KBLI 2025 Health & Wellness Investment Guide: Medical Tourism, Private Clinics & Wellness Retreats in Bali

Bali's health and wellness sector is undergoing its most significant transformation in a generation. Two forces are converging: UU Kesehatan 17/2023 (the comprehensive Health Law that revokes 11 prior laws and restructures the entire regulatory framework) and KEK Sanur (the 41-hectare medical tourism special economic zone). Together, they are opening Indonesia's healthcare market to foreign investment at a level previously unavailable.

For PT PMA investors, the timing is critical. The KBLI 2025 transition window has closed. And the October 2026 Halal certification mandate will hit every cosmetics, traditional medicine, and OTC product used in Bali's 3,000+ wellness businesses. This guide covers all relevant KBLI 86xxx codes plus supporting codes 74910 (IP brokerage) and 96120 (beauty/salon services) with actionable 2026 investment intelligence.

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The Bali Wellness Market: 2026 Landscape

Medical Tourism: Growing 15–20% YoY. Key feeder markets: Singapore, Australia, Japan, Europe. Main drivers: competitive pricing (50–70% below Singapore/Australia for equivalent quality), improving international accreditation (JCI, KARS), and Bali's lifestyle appeal for post-treatment recovery.

Wellness Tourism: Growing 20–25% YoY. Traditional Balinese healing (melukat, traditional massage, jamu), yoga retreats, and integrated wellness programs are Bali's strongest experiential differentiator globally.

Regulatory window: UU 17/2023 removed the IDI (Indonesian Medical Association) endorsement requirement that previously blocked foreign specialist applications. For the first time, PT PMA health companies can recruit foreign medical professionals via a streamlined KKI (Konsil Kedokteran Indonesia) process.

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KEK Sanur: The Medical Tourism Special Zone

Location: Sanur, Denpasar Selatan Area: 41 hectares Focus: Medical tourism, international hospital development, pharmaceutical manufacturing, medical devices, health R&D

Key KEZ advantages under PP 24/2022:

• Tax holiday: 5–20 years depending on investment scale and sector
• 100% foreign ownership (PT PMA) fully permitted
• Simplified licensing: one-stop via KEK management body (BUPP)
• Relaxed TKA: foreign medical professionals may practice for up to 2 years under supervised arrangement without full KKI equivalency process
• Import duty exemptions on medical equipment and supplies

Entry requirements for KEK Sanur:

• Investment commitment letter to KPPIP
• Business plan approved by KEK management
• Environmental compliance pre-assessment
• IDR 20B minimum investment for hospital development (varies by activity type)

Practical note: Non-KEK health investments outside Sanur follow standard BKPM Reg. 5/2025 requirements: IDR 2.5B paid-up + IDR 10B total investment per KBLI code.

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KBLI 86103: Private Hospital (Rumah Sakit Swasta)

Code: 86103 Title: AKTIVITAS RUMAH SAKIT SWASTA PMA Status: 100% Foreign Ownership Allowed (especially within KEK Sanur) Activity: Development and operation of private hospitals providing inpatient and outpatient medical services.

2026 Investment Intelligence

Market Sentiment: Private hospital development is booming. International benchmarks BIMC Nusa Dua and Kasih Ibu are expanding. The KEK Sanur anchor hospital (rumored to involve a Singapore Group) will set the new quality standard for the island.

Bali Nuance: KEK Sanur is the preferred entry point for premium international hospital PT PMA. Outside KEK, Badung and Seminyak/Kuta hospital zoning is available but faces competition from established players. Ubud highlands (wellness-oriented hospital concept) is an underserved premium niche.

Operational Risks:

• UU Kesehatan 17/2023 Section 4: all hospitals must register with Sistem Informasi Rumah Sakit (SIRS) national database within 90 days of operational license
• BPJS Kesehatan accreditation (KARS Level Paripurna minimum) required to receive BPJS patient flow — without it, hospital is limited to self-pay patients
• Foreign doctors: STR (Surat Tanda Registrasi) + SIP (Surat Izin Praktik) from KKI are mandatory even under KEK simplified rules — allow 3–6 months for KKI processing
• Halal certification mandatory from October 2026 for all pharmaceutical products, food/beverage, and OTC products used in hospital premises (BPJPH PP 39/2021)
• Medical waste: Permen LHK 56/2015 requires licensed medical waste transporter + TPS B3 temporary storage facility with Dinas Lingkungan Hidup approval

Investment Outlook: Strong 5–10 year ROI for international standard hospital with JCI accreditation + medical tourism focus. Target: 200+ beds, specialist-led, English-speaking clinical staff.

