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Zantara AI
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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 WhatsAppReal estate under KBLI 2025 represents one of the most significant expansions in the entire classification — from 5 codes to 14 codes, with all 14 codes fully open to 100% foreign ownership (PMA). For investors navigating Bali's property market in 2026, understanding which KBLI code governs which activity — and what operational constraints apply — is not optional. It is the difference between a compliant investment and a costly compliance failure.
This guide covers all 14 KBLI 68xxx codes with 2026-specific intelligence: land title structures, the Sarbagita construction moratorium, OSS-RDTR GPS-linked zoning, transaction taxes, broker licensing, and the ongoing digitalization of Indonesian land records.
KBLI 2025 organizes real estate activities into three distinct pillars:
Pillar 1 — Property by the Company's Own Account (68111–68129) The company develops, owns, leases, or manages real estate using its own assets.
Pillar 2 — Real Estate Services / Intermediation (68210) The company acts as a broker or agent facilitating transactions on behalf of others.
Pillar 3 — Fee-Based Real Estate Services (68291–68299) The company provides appraisal, management, or advisory services for a fee.
Understanding this structure is critical for PT PMA registration: each pillar carries different capital requirements, licensing obligations, and operational scope.
Code: 68111 Title: AKTIVITAS PENGEMBANGAN BANGUNAN DAN LAHAN HUNIAN MILIK SENDIRI PMA Status: 100% Foreign Ownership Allowed Activity: Development and sale of residential property (villas, housing complexes, apartments) by the company using its own land and capital.
Market Sentiment: Bali residential development is under intense pressure from the 2026 construction moratorium and OSS-RDTR GPS enforcement. The market is bifurcating: luxury villa compounds in pre-approved zones command premium prices, while speculative development in moratorium-affected districts and on agricultural land faces permit stalls.
Bali Nuance: The 2026 construction moratorium does NOT target the Sarbagita tourist core — that was the cancelled September 2024 proposal. The actual formal ban covers six less-developed districts (Tabanan, Jembrana, Buleleng, Bangli, Karangasem, Klungkung) and explicitly excludes the main tourist zones of Badung, Gianyar, and Denpasar. Separately, a province-wide ban on converting productive agricultural land into commercial development applies everywhere, including the tourist core. Where the RDTR digital layer is integrated into OSS, development applications are validated automatically by GPS coordinate against the zoning map.
Operational Risks:
Investment Outlook: Strong long-term demand for structured villa compounds in Canggu, Seminyak corridor. Near-term entry requires meticulous RDTR coordinate verification and budget for 12–18 month permit processing.
Legacy Bridge (KBLI 2020 → 2025): 68111 in KBLI 2025 is largely equivalent to 68111 in KBLI 2020 for residential development. No code migration required — verify OSS registration reflects the 2025 classification.
Code: 68112 Title: AKTIVITAS PENYEWAAN BANGUNAN DAN LAHAN HUNIAN MILIK SENDIRI PMA Status: 100% Foreign Ownership Allowed Activity: Long-term leasing of residential buildings and land owned by the company.
Market Sentiment: This is the structural code for PT PMA companies that own and lease villa portfolios on long-term contracts (12+ months). Demand from digital nomads and expat families is robust, with occupancy averaging 85%+ in the Canggu/Seminyak corridor. For investors seeking higher returns in the managed accommodation segment, see how Bali aparthotels are hitting 17–20% yields through dual-revenue operating models.
Bali Nuance: 68112 is distinct from 55203 (short-term villa rental/hospitality). If your company leases villas on annual contracts to individuals — without providing hotel-like services — 68112 is the correct code. Mixing 68112 with short-term OTA listings (Airbnb, Booking.com) without also registering 55203 creates a compliance gap.
Operational Risks:
Investment Outlook: Stable, cash-generating model with limited capital appreciation speculation. Best combined with 68111 in a vertically integrated property holding structure.
Legacy Bridge: New granularity in KBLI 2025 — previously grouped under broader 68110. Update OSS registration if your current NIB shows the legacy 2020 code.
Code: 68121 Title: PENGELOLAAN KAWASAN PARIWISATA PMA Status: 100% Foreign Ownership Allowed Activity: Development and management of integrated tourism zones (kawasan pariwisata) — resorts, eco-parks, tourism estates.
