KBLI 2025 Sports & Entertainment Bali: PMA Guide | Bali Zero

Q: Is the 40–75% entertainment tax in Bali constitutional and does it apply to fitness centers?

The 40–75% PBJT (Pajak Barang dan Jasa Tertentu) under UU HKPD No. 1/2022 was confirmed constitutional by the Constitutional Court (MK No. 32/PUU-XXII/2024) for discotheques, karaoke, nightclubs, bars, and spa/steam baths. Fitness centers (KBLI 93116), adventure tourism (93294), agrotourism (93296), gaming (93293), and sports events (93191) are classified as hiburan umum and subject to a maximum 10% rate only.

Q: What is the best sports or recreation KBLI for a PT PMA in Bali in 2026?

KBLI 93294 (Adventure Tourism) and 93296 (Agrotourism) are the top picks. Adventure tourism covers white water rafting, volcano trekking, waterfall tours, and surf adventures with 15–20% annual growth and government alignment. Agrotourism is uniquely positioned to benefit from Governor Koster's agricultural land construction ban — it monetizes agricultural land without converting it, with $300K–1.5M investment and strong political support.

Q: How does the Sarbagita moratorium affect new sports and recreation facilities in Bali?

The formal moratorium was not approved as a Presidential Instruction, but Governor Koster imposed an effective construction ban on productive agricultural land and precipitation absorption areas in September 2025, with active demolitions underway (48 structures at Bingin Beach). Greenfield development in Denpasar, Badung, Gianyar, and Tabanan is severely constrained in practice. Best options for new facilities: existing structure conversion, Uluwatu, North Bali, or East Bali.

Q: Does the OSS-RDTR GPS system block construction licenses for sports facilities in Bali?

Yes. PP 28/2025 elevated RDTR compliance to a legally blocking requirement in OSS-RBA. Every physical location must be GPS-validated against digital RDTR zoning maps before NIB issuance — if the KBLI activity is incompatible with the zone, the NIB is automatically blocked with no administrative discretion. Check the interactive RDTR tool at oss.go.id/rdtr-interaktif before committing to any site.

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Bali's sports and recreation sector in 2026 presents a deeply polarized investment landscape. Wellness tourism, digital nomad fitness, eco-adventure tourism, and agrotourism enjoy strong alignment with the provincial government's quality tourism strategy and are classified as highly positive for PMA investment. On the other side, the nightlife entertainment sector (discotheques, karaoke, clubs) faces a multi-front regulatory assault: punitive 40–75% entertainment taxation, political pressure from Governor Koster, and growing national halal agenda tension.

Cross-Sector Regulatory Framework

Sarbagita Moratorium: 2026 Status

The formal construction moratorium proposed in September 2024 for the Sarbagita area (Denpasar, Badung, Gianyar, Tabanan) was not approved as a Presidential Instruction. Governor Wayan Koster (inaugurated January 2025) declared: "there is no need for a moratorium, what is needed is strict supervision."

However, in September 2025, following severe floods, Koster imposed an effective construction ban on productive agricultural land and precipitation absorption areas, with direct instructions to all Regency Heads (Bupati) and Mayors (Walikota). Active demolitions are underway: 48 illegal structures demolished at Bingin Beach (Uluwatu), non-compliant structures being scaled down in Jimbaran.

Practical impact: Greenfield development for entertainment and sports facilities in South Bali is severely constrained in practice, even without a formal moratorium. Investment options focus on existing structure conversion, North Bali, or East Bali.

Entertainment Tax 40–75% (Pajak Hiburan)

UU HKPD No. 1/2022 (Pasal 58 ayat 2) establishes a PBJT (Pajak Barang dan Jasa Tertentu) of 40% to 75% for five specific categories:

Diskotek
Karaoke
Kelab Malam (nightclubs)
Bar
Spa/mandi uap

The rate is determined by each local government (pemda). PP No. 35/2023 (Art. 99-100) allows operators to request fiscal incentives (reduction, exemption, deferral) — either on application or at the initiative of the Regional Head. A Constitutional Court (MK) judicial review was filed in February 2024 by karaoke operators — monitor for potential outcomes.

Codes affected: 93291 (diskotek/dancefloor), 93292 (karaoke). Codes NOT affected (hiburan umum, max 10% PBJT): 93116, 93127, 93191, 93210, 93293, 93294, 93296, 93299.

