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Bali Zero handles visas, company setup, tax and property compliance in Indonesia. Ask us directly on WhatsApp.
Chat with Bali Zero on WhatsAppIndonesia's healthcare sector is fully open to foreign investment under KBLI 2025, with every healthcare code allowing 100% foreign ownership through a PT PMA structure. This includes hospitals, clinics, specialist practices, traditional medicine services, and medical transport. For foreign investors eyeing Bali's booming medical tourism and wellness sectors, or for healthcare professionals looking to establish practices in Indonesia, this represents a clear regulatory pathway.
But "open to foreign investment" does not mean "simple to execute." Healthcare is among the most heavily regulated sectors in Indonesia, with most codes carrying Tinggi (High) or Menengah Tinggi (Medium-High) risk classifications. This translates to extensive licensing requirements, mandatory accreditation timelines, and ongoing compliance obligations that go far beyond the basic NIB registration required for low-risk businesses.
This guide breaks down all 13 healthcare KBLI codes, explains the practical differences between hospital and clinic classifications, clarifies accreditation and licensing requirements, and shows you exactly what foreign ownership means in the context of Indonesian healthcare regulations. The June 2026 KBLI 2025 compliance deadline applies to all businesses, including healthcare operators — if you already hold a medical license under legacy KBLI codes, you need to verify your classification maps correctly to the new system.
If you are new to the KBLI classification system entirely, start with our Beginner's Guide to KBLI 2025 before diving into sector-specific details.
Here is the full breakdown of all healthcare codes under KBLI 2025, organized by service category:
| Code | Name (Bahasa) | Name (EN) | Risk Level | Licensing | Authority |
|---|---|---|---|---|---|
| 86101 | Aktivitas Rumah Sakit Pemerintah | Government Hospital | Tinggi | NIB + Izin | Bupati/Walikota |
| 86102 | Aktivitas Puskesmas | Public Health Center (Puskesmas) | Menengah Tinggi | NIB + Sertifikat Standar | Bupati/Walikota |
| 86103 | Aktivitas Rumah Sakit Swasta | Private Hospital | Tinggi | NIB + Izin | Bupati/Walikota |
| 86104 | Aktivitas Klinik Pemerintah | Government Clinic | Menengah Tinggi | NIB + Sertifikat Standar | Bupati/Walikota |
| 86105 | Aktivitas Klinik Swasta | Private Clinic | Menengah Tinggi | NIB + Sertifikat Standar | Bupati/Walikota |
| 86109 | Aktivitas Rumah Sakit Lainnya | Other Hospital Activities | Tinggi | NIB + Izin | Bupati/Walikota |
| Code | Name (Bahasa) | Name (EN) | Risk Level | Licensing | Authority |
|---|---|---|---|---|---|
| 86201 | Aktivitas Praktik Dokter | General Medical Practice | Menengah Tinggi | NIB + Sertifikat Standar | Bupati/Walikota |
| 86202 | Aktivitas Praktik Dokter Spesialis | Specialist Medical Practice | Menengah Tinggi | NIB + Sertifikat Standar | Bupati/Walikota |
| 86203 | Aktivitas Praktik Dokter Gigi | Dental Practice | Menengah Tinggi | NIB + Sertifikat Standar | Bupati/Walikota |
| Code | Name (Bahasa) | Name (EN) | Risk Level | Licensing | Authority |
|---|---|---|---|---|---|
| 86991 | Aktivitas Pelayanan Kesehatan oleh Tenaga Kesehatan Selain Dokter | Health Services by Non-Doctor Practitioners | Menengah Tinggi | NIB + Sertifikat Standar | Bupati/Walikota |
| 86992 | Aktivitas Pelayanan Kesehatan Tradisional | Traditional Medicine Services | Menengah Tinggi | NIB + Sertifikat Standar | Bupati/Walikota |
| 86993 | Aktivitas Pelayanan Penunjang Kesehatan | Health Support Services (Labs, Blood Banks) | Tinggi | NIB + Izin | Menteri/Badan |
| 86994 | Aktivitas Angkutan Khusus Pengangkutan Orang Sakit | Medical Transport (Ambulance) | Menengah Tinggi | NIB + Sertifikat Standar | Menteri/Badan |
Critical takeaway: All codes allow 100% foreign ownership. But only three codes carry the Tinggi (High) risk classification requiring full Izin permits: hospitals (86101, 86103, 86109) and health support services (86993). The remaining codes sit at Menengah Tinggi (Medium-High), requiring Sertifikat Standar rather than full permits.
