KBLI 2025 Engineering & Architecture Bali | Bali Zero

Q: What is the foreign ownership cap for engineering and architecture PT PMA in Indonesia?

Under UU Jasa Konstruksi (UU 2/2017 + PP 14/2021), a foreign construction/engineering PMA (BUJK PMA) must have a minimum 33% local Indonesian partner — maximum 67% foreign ownership. SBU certification via LPJK is required, and every technical staff member must hold a valid SKK (Work Competency Certificate). Foreign technical staff (TKA) must complete mandatory knowledge transfer programs.

Q: What is the IMB to PBG/SLF transition and why does it matter for engineering firms in Bali?

Indonesia fully replaced the old IMB (Izin Mendirikan Bangunan) system with PBG (Persetujuan Bangunan Gedung) for pre-construction approval and SLF (Sertifikat Laik Fungsi) for post-construction certification, managed via SIMBG. All existing structures with IMB must migrate to PBG+SLF, creating a massive backlog of architectural audits, technical inspections, material testing, and engineering assessments for thousands of Bali hotels, villas, and commercial structures between 2026 and 2028.

Q: What does the KBLI 2025 restructuring of code 71200 mean for testing and inspection firms?

KBLI 2025 fragmented the old aggregated 71200 (Testing & Analysis) into 5 specific codes: 71201 (Certification), 71202 (Inspection), 71203 (Verification & Validation), 71204 (Technical Testing), and 71209 (Other Testing). All companies operating under old KBLI 71200 must re-map their activities to the correct new codes and update their NIB in OSS by the now-closed June 2026 transition window — failure to do so will create licensing non-compliance.

Q: What is the engineering business opportunity from the North Bali Airport project?

Perpres 12/2025 authorizes the North Bali Airport in Kubutambahan, Buleleng Regency — a 2,800-hectare development with significant marine reclamation, targeting up to 50 million passengers. Construction is expected to start around 2027. Engineering demand includes geotechnical, coastal, marine, structural, and traffic engineering. The airport is outside the Sarbagita moratorium zone, and the Gilimanuk-Mengwi toll road (97 km, IDR 9 trillion) creates an additional infrastructure corridor.

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The engineering and architecture sector in Bali is entering a period of simultaneous constraint and opportunity. The Sarbagita moratorium limits greenfield development in South Bali's most active zone, while the North Bali Airport (Perpres 12/2025) and the Gilimanuk-Mengwi toll road are creating a new infrastructure corridor worth billions of USD. Overlaid on this is the critical IMB→PBG transition creating a massive retrofit and inspection market, and the OSS-RDTR GPS geospatial validation system that now gates every construction project.

Regulatory Framework 2026

KBLI 2025 Structural Changes for Group 71

KBLI 2025 (BPS Reg 7/2025, based on ISIC Rev.5) introduced the most significant restructuring of subgolongan 7120 in the KBLI's history:

Old KBLI 2020	New KBLI 2025	Change
71200 (Testing & Analysis — aggregated)	71201 (Certification)	Fragmented into 5 specific codes
71200	71202 (Inspection)
71200	71203 (Verification & Validation)
71200	71204 (Technical Testing)
71200	71209 (Other Testing)
71101 (Architecture)	71101 (Architecture)	Retained, description expanded (IBC reference added)
71109 (Engineering)	71109 (Engineering)	Retained, expanded to include project management and safety engineering

Action required: All companies with KBLI 71200 must re-map their activities to the specific new codes and update their NIB in OSS by the now-closed June 2026 transition window.

PMA Structure: UU Jasa Konstruksi (UU 2/2017 + PP 14/2021)

For construction-related PT PMA (BUJK PMA):

Requirement	Detail
SBU required	Via LPJK-accredited body
Maximum foreign ownership	67% (minimum 33% local partner)
Net worth minimum (consultancy)	IDR 250 billion (perencana dan pengawas konstruksi)
SKK (Work Competency Certificate)	Mandatory for every technical staff member
Knowledge transfer	Mandatory for all foreign TKA employed

OSS-RDTR GPS: The New Construction Gatekeeper

PP 28/2025 elevated RDTR (Rencana Detail Tata Ruang) from a planning instrument to the primary legal determinant for OSS licensing. The verification is automatic:

Entrepreneur enters project GPS coordinates in OSS
System cross-references coordinates against digital RDTR zoning maps (800+ RDTR integrated nationally by end 2025)
If KBLI activity is incompatible with the zone → NIB automatically blocked. No administrative discretion.