Positive Investment List & PMA

Under Perpres 10/2021 (amended by Perpres 49/2021), all sectors are open to 100% foreign investment unless explicitly restricted. KBLI 93 (sports and recreation) codes do not appear in restricted or reserved sector annexes, making them generally accessible for 100% PT PMA.

However, micro and small-scale operations remain reserved for Indonesian UMKM. A PT PMA must structurally operate as a "large enterprise" with minimum IDR 10 billion investment and full corporate governance compliance — directing foreign investors toward significant-scale structures: premium gyms, sports resorts, integrated complexes.

OSS-RDTR GPS: Mandatory Geospatial Validation

PP 28/2025 has elevated RDTR compliance to a legally blocking requirement in the OSS-RBA system. Every physical location for a sport/recreation facility must be GPS-validated against digital RDTR zoning maps before NIB issuance. Non-compliance = automatic NIB block. Check: https://oss.go.id/rdtr-interaktif

KBLI 93116 — Fitness Center

Sentiment: Very Positive ★★★★★

The fitness center is the most aligned KBLI with Bali's 2026 quality tourism strategy. Provincial government explicitly targets digital nomads and wellness tourists as priority visitor segments. Premium hybrid gym+co-working+café model commands IDR 1.5–5M/month memberships.

Market dynamics by location:

Area	Status	Investment Recommendation
Canggu	Saturated — rising land costs, new entrant ROI declining	Avoid unless premium differentiation
Uluwatu	Emerging frontier — lower competition, growing fast	Best opportunity 2026
Seminyak	Mature, stable	Acquisition of existing over greenfield
Ubud	Strong yoga-fitness integration	Premium wellness positioning
Sanur	Underserved — KEK Sanur expansion driving demand	Good opportunity

Not subject to 40–75% entertainment tax. Target market: E33G KITAS and B211A visa holders. RDTR GPS check mandatory. Agricultural land conversion ban limits rural site selection.

KBLI 93122 — Golf Club

Sentiment: Stable Niche ★★☆☆☆

Mature market with few consolidated operators (Bali National, New Kuta Golf, Handara). Required land (50–80 ha) virtually unavailable in the Sarbagita zone post Koster ban. High water consumption creates tension with the subak irrigation system (UNESCO heritage).

Investment outlook: Cautious. Greenfield almost impossible in South Bali. Only viable via acquisition of existing structures or development in North Bali. Capital requirements >$10M.

KBLI 93127 — Fitness & Bodybuilding Club

Sentiment: Positive ★★★☆☆

Significant overlap with 93116 — code choice depends on primary offering (bodybuilding/binaraga focus → 93127). Bali market favors boutique gym model with specialized classes (CrossFit, Muay Thai, calisthenics).

Additional risk: mandatory halal certification from October 2026 for supplements and sports nutrition sold on premises. Imported equipment subject to import duties.

KBLI 93191 — Sports Event Organization

Sentiment: Strongly Growing ★★★★☆

Bali hosts an increasing number of international sports events generating significant economic multipliers:

Event	Location	Notes
WSL Surf Championship Tour	Uluwatu	Consolidated commercial asset
Ironman 70.3	Regional	Established international profile
Bali Marathon	Regional	Growing international participation
Yoga Festivals	Ubud	Thousands of international participants annually
Ultra-trail running	Ubud rice fields	Niche but growing fast

Revenue model: sponsorship + ticket sales + media rights. Complex permitting: coordination with police, PHRI, Dinas Pariwisata, and local banjar. Weather risk in wet season (Nov–Mar). 15–20% annual growth in sports-tourism events segment.

KBLI 93210 — Theme Parks & Amusement Facilities

Sentiment: Moderate ★★☆☆☆

Waterbom Bali (Kuta) is the established benchmark — operational for decades with solid revenue. New developments must differentiate: eco-adventure or cultural theme park model. Sarbagita zone nearly saturated; North Bali or East Bali more viable for greenfield.

Critical: AMDAL (environmental impact assessment) mandatory for large structures. Investment >$5M required with 5–7 year ROI horizon.

