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Indonesia's tourism sector is governed by Law No. 10 of 2009 on Tourism, supplemented by regional regulations specific to Bali Province and the releva
Indonesia's tourism sector is governed by Law No. 10 of 2009 on Tourism, supplemented by regional regulations specific to Bali Province and the relevant kabupaten (regency). Any business offering accommodation, travel services, food and beverage, or entertainment to tourists must obtain a Tourism Business License, known as Tanda Daftar Usaha Pariwisata (TDUP), before commencing operations.
The process begins with establishing a legal business entity. Foreigners cannot directly own a tourism business under their personal name. The standard vehicle is a PT PMA (Perseroan Terbatas Penanaman Modal Asing), a foreign-owned limited liability company, which requires a minimum investment threshold and must be registered with the Investment Coordinating Board (BKPM, now BKPM/OSS). Certain tourism sub-sectors are open to 100% foreign ownership, while others require Indonesian partnership under the Negative Investment List (DNI), now largely replaced by the Positive Investment List under Government Regulation No. 10 of 2021.
Once the legal entity is established, the applicant must register through Indonesia's Online Single Submission (OSS) system — the central digital portal for all business licensing. OSS issues a Business Identification Number (NIB), which functions as the foundational license for all subsequent permits. For tourism businesses, the NIB must be followed by sectoral verification through the relevant regional tourism office (Dinas Pariwisata) at the kabupaten level.
The TDUP itself is issued by the local Dinas Pariwisata and is specific to the category of tourism business — categories include accommodation, food and beverage services, tourism attractions, travel bureaus, meeting and exhibition venues, and wellness businesses such as spas. Each category carries its own technical requirements, including facility standards, staffing criteria, and in some cases, environmental impact assessments (UKL-UPL or AMDAL for larger developments).
Additional permits often required alongside the TDUP include a Building Permit (PBG, formerly IMB), a Disturbance Permit (UUG/HO) in certain regencies, a liquor retail license (SIUP-MB) for establishments serving alcohol, and fire safety certification. Bali's spatial planning regulations (RTRW) also restrict where tourism businesses can legally operate — zoning compliance must be confirmed before any investment is made in a physical location.
Bali's tourism licensing framework looks daunting on paper, but the core risk is not bureaucratic complexity — it's the number of operators who skip or defer the process entirely, then find themselves
operating on borrowed time. Indonesian authorities have intensified enforcement across Bali's tourism corridor, particularly targeting villas and short-term rental operations that lack a TDUP or that
use an incorrect business structure.
For our clients, the most critical decision point is not which permits to get, but which legal structure to use before applying. A PT PMA is almost always the right answer for foreigners who want operational control, but the permitted business activities coded in the NIB must precisely match what the business actually does. A mismatch — common when founders cut corners during incorporation — can invalidate downstream permits or create liability during inspections.
The OSS system has improved transparency considerably, but local Dinas Pariwisata offices still exercise discretion, and relationships with the kabupaten matter. Getting this right from day one is significantly cheaper than remediation later.
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