Healthcare risk classifications directly determine the depth and duration of your licensing process. Here is what each tier means in practice.
High-risk healthcare businesses require NIB + Izin — a full operational permit issued by the relevant government authority. This is the most rigorous licensing pathway in Indonesia's risk-based system. For hospitals, this means:
For health support services (86993) — which includes blood banks, medical laboratories, and pathology services — the Tinggi classification reflects the critical public health role these facilities play. Labs handling infectious disease diagnostics or blood banks managing donor supplies face rigorous oversight.
Medium-high risk businesses require NIB + Sertifikat Standar — a standards certificate confirming you meet regulatory requirements for your sector. This is less intensive than a full Izin permit, but significantly more demanding than the NIB-only pathway that low-risk businesses enjoy.
For clinics (86104, 86105) and medical practices (86201-86203), this includes:
For traditional medicine (86992), the Sertifikat Standar process includes verification of practitioner certification under Indonesia's traditional medicine framework. Foreign practitioners may face additional hurdles around credential recognition.
One of the most consequential decisions in healthcare business classification is whether your facility registers as a hospital (rumah sakit) or a clinic (klinik). The regulatory burden differs dramatically.
Hospitals are defined by their capacity to provide inpatient care (rawat inap), 24/7 emergency services, and comprehensive medical departments. Under Indonesian regulations, a hospital must:
The accreditation requirement is particularly significant. Hospitals that fail to achieve accreditation within the 2-year window face operational restrictions, fines, and potentially permit revocation. Accreditation is not a formality — it involves extensive external audits of clinical quality, patient safety protocols, staff competencies, and management systems.
Clinics provide outpatient care (rawat jalan) and may offer limited inpatient observation beds, but they do not operate as full-service hospitals. A clinic's regulatory burden is lighter:
The practical consequence: If your business model centers on outpatient services — a general practice clinic, a specialist consultation center, a diagnostic imaging facility — registering under the clinic code (86105 for private clinics) avoids the Tinggi risk classification and the hospital accreditation mandate. This dramatically shortens the licensing timeline and reduces operational compliance costs.
Every healthcare KBLI code allows 100% foreign ownership through a PT PMA structure. This is a clear regulatory statement: Indonesia wants foreign investment in healthcare. But ownership and operational control are not identical concepts in the healthcare sector.
PT PMA capital requirements apply uniformly across all sectors, including healthcare:
For healthcare businesses, these thresholds are on the low end of realistic costs. A private hospital project in Bali typically requires IDR 50-100 billion in total investment (USD 3-6 million) when you account for land, construction, medical equipment, accreditation preparation, and initial staffing. A specialist clinic might run IDR 15-25 billion (USD 1-1.5 million). Traditional medicine practices sit closer to the minimum threshold.
Here is where foreign ownership meets regulatory reality. To practice medicine in Indonesia, you must hold an Indonesian medical license. This applies to doctors, specialists, dentists, nurses, and traditional medicine practitioners.
Foreign medical professionals face a multi-step process:
The practical implication: You can own 100% of a healthcare PT PMA and employ Indonesian doctors to deliver services. But if you, as the foreign owner, want to personally practice medicine, you must go through the Indonesian licensing process. Many foreign investors in Indonesian healthcare operate as business owners and administrators, not as practicing clinicians.
For specialist medical practices (86202), Indonesia has been gradually opening pathways for foreign specialists in high-demand fields — particularly in areas where Indonesia faces domestic shortages. Medical tourism hubs like Bali and Jakarta have seen foreign specialists (especially from Australia, Singapore, and Malaysia) obtain Indonesian practice permits after meeting the credential and competency requirements.
But this remains a complex pathway with significant lead time. If your business model depends on a foreign doctor practicing in Indonesia, budget 12-18 months for the full licensing process, and work with a legal advisor experienced in medical credential recognition.