Market Sentiment: Kawasan pariwisata development is a high-barrier, high-reward play. Bali's established tourism zones (Nusa Dua, Tanah Lot corridor, Ubud highlands) are constrained by existing concessions; new zones require RTRWP alignment and KLHK environmental clearance.
Bali Nuance: ITDC (Indonesia Tourism Development Corporation) controls access to Nusa Dua zone. Private tourism zone development requires a Kawasan Pariwisata license from the Ministry of Tourism + AMDAL (full environmental impact assessment) for projects above 5 hectares.
Operational Risks:
Investment Outlook: Strategic code for large-scale integrated resort developers. Not suitable for single-villa or small-cluster operations — use 55203 or 68112 for those structures.
Legacy Bridge: Refined from the KBLI 2020 category; ensure your OSS KBLI reference is updated from any 2020-era tourism zone codes.
Code: 68123 Title: PENGELOLAAN KAWASAN EKONOMI KHUSUS PMA Status: 100% Foreign Ownership Allowed Activity: Development and management of Kawasan Ekonomi Khusus (KEK) — special economic zones with tax and regulatory incentives.
Market Sentiment: KEK Sanur (41 hectares, medical tourism focus) is the landmark 2026 development for Bali. KEK operators benefit from tax holidays, simplified licensing, and the ability to employ foreign professionals under relaxed TKA rules.
Bali Nuance: Outside KEK Sanur, Bali does not currently have operational KEK designations. 68123 registration outside an officially designated KEK perimeter creates compliance ambiguity — BKPM has noted that the KBLI can be registered but the KEK-specific benefits only apply within formally gazetted zones.
Operational Risks:
Investment Outlook: High-complexity, high-reward for qualified developers with government relationships. Not a DIY structure — requires experienced legal and regulatory advisors.
Code: 68129 Title: AKTIVITAS REAL ESTAT (BANGUNAN DAN LAHAN) NONHUNIAN MILIK SENDIRI PMA Status: 100% Foreign Ownership Allowed Activity: Leasing of non-residential buildings and land owned by the company — offices, retail spaces, warehouses, event venues.
Market Sentiment: Co-working spaces, creative hubs, and flexible office products are showing the strongest growth in Bali's non-residential leasing market. Traditional long-term office leases are under pressure from remote-work normalization.
Bali Nuance: 68129 is the correct code for companies that own and lease commercial buildings. Do NOT use 68129 for management of third-party commercial properties — that falls under 68299 (fee-based management services).
Operational Risks:
Investment Outlook: Co-working and flex-office in Canggu/Seminyak showing 15–25% YoY rental growth. Event venue leasing tied to MICE growth from Singapore/Australia corporate market.
Code: 68210 Title: AKTIVITAS JASA INTERMEDIASI REAL ESTAT PMA Status: 100% Foreign Ownership Allowed Activity: Real estate brokerage — facilitating property sales, leases, and transfers for a commission.
Market Sentiment: The real estate broker market in Bali is professionalizing rapidly under new licensing requirements. Companies without formal SIU-P4 certification are increasingly shut out of institutional and PMA-to-PMA transactions.
Bali Nuance: SIU-P4 (Surat Izin Usaha Perusahaan Perantara Perdagangan Properti) is mandatory for brokerage companies since PERMEN PUPR 11/2021. Requirements: minimum 2 certified brokers with AREBI (Asosiasi Real Estat Broker Indonesia) credentials + NIK-registered office address.
Operational Risks:
Investment Outlook: Consolidation opportunity — SIU-P4 requirement is filtering out informal brokers. Compliant PT PMA brokerages can capture market share from the informal channel, especially for international buyer segment.
Legacy Bridge: 68210 in KBLI 2025 is equivalent to 68200 in KBLI 2020. Update OSS NIB if still showing 2020 code.
Code 68291: JASA PENAKSIR REAL ESTAT — Real estate valuation/appraisal services Code 68292: PENGELOLAAN REAL ESTAT HUNIAN ATAS DASAR BALAS JASA — Fee-based management of residential properties owned by third parties
68291 — Appraisal:
68292 — Residential Property Management:
Code: 68299 Title: AKTIVITAS REAL ESTAT ATAS DASAR BALAS JASA (FEE) ATAU KONTRAK LAINNYA PMA Status: 100% Foreign Ownership Allowed Activity: All other fee-based real estate services not covered by 68291/68292 — including commercial property management, master-planned community management, strata title management.