Code Note: Use 86103 (Rumah Sakit Swasta) for PT PMA hospital investment. 86101 (Rumah Sakit Pemerintah) is government-owned and not available for PT PMA.

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KBLI 86105: Private Clinic (Klinik Swasta)

Code: 86105 Title: AKTIVITAS KLINIK SWASTA PMA Status: 100% Foreign Ownership Allowed Activity: Operation of private outpatient clinics providing medical consultation, treatment, and minor procedures.

2026 Investment Intelligence

Market Sentiment: Private clinics are the most accessible PT PMA entry into Bali's health sector. Setup cost IDR 500M–IDR 2B; payback 18–24 months in premium tourist zones. Aesthetic medicine (botox, dermal fillers, laser) is the highest-margin subspecialty.

Bali Nuance: Canggu, Seminyak, and Ubud have active clinic clusters with 85%+ occupancy serving expats, digital nomads, and wellness tourists. Key winning differentiators: 24/7 emergency service, English-speaking staff, international insurance acceptance, telemedicine follow-up.

Licensing Path:

1. NIB from OSS (KBLI 86105)
2. Surat Izin Operasional Klinik from Dinas Kesehatan Kabupaten/Kota (not issued through OSS — requires physical inspection)
3. Minimum staff: 1 licensed doctor on premises during operating hours (dokter penanggung jawab)
4. Medical waste disposal contract with licensed transporter
5. Annual renewal from Dinas Kesehatan

Operational Risks:

• Aesthetic procedures using imported medical devices require BPOM Alkes (alat kesehatan) registration — each device type requires separate registration, process 3–6 months
• Foreign doctors: KKI STR process for non-ASEAN doctors is 3–6 months minimum; "visiting specialist" arrangement available under UU 17/2023 for up to 6 months initially
• BPJS participation: optional but recommended for local patient market — significantly expands patient base
• Permenkes 9/2014 updated under UU 17/2023 sets minimum facility standards (examination room dimensions, sterilization equipment, emergency equipment list)

Investment Outlook: Aesthetic medicine clinics and sports medicine practices in Canggu/Seminyak are generating USD 50K–USD 200K monthly revenue. Dental specialty clinics with panoramic X-ray and implant capabilities show 24-month breakeven in high-tourist zones.

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KBLI 86201 & 86202: Specialist Medical Practice

Code 86201: AKTIVITAS PRAKTIK DOKTER — General medical practice Code 86202: AKTIVITAS PRAKTIK DOKTER SPESIALIS — Specialist medical practice PMA Status: 100% Foreign Ownership Allowed (via PT PMA with Indonesian doctor on record)

2026 Investment Intelligence

86201 — General Practice: Bali's 300,000+ long-term foreign residents + 15M+ annual tourists generate consistent demand for English-speaking GPs. Expat-focused general practice clinics (Canggu Health Center model) serve as primary care anchors for the foreign community.

Key compliance note: The "dokter penanggung jawab" (responsible doctor on the SIP) must hold an Indonesian KKI license. For PT PMA structures: the Indonesian director/local partner holds the SIP; foreign GPs practice under supervised arrangement pending their own KKI registration.

86202 — Specialist Practice: The UU 17/2023 change that removed IDI endorsement for foreign specialists is the 2026 game-changer. Previously, a foreign cardiologist, orthopedic surgeon, or dermatologist needed IDI organizational approval (which was discretionary and politicized). Now, KKI directly evaluates the credential equivalency — the process is procedural, not political.

KEK Sanur advantage for specialists: Under PP 24/2022, specialist doctors in KEK Sanur can practice for 2 years under simplified arrangement while their full KKI STR application is processed. This enables immediate deployment of international specialists.

High-demand specialties in Bali (2026):

1. Orthopedics/Sports Medicine (surf/dive injury volume)
2. Dermatology/Aesthetic Medicine (cosmetic demand + skin cancer screening for sun-exposed tourists)
3. Cardiology (medical tourism from Southeast Asia)
4. Oncology (KEK Sanur medical tourism target)
5. Ophthalmology (LASIK, cataract — significant cross-border patient flow)

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KBLI 86992: Traditional Health Services (Jamu & Balinese Wellness)

Code: 86992 Title: AKTIVITAS PELAYANAN KESEHATAN TRADISIONAL PMA Status: 100% Foreign Ownership Allowed Activity: Traditional medicine, herbal health services, Balinese healing practices, jamu production and service.