For engineering and architecture projects, this means:

RDTR compliance check must occur before any lease, land purchase, or OSS registration
Same location may be authorized for one activity type and prohibited for another
Non-compliance can invalidate all downstream permits (PBG, environmental permits, operating licenses)
Interactive RDTR tool: https://oss.go.id/rdtr-interaktif

IMB → PBG + SLF: The Critical 2026 Legacy Transition

The old IMB (Izin Mendirikan Bangunan) system has been fully replaced by:

PBG (Persetujuan Bangunan Gedung): Building design approval before construction begins — verifies compliance with RTRW, structural safety, and environmental impact
SLF (Sertifikat Laik Fungsi): Functional fitness certificate issued after construction completion, verified by a licensed pengkaji teknis with IPTB
Managed online via SIMBG (simbg.pu.go.id)

All existing structures with IMB must migrate to PBG+SLF. This creates a massive market across all 71xxx codes: architectural audits, technical inspections, material testing, and engineering assessments for thousands of Bali's hotels, villas, and commercial structures.

KBLI 71101 — Architectural Services

The Bali Aesthetic Paradox

The highest-value differentiation in Bali's architecture market is the ability to resolve a fundamental design conflict: clients demand vernacular Balinese architecture — bamboo, rammed earth, alang-alang roofs, rice terrace integration, and the philosophical framework of Tri Hita Karana — while requiring international clinical and hospitality performance: concealed HVAC, sanitary standards, seismic compliance for Ring of Fire conditions.

The 15-meter height limit ("no taller than a coconut tree") — established by SK Gubernur 1971 and confirmed in Perda 16/2009 Art. 95 — forces creative solutions: cliff-edge design building downward, semi-underground spaces, and cascading terraces. The rare exceptions (hospitals, airports, transmission towers) do not apply to hotels or resorts.

Operational requirements: SBU certification via LPJK under AR001/AR002 sub-classifications. Minimum 33% local partner required. SKK mandatory for each architect. Foreign architects must complete knowledge transfer (alih teknologi) program.

2026 opportunity zones:

Zone	Status	Rationale
Uluwatu	Growing fast	International airport incoming; still early-stage
North Bali (Buleleng)	Best opportunity	Outside Sarbagita moratorium; airport coming
Sanur	Underserved	Medical tourism KEK expansion
Tabanan/West Bali	Emerging	Gilimanuk-Mengwi toll road corridor
South Bali (Sarbagita)	Constrained	Moratorium limits greenfield; retrofit market strong

KBLI 71109 — Engineering Consulting (General)

Most versatile and highest-demand code in the 71xxx group

KBLI 2025 expands the scope of 71109 to explicitly include project management and safety engineering — making it the optimal core license for a PT PMA engineering firm. Covers civil, hydraulic, traffic, MEP, geotechnical, acoustic engineering, and more.

2025–2030 Infrastructure Pipeline

North Bali Airport (Perpres 12/2025):

Location: Kubutambahan, Buleleng Regency (north coast)
Scale: 2,800 hectares, significant marine reclamation component
Target capacity: up to 50 million passengers
Construction start: estimated ~2027 (currently in preparatory/financial phase)
Engineering demand: geotechnical, coastal, marine, structural, traffic

Gilimanuk-Mengwi Toll Road:

Length: 97 km across three sections
Cost: IDR 5 trillion (construction) + IDR 4 trillion (land acquisition), PPP scheme
Target completion: 2027–2029
Impact: reduces Gilimanuk-Mengwi journey from 3–4 hours to 1–1.5 hours

Post-flood demand (September 2025 Bali floods): explosive growth in hydrological studies, drainage engineering, and risk mitigation — particularly under Pergub 24/2020 requirements for lake/spring/river/sea protection.

KBLI 71201 — Technical Certification

New granularity in KBLI 2025 — covers product, process, service, and system certification: ISO, HACCP, ISPO, SMK3, halal certification, wood legality (SVLK), and SBU construction certification.

Primary Bali demand driver: ecolabel and sustainable tourism certification. KBLI 2025 explicitly includes sertifikasi kegiatan pariwisata within this code's scope. Green building certification (EDGE, Greenship) growing on eco-resorts.