Bali's healthcare sector is undergoing rapid transformation, driven by medical tourism demand, an aging expat population, and rising domestic healthcare expectations. The opportunities fall into several categories:
Bali's foreign resident population (estimated 50,000-80,000) represents a stable patient base seeking Western-standard medical care. High-demand specialties include:
A specialist clinic under KBLI 86202 or 86203, targeting this demographic with English-speaking practitioners and international insurance billing, avoids the Tinggi risk hospital classification while serving a lucrative market segment.
Indonesia's traditional medicine sector (86992) is enormous — spanning herbal medicine (jamu), traditional massage, acupuncture, and indigenous healing practices. Bali's wellness tourism industry creates a natural overlap between traditional medicine and spa/wellness services.
Key distinction: Therapeutic traditional medicine (86992) is different from spa services (96xxx). A traditional medicine practice involves diagnosis and treatment of health conditions by certified practitioners. A spa offers relaxation and beauty services. The line blurs in integrative wellness centers that combine both, which may need to register multiple KBLI codes.
For foreign investors interested in Bali's wellness sector, the 86992 pathway requires engaging licensed Indonesian traditional medicine practitioners (Penyehat Tradisional) who hold certification from Kementerian Kesehatan. You can own the business; the practitioners deliver the services.
Medical laboratories and diagnostic imaging centers (86993) represent a growing market as healthcare infrastructure expands across Indonesia. These facilities serve both hospitals (which may outsource certain diagnostics) and direct-to-consumer health screening markets.
The Tinggi risk classification reflects the public health importance of accurate diagnostics — a lab misdiagnosing infectious diseases can cause public health emergencies. Expect rigorous inspections, equipment certification requirements, and quality control audits.
Medical transport (86994) covers ambulance services, medical evacuation flights, and patient transfer services. Bali's medical evacuation market is substantial — thousands of tourists and expats require medical evacuation annually, typically to Singapore or Australia for complex procedures.
A medical evacuation business under 86994 requires coordination with hospitals, insurance providers, and international medical transport networks. The Menengah Tinggi risk classification reflects safety requirements for patient transport, but this is significantly less burdensome than operating a hospital.
Many healthcare businesses register multiple KBLI codes to cover different service lines under a single PT PMA. Here are common combinations:
86103 (Private Hospital) + 86202 (Specialist Practice) + 86993 (Lab Services)
A comprehensive medical center might register all three codes — the hospital code for inpatient services, specialist codes for outpatient consultations, and lab codes for diagnostics. This allows the business to bill appropriately for different service types and maintain clarity in regulatory compliance.
86105 (Private Clinic) + 86992 (Traditional Medicine) + 96190 (Spa Services)
An integrative wellness center offering both conventional medicine and traditional healing services would register the clinic code for general medical services, traditional medicine for therapies like acupuncture or herbal treatment, and spa codes (from the 961xx group) for non-medical wellness services.
86910 (Health Intermediation Services) + 86105 (Private Clinic)
A medical tourism facilitator that also operates its own clinic might register both codes — 86910 for arranging patient referrals to other hospitals and 86105 for delivering direct patient care in its own facility.
Healthcare licensing in Indonesia is measured in months, not weeks. Here is a realistic timeline for different healthcare business types.
The accreditation deadline is firm. Plan your hospital project timeline so that you can realistically achieve accreditation standards within the 2-year window. Many foreign hospital operators bring in accreditation consultants during the construction phase to ensure facilities are designed to meet accreditation criteria from day one.
The IDR 10 billion PT PMA minimum investment commitment is legally binding, but it represents only the baseline. Actual healthcare investment costs vary dramatically by business type.
A traditional medicine clinic with 2-3 treatment rooms, herbal pharmacy, and 5-10 staff can launch near the minimum investment threshold. Costs include facility lease/renovation, treatment equipment, inventory of herbs and compounds, and initial working capital.
A specialist clinic (dermatology, dental, orthopedics) requires specialized medical equipment, which drives costs. A dental clinic needs dental chairs, imaging equipment, sterilization systems. A dermatology clinic needs lasers and aesthetic treatment devices. Budget IDR 20-25 billion for a well-equipped specialist clinic.