Market Sentiment: Strata title management (for apartment complexes and commercial towers) is an emerging segment in Bali as high-rise residential projects in Seminyak and Denpasar enter operational phase.
Operational Risks:
PT PMA can only hold HGB (Hak Guna Bangunan) — the right to build on and use land for a term of years. PT PMA cannot hold Hak Milik (freehold).
| Feature | Hak Milik | HGB |
|---|---|---|
| Who can hold | WNI only | PT PMA allowed |
| Duration | Perpetual | 30 years + 20 year extension + 30 year renewal = 80 years max |
| On expiry | N/A | Must be renewed; reverting to state land is the legal default |
| Transfer | Full alienation | Can be pledged, mortgaged, and transferred within HGB duration |
| Construction | Unlimited | Permitted within HGB term |
Critical: HGB extensions require active application to ATR/BPN before expiry. Automatic renewal does not exist — failure to apply results in the land reverting to the state or original Hak Milik holder.
Most off-plan and high-value property transactions use a two-stage process:
PPJB (Perjanjian Pengikatan Jual Beli) — Preliminary sale agreement executed before a Notaris (notary). No title transfer occurs. Commonly used when: building not yet complete, buyer arranging financing, or parties need a locked transaction while permits are processed.
AJB (Akta Jual Beli) — Final sale deed executed before PPAT (Pejabat Pembuat Akta Tanah — land deed official). Title transfers at this moment. Triggers:
A common misconception is that the "Sarbagita" tourist core (Denpasar, Badung, Gianyar, Tabanan) is under a construction freeze. That was the September 2024 proposal, which was cancelled. The policy has gone through four reversals; the form in force in 2026 is different and is not codified in a single Pergub or Perda — it operates through executive instructions from the Governor's office to district heads, drawing legal backing from SK Menko Marves 163/2024, Perda Bali 2/2023 (RTRWP) and PP 16/2021 (PBG). Two overlapping scopes apply:
Under PP 28/2025, OSS runs two KKPR tracks. Where a location is already covered by an integrated RDTR, the Konfirmasi KKPR (KKKPR) is issued automatically by the OSS system:
Practical implication: Any land acquisition for PT PMA real estate must be preceded by RDTR coordinate verification (GISTARU portal or OSS-RDTR Interaktif) before signing any PPJB — in an integrated-RDTR area a zoning mismatch is rejected instantly, with no negotiation.
As of 2 February 2026, Girik documents (informal customary land documents that pre-date formal BPN certification) have expired as evidence of land ownership. Any land acquisition where the seller presents only Girik — without a BPN Sertifikat — is legally unsafe for PT PMA buyers.
The Sertifikat Elektronik (digital certificate) program is actively replacing paper certificates in Bali. Verify the digital status of any target parcel at the ATR/BPN Bali office before proceeding with PPJB.
| Cost Item | Rate | Paid By | Trigger |
|---|---|---|---|
| BPHTB | 5% of NJOP or transaction value | Buyer | AJB execution |
| PPh Final | 2.5% of gross transaction value | Seller | AJB execution |
| Notary/PPAT fees | 0.5–1.0% | Negotiated | PPJB + AJB |
| PNBP (BPN) | Fixed scale by land value | Buyer | Certificate issuance |
| IMB/PBG retribution | Variable by municipality | Developer | Building permit |
| KBLI 2020 Code | KBLI 2020 Title | KBLI 2025 Code | KBLI 2025 Title |
|---|---|---|---|
| 68110 | Real estat milik sendiri | 68111 / 68112 | Split: pengembangan vs penyewaan hunian |
| 68120 | Real estat bukan milik sendiri | 68121–68129 | Expanded to 7 specific non-hunian codes |
| 68200 | Real estat atas dasar balas jasa | 68210 / 68291 / 68292 / 68299 | Split into intermediasi + 3 fee-based codes |
For villa developers / resort builders (68111):
For villa portfolio operators (68112 + 55203):
For brokerages (68210):
For property management companies (68292 + 68299):
Data sourced from KBLI 2025 (BPS Regulation 7/2025), PP 18/2021 (Hak Atas Tanah), PP 34/2016 (PPh Pengalihan), PERMEN PUPR 11/2021 (SIU-P4), ATR/BPN Regulation on Sertifikat Elektronik. Intelligence accurate as of February 2026. Consult a qualified Indonesian notaris and PPAT before executing any property transaction.