2026 Investment Intelligence

Market Sentiment: Traditional wellness is Bali's most differentiated global offering. Melukat (Balinese purification ritual), traditional boreh (herbal body wrap), and jamu therapy align with global "authentic wellness" trends driving premium pricing.

Bali Nuance: The distinction matters — 86992 covers traditional and herbal health services; 86995 covers massage/spa; 96120 covers beauty salons. Integrated wellness retreats typically need a combination of 55203 (villa accommodation) + 86992 (traditional wellness) + 86995 (massage) in their NIB.

October 2026 Halal Mandate — Critical for Wellness: BPJPH PP 39/2021 mandates Halal certification by October 2026 for:

• All jamu and traditional herbal products
• Cosmetics and personal care products used commercially
• OTC medicines (obat bebas/obat bebas terbatas)

Practical impact: 3,000+ Bali wellness businesses must certify their product supply chain before the deadline. Non-certified products cannot legally be used in commercial services. Certification path: BPJPH registration + MUI (Majelis Ulama Indonesia) Halal audit + certificate issuance (typically 3–6 months; priority track available for small businesses).

Practitioner Requirements:

• STPT (Surat Tanda Pendaftaran Tenaga Penyehat Tradisional) from Dinas Kesehatan for traditional health practitioners
• BPOM registration required for any manufactured jamu products (not required for immediate-service preparations)

Investment Outlook: Premium integrated Balinese wellness retreat (86992 + 55203) generating USD 200–USD 800/night is among the highest-EBITDA models in Bali hospitality. Target market: 3–7 day "wellness immersion" programs for European and Australian clients.

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KBLI 86995: Spa & Massage Establishments (Rumah Pijat)

Code: 86995 Title: AKTIVITAS RUMAH PIJAT PMA Status: 100% Foreign Ownership Allowed Activity: Dedicated spa and massage establishments offering therapeutic and relaxation massage, body treatments.

2026 Investment Intelligence

Market Sentiment: Bali's spa industry is consolidating from 5,000+ fragmented operators toward branded concepts. Premium international spa brands command 10–15x pricing over street-level operators. The market is bifurcating: ultra-premium retreat spa vs. high-frequency "express" spa for tourists.

Bali Nuance: Standalone day spa/massage centers use 86995. Hotel spa operations integrated into a villa or resort register under the hotel's primary code (55203, 55101). Mixing these is a common error that creates licensing gaps.

Operational Risks:

• Therapist certification: BNSP (Badan Nasional Sertifikasi Profesi) competency certificate required for massage therapists per Permenaker 2/2016
• Hiburan tax exposure: Badung and Gianyar classify massage services as "hiburan" (entertainment) in some zones → 10–15% gross revenue hiburan tax in addition to standard PPN/PPh
• Halal certification October 2026: all aromatherapy oils, scrubs, body wraps, and cosmetic products used in services must be Halal-certified
• BPOM import license required for commercially-used non-ASEAN cosmetic/aromatic products

Facility Requirements: Permenkes on spa facilities (updated under UU 17/2023 implementing regulations) specifies: minimum room dimensions, ventilation, sterilization equipment, water quality standards.

Investment Outlook:

• Budget spa chain (IDR 200M setup): 12–18 month payback in tourist zones
• Premium concept (IDR 1B–IDR 2B setup): 24–36 month payback; significantly higher LTV per client
• Franchise model (under Indonesian brands or international concepts): lower risk, faster ramp

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KBLI 86910: Health Intermediation Services

Code: 86910 Title: AKTIVITAS JASA INTERMEDIASI UNTUK KESEHATAN MEDIS PMA Status: 100% Foreign Ownership Allowed Activity: Health coordination services — international insurance case management, medical evacuation coordination, patient referral management, third-party health plan administration.

2026 Investment Intelligence

Market Sentiment: Bali's 300,000+ long-term foreign residents, each with international health insurance, generate a significant case management market. Medical evacuation coordination (Singapore/Australia referrals) and international insurance pre-authorization are the primary service lines.

Bali Nuance: 86910 is new in KBLI 2025 — these activities were previously unclassified. Companies providing international health coordination services (managing expat health claims, arranging medical tourism packages) now have a proper KBLI code.

Key market players: SOS International, BUPA partnerships, and boutique health concierge companies targeting the villa/retreat segment.