KBLI 93291 — Discotheque with Dancefloor

Sentiment: Negative / Under Pressure ★☆☆☆☆

Most impacted code by the 40–75% PBJT entertainment tax. Bali's nightlife (Seminyak, Kuta, Canggu) is a fundamental tourism asset but under simultaneous regulatory pressure:

PBJT 40–75% compresses margins severely
Governor Koster actively targeting structures that "lower the island's energy"
Active demolitions of non-compliant structures (48 buildings at Bingin Beach)
Beach club/disco hybrids in dangerous regulatory grey zone
National halal agenda creates additional normative tension

Fiscal incentive application possible (PP 35/2023 Art. 99–100) but bureaucratic. MK judicial review pending (Feb 2024). Not recommended for new PMA entry in 2026.

KBLI 93292 — Karaoke Facility

Sentiment: Negative ★☆☆☆☆

Same 40–75% PBJT pressure as discotheques. Inul Daratista's emblematic public protest brought the issue to national media prominence. Constitutional Court petition pending. Standalone karaoke in Bali is a high-risk investment. Only viable model: integrated within existing hospitality structures (hotel karaoke rooms).

KBLI 93293 — Gaming / Arcade Arena

Sentiment: Moderately Positive ★★★☆☆

Traditional arcade declining but e-sports and gaming lounges growing strongly. Indonesia is a top-5 global gaming market by mobile users. Bali attracts gaming/e-sports community among digital nomads.

Critical distinction: NOT subject to 40–75% PBJT — classified as hiburan umum (max 10%). Must clearly be entertainment, not gambling (illegal in Indonesia). E-sports lounge + café in Canggu has strong first-mover potential. Initial investment $100–300K.

KBLI 93294 — Adventure Tourism (Caves, Hot Springs, Nature Adventure)

Sentiment: Very Positive ★★★★★

Eco-adventure tourism is one of Bali's fastest-growing segments, perfectly aligned with the 2026 government quality tourism strategy. Strong international demand with 15–20% annual growth.

Bali's natural adventure assets:

Activity	Location	Commercial Maturity
White water rafting	Ayung River (Ubud)	Mature, high revenue
Volcano trekking	Mt. Agung, Mt. Batur (Kintamani)	Growing fast
Waterfall tours	Nungnung, Gitgit, Sekumpul	Popular, expandable
Hot springs	Banjar (North Bali), Toya Bungkah	Underdeveloped
Cave exploration	Regional	Niche, low competition
Surf adventure	Uluwatu, Canggu	Major commercial asset

Note on surf: No dedicated surf KBLI code exists — typically classified under 93294, 93191, or 93299 depending on primary activity.

Investment recommendation: Very favorable. $200K–1M initial investment. Eco-lodge + adventure integrated model commands premium pricing. Rapid 2–3 year ROI. Essential: coordination with local desa adat communities for natural site access.

KBLI 93296 — Agrotourism

Sentiment: Very Positive with Strong Political Alignment ★★★★★

Agrotourism is the only land-use model that benefits directly from the Sarbagita moratorium. Governor Koster's ban on productive agricultural land construction paradoxically makes agrotourism the primary way to monetize agricultural land without converting it.

Ubud epicenter assets:

Tegallalang rice terraces — iconic globally
Kintamani coffee plantations — luwak coffee tours
Subak irrigation system — UNESCO World Heritage
Organic farm-to-table restaurant potential

North Bali opportunities: vanilla, cacao, clove farming in Buleleng and Jembrana.

Investment model: agro-lodge + educational tours + farm-to-table restaurant. $300K–1.5M investment. Recommended areas: Ubud/Tegallalang, Kintamani, Pupuan (Tabanan), Sidemen (Karangasem).

Key requirement: genuine partnership with local farmers (petani) and subak community — not tokenistic, but revenue-sharing. Neo-colonial approach is a serious reputational risk. Mandatory halal certification for food products sold on premises by October 2026.

KBLI 93299 — Other Recreation & Entertainment Activities (YTDL)

Sentiment: Neutral-Positive ★★★☆☆

Flexible catch-all code covering: escape rooms, trampoline parks, cooking classes, batik workshops, daytime beach clubs (without nightlife classification), hybrid wellness retreats.

Primary risk: fiscal reclassification. If local tax authorities determine the activity is effectively a discotheque/karaoke/bar, the 40–75% PBJT applies retroactively. Beach clubs are the most dangerous grey area. Obtain written tax advisory from local Dinas Pendapatan on applicable PBJT classification before launching.

PMA Risk-Opportunity Matrix

KBLI	Sentiment	