A clinic offering multiple specialties (internal medicine, pediatrics, obstetrics, diagnostic imaging) under one roof requires larger space, more equipment, and bigger staff. This approaches small hospital scale in cost but avoids the hospital accreditation requirement by focusing on outpatient services only.
A 50-bed hospital in Bali with 24/7 emergency, surgery capabilities, and multiple departments represents a major capital project. Land/construction, medical equipment, information systems, initial inventory, staff recruitment, and accreditation preparation combine to push investment well above the PT PMA minimum.
A 100+ bed hospital with advanced imaging (MRI, CT), intensive care units, specialized surgical suites, and international patient facilities is a large-scale infrastructure project comparable to hotel development in capital intensity.
All healthcare businesses in Indonesia ultimately answer to Kementerian Kesehatan (Ministry of Health), which sets standards for medical practice, facility design, equipment standards, patient safety protocols, and professional licensing.
Regional health offices (Dinas Kesehatan at provincial and district levels) issue most healthcare permits and conduct inspections. But national policies, accreditation standards, and major regulatory changes come from Kementerian Kesehatan.
Key regulatory documents for healthcare operators:
Healthcare is one of the few sectors where reading Indonesian-language regulations is mandatory. Medical facility standards, professional licensing rules, and compliance requirements are not fully translated into English. If you do not have Indonesian-language capacity internally, hire a local healthcare consultant or legal advisor who specializes in health sector regulations.
The KBLI 2025 system became official with BPS Regulation No. 7 of 2025. All businesses in Indonesia — including healthcare operators — must ensure their registered KBLI codes align with the new classification now that the June 2026 transition window has closed.
If you already operate a healthcare facility with KBLI codes from the previous classification system (KBLI 2020), verify your code mapping:
Failing to update now that the June 2026 transition window has closed does not automatically shut down your business, but it creates compliance gaps that can cause problems during inspections, permit renewals, or if you seek to expand operations.
If you are establishing a new healthcare facility, register directly with KBLI 2025 codes. Do not use legacy KBLI 2020 codes — OSS is transitioning to the new system, and outdated codes will be flagged for correction.
Despite the regulatory complexity, Bali represents one of Indonesia's strongest markets for private healthcare investment. Several structural factors drive demand:
Bali's foreign resident population has grown steadily, creating a patient base that seeks international-standard medical care, speaks English, and often holds international insurance that reimburses Indonesian providers at negotiated rates.
Dental tourism, cosmetic procedures, and wellness retreats attract tens of thousands of international patients annually. Bali's cost advantage over Singapore and Australia — combined with its tourism appeal — makes it a natural medical tourism destination.
Indonesia's rising middle class increasingly seeks private healthcare over public facilities. Bali's domestic population of 4.3 million represents a growing market for private clinics and specialist services.
Indonesia's public healthcare system (Puskesmas and government hospitals) operates at or above capacity in many regions. Private healthcare fills gaps in service quality, specialist availability, and patient experience.
The Positive Investment List (PP 28/2025) opening all healthcare codes to 100% foreign ownership is a deliberate policy signal. Indonesia needs healthcare infrastructure investment and is willing to accept foreign capital to accelerate development.
Setting up a healthcare PT PMA in Indonesia involves multiple specialized steps. Here is the sequence:
Bali Zero handles PT PMA formation, NIB processing, and KITAS sponsorship for healthcare business owners. For sector-specific healthcare licensing (facility permits, accreditation consulting, professional credential verification), we work with specialized healthcare consultants. Learn more about PT PMA registration.
For a broader perspective on how KBLI 2025 is reshaping Bali's business landscape, see our KBLI 2025 Bali Transformation guide. For the technical details of PT PMA formation, read our PT PMA Registration Guide.
This analysis is based on KBLI 2025 data (BPS Regulation No. 7 of 2025), the Positive Investment List (PP 5/2021 as amended by PP 28/2025), and Ministry of Health regulations governing healthcare facility licensing in Indonesia. Healthcare regulations change frequently — always verify current requirements through Kementerian Kesehatan, regional Dinas Kesehatan offices, or a licensed healthcare business consultant before making investment decisions.