Operational Risks:

• OJK coordination required if activities include insurance premium collection or product distribution — the boundary between "health coordination" and "insurance product" is under active regulatory review
• UU 17/2023 implementing regulations on health intermediaries are still being issued — monitor for new Permenkes requirements

Investment Outlook: High-margin, low-capex model. USD 5,000–USD 20,000 monthly retainer model for corporate clients with Bali-based operations.

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KBLI 96120: Beauty Salons & Nail Services

Code: 96120 Title: AKTIVITAS SALON KECANTIKAN PMA Status: 100% Foreign Ownership Allowed Activity: Hair salons, nail salons, beauty treatment centers (non-medical aesthetic).

2026 Investment Intelligence

Market Sentiment: Beauty salon market is high-frequency, high-repeat — one of Bali's most stable small business segments. Premium international concepts (blow-dry bars, nail art studios, Korean beauty salons) are showing 20%+ market growth.

Bali Nuance: 96120 is the correct code for non-medical beauty services. Medical aesthetic procedures (botox, chemical peels, laser) require 86105 (klinik swasta) + licensed doctor. Mixing medical aesthetics and beauty services under 96120 creates regulatory exposure.

October 2026 Halal Mandate — Specific Impact: All commercial cosmetics used in salon services must be Halal-certified by October 2026:

• Hair dyes (cat rambut)
• Nail polish and gel systems
• Skin care products used in facials
• Waxing and hair removal products

This will require all salons to audit their product suppliers for BPJPH certification status.

Operational Risks:

• BNSP competency certificates: hairdressers and nail technicians require BNSP certification
• Badung/Gianyar hiburan tax: some beauty services in resort zones classified as entertainment
• BPOM: import of non-ASEAN professional cosmetics for commercial use requires Alkes/Cosmed registration

Investment Outlook:

• Budget salon (IDR 100M–IDR 200M): 6–12 month payback in tourist density areas
• Premium concept salon (IDR 300M–IDR 800M): 12–18 month payback
• Salon franchise: lowest-risk entry, national brand support

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KBLI 74910: Patent Brokerage & IP Marketing (Health Sector)

Code: 74910 Title: AKTIVITAS BROKER DAN LAYANAN PEMASARAN PATEN PMA Status: 100% Foreign Ownership Allowed Activity: Brokerage and marketing services for patents, trademarks, and other intellectual property rights.

2026 Investment Intelligence

Health Sector Relevance: 74910 supports wellness companies commercializing proprietary traditional formulas, branded treatment protocols, or Balinese cultural wellness IP.

Bali Nuance: Traditional Balinese recipes (jamu formulas, boreh recipes, ritual practices) are increasingly being commercialized internationally. A PT PMA using 74910 can legitimately broker these IP rights to international wellness brands — provided proper community consent (FPIC — Free, Prior, and Informed Consent) and DJHKI registration are in place.

Operational Risks:

• DJHKI registration required for all IP being brokered
• Balinese cultural IP: Bali Provincial Regulation on cultural protection may apply — community consultation is legally and reputationally prudent
• Indonesia does not yet have a comprehensive traditional knowledge protection law, but international treaties (CBD, Nagoya Protocol) apply to biogenetic resources

Investment Outlook: Niche, high-margin supporting code. Best used as secondary KBLI for wellness companies with proprietary IP assets.

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Critical 2026 Regulatory Checkpoints

UU Kesehatan 17/2023 — Key Changes for Investors

KEK Sanur — Benefits Summary

October 2026 Halal Deadline — Action Plan

All Bali health and wellness businesses must complete by October 17, 2026:

1. Inventory audit: List all products used commercially (cosmetics, traditional medicines, OTC drugs, food/beverages)
2. Supplier check: Verify which suppliers already have BPJPH Halal certification
3. Product substitution: Replace non-certifiable products with Halal-certified alternatives
4. BPJPH registration: Submit products that can be certified
5. Documentation: Maintain Halal compliance records for future audits

Non-compliance: Post-deadline, using non-certified products in commercial services exposes businesses to Dinas Kesehatan closure orders and BPOM administrative penalties.

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KBLI 2020 → 2025 Migration for Health Sector

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Strategic Entry Matrix for PT PMA Health/Wellness in Bali

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Data sourced from UU Kesehatan 17/2023, PP 24/2022 (KEK), BPJPH PP 39/2021 (Halal), BKPM Reg. 5/2025, Permenkes 9/2014 (updated), KKI regulations, Permen LHK 56/2015. Intelligence accurate as of February 2026. Consult a licensed Indonesian health law firm before commencing any health sector PT PMA operation.