investment, land or immigration advice. Confirm the exact company, contract, asset, address and current OSS result before acting.

Additional official references

• BPS Regulation 7/2025: the formal KBLI 2025 instrument
• BPS transition guidance, 27 April 2026
• BPS tourism and OSS clarification, 14 July 2026

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General information. Updated 20 July 2026. This page presents DALLEAU's good-faith reading of the official sources cited. It is not professional advice. Rules and administrative practice can change; the summary may be incomplete, outdated or mistaken. Check the current official text and your facts with the competent authority or appropriately authorised professional before acting.