Villa licensing under PP 28/2025: a dated timeline

Government Regulation 28 of 2025 changed Indonesia's general risk-based licensing framework. It did not ban short stays or switch on an automatic platform check overnight. Tourism standards, supervision and platform verification have developed through separate measures on different dates.

Owners need to separate three questions. What licence applies to the business today? Which tourism standard must it meet? What checks can a booking platform or authority perform now? A message that treats all three as a single new “villa law” is likely to mislead.

5 June 2025: the general licensing framework changed

Government Regulation 28 of 2025, usually cited as PP 28/2025, took effect on 5 June 2025 and replaced PP 5/2021. It governs Indonesia's risk-based business licensing system across sectors. Its scope includes basic requirements, business licences, supporting licences, the Online Single Submission system, supervision and sanctions.

This is not a villa-only regulation. It provides the general machinery through which an activity's risk level and business permissions are handled. The result still depends on the business carried on, the applicant, scale, location and the current record in the licensing system.

Risk level and PT PMA eligibility are different tests. A low-risk activity is not automatically closed to a PT PMA: foreign investment must still be permitted and the activity must offer a route for the appropriate enterprise scale, normally large enterprise. The reverse is equally important. A code requiring only an NIB does not override an MSME allocation, a foreign-ownership condition, a missing large-enterprise route or property-specific requirements.

10 October 2025: tourism standards followed

Tourism Ministry Regulation 6 of 2025 took effect on 10 October 2025. It sets business standards, supervision procedures and administrative sanctions for the tourism sector under PP 28/2025.

Do not assume that every business described as a villa has the same risk classification or evidence requirement. The Tourism Ministry's SISUPAR standards directory publishes villa standards across more than one risk tier. The live licensing result must be checked for the precise business rather than copied from another property.

26 May 2026: platform verification was still being built

In its 26 May 2026 briefing, the Ministry of Tourism said that its automated interface with online travel agencies was under internal development. The planned check would use three items:

• the Business Identification Number, or NIB;
• the Indonesian business classification, or KBLI;
• the Business Activity Number, or NKU.

The ministry stated that it aimed to launch the interface by June 2027. That is a target recorded in a dated press release, not a guarantee that the system will launch on that day or with unchanged rules.

The same briefing describes action that does not depend on the future interface. The ministry said it had identified unlicensed accommodation and would send official lists to platforms, which would suspend sales within two months of official notification. A compliant business could then be reinstated. Automated verification was future work; licensing duties and manual enforcement were not.

What a property owner should check now

A listing on a platform proves neither that the accommodation is licensed nor that the underlying property, entity and operations align. Before accepting bookings, assemble one current file:

1. Describe the service offered, who operates it and who receives the guest's payment.
2. Confirm the appropriate activity classification in the live Online Single Submission result.
3. Confirm the enterprise scale offered for that activity and whether the applicant's foreign investment is permitted or conditional.
4. Check the NIB and every licence or standard certificate required for that risk level.
5. Match the land use and building file, including the building approval and certificate of proper function where applicable, to the intended operation.
6. Confirm the tourism standard, local tax registration, staff obligations and guest reporting process.
7. Record renewal, reporting and supervision dates instead of treating the first licence as permanent clearance.

The NIB identifies the business but does not, by itself, establish that every property and activity may open. A paid tourist accommodation business remains regulated whether guests arrive through Airbnb, another platform or a direct booking. The exact route depends on the facts. Our KBLI 2025 villa activity map separates owner operation, third-party management, intermediation and residential rental.

A genuinely pre-existing valid licence raises a separate transition question. Its continued validity may be preserved when only the classification number changes, but that does not prove that the same activity is open to a new PT PMA today. Verify the original holder and shareholding, issue date, authorised activity and address, later changes and whether the current operation is still substantively the same.

Six claims to avoid

“PP 28/2025 made short stays illegal.” It did not create a general ban. It replaced the national risk-based licensing framework.

“Every villa is low risk.” The official tourism directory shows villa standards in different risk tiers. Check the live result for the specific activity and scale.

“A PT PMA cannot carry any low-risk activity.” Risk determines the licensing pathway, not foreign-investment eligibility. Test the activity, enterprise scale and investment conditions separately.

“An old licence proves that a new PT PMA can obtain the same code.” A valid prior authorisation may benefit from a transition rule without opening the route to a new applicant.

“The future platform interface is already active nationwide.” The ministry described it as under development on 26 May 2026 and gave June 2027 as a target.

“No interface means no enforcement.” The same ministry briefing describes official identification and platform suspension procedures outside the future automated check.

Updated: 17 July 2026.

Sources checked 20 July 2026: PP 28/2025; Presidential Regulation 49/2021 and its investment schedules; Law 20/2008, including the definition of large enterprise; Tourism Ministry Regulation 6/2025; Tourism Ministry SISUPAR villa standards; Tourism Ministry platform-verification briefing, 26 May 2026. Check the live Online Single Submission record and current Indonesian text before acting.

This note presents our interpretation of sources available on the review date. It may be incomplete, outdated or mistaken. It is general information, not legal, tax or licensing advice.