Entry barrier: KAN (National Accreditation Committee) accreditation required. Market dominated by SGS, Bureau Veritas, TÜV. Better positioned as complementary service to a PMA already operating in 71101/71109 than as a standalone business.

KBLI 71202 — Technical Inspection

Immediate 2026–2028 market opportunity

Separated from old 71200 in KBLI 2025. Covers pipeline and structural inspection not connected to repair/installation. The IMB→PBG transition is generating a massive backlog of inspection requirements:

Thousands of Bali hotels, villas, and commercial structures require technical inspection for PBG/SLF migration
Post-September 2025 floods: structural inspections on damaged buildings in Sarbagita and Buleleng
Periodic water crisis drives pipe network inspection demand

IPTB (Building Technical Practitioner License) required for inspectors. High legal liability — inspection errors create litigation risk. Excellent as add-on to 71101 or 71109 for a complete design+inspection package.

KBLI 71203 — Technical Verification & Validation

Entirely new in KBLI 2025 (not in KBLI 2020). Covers verification and validation of technical processes, systems, and documents without issuing final certification.

Particularly relevant for pre-OSS-RDTR validation consulting — helping clients verify GPS coordinate compliance before official submission. In complex eco-resort projects, simultaneous compliance with seismic standards, environmental regulations, the 15m height limit, and international standards (WELL, LEED, FGI 2026) creates a specialized validation niche.

Best positioned as a complementary code within a multi-KBLI offering.

KBLI 71204 — Technical Testing

High potential, high barrier

Physical, chemical, and analytical testing of materials, products, and environmental conditions. Bali-specific demand:

Testing Type	Bali Application
Water quality testing	Contamination from overtourism; KEK Sanur medical requirements
Local construction materials	Structural bamboo, Paras Bali stone, rammed earth per SNI standards
Seismic testing	Existing structures post-earthquake compliance
Acoustic testing	Open-air resort design vs. privacy requirements paradox
Indoor environment testing	FGI 2026 Evidence-Based Design for wellness centers and clinics

Market gap: Most Bali samples are currently sent to Surabaya or Jakarta for testing. A KAN-accredited laboratory in Bali would address this gap. Partnership with Udayana University can reduce CAPEX significantly.

KBLI 71209 — Other Technical Testing

Catch-all residual code. Covers forensic testing, physical models (airports, dams), and product quality analysis. Relevant Bali applications: forensic analysis of post-flood structural failures, marine impact modeling for North Bali Airport reclamation, quality testing of artisanal Balinese products for export certification.

Recommended only as additional code alongside a firm already covering 71204. Functions as a regulatory insurance policy for activities at the margins of other codes.

PMA Strategy Matrix

KBLI	Sentiment	Bali Priority	Entry Barrier	Best Combination
71101 Architecture	★★★★☆	Very High	Medium	Core license
71102 Industrial Eng.	★★☆☆☆	Low	Medium	Add-on
71109 Engineering	★★★★★	Very High	Medium	Core license
71201 Certification	★★★☆☆	Medium	High	Complementary
71202 Inspection	★★★★☆	High	Medium-Low	Strong add-on
71203 Verification	★★☆☆☆	Medium-Low	Medium

Recommended PMA KBLI Configuration

Core: 71101 (Architecture) + 71109 (Engineering General) Value-add: 71202 (Inspection) + 71204 (Testing) — complete full-service package Compliance hedge: 71203 (Verification) + 71209 (Other Testing) — regulatory coverage Optional: 71102 (Industrial) + 71201 (Certification) — add if pipeline justifies

With the reduction of paid-up capital to IDR 2.5B per KBLI (BKPM 5/2025), including multiple codes is more accessible. Each additional KBLI still requires >IDR 10B total investment and appropriate SKK certifications.

2026 Action Plan for Engineering PMA

RDTR GPS validation first: Check https://oss.go.id/rdtr-interaktif before any project commitment
KBLI 71200 migration: Re-map all activities from old 71200 to 71201–71209 by the now-closed June 2026 transition window
SBU renewal: Verify SBU sub-classifications are current with LPJK under KBLI 2025 framework
SKK compliance: Every technical staff member must hold valid SKK for their specialization
IMB retrofit opportunity: Position proactively for the 2026–2028 PBG transition market

Disclaimer: This report is based on normative sources current as of February 2026. UU Jasa Konstruksi requirements and PMA ownership caps require verification against current OSS-RBA system. Independent Indonesian legal counsel required before investment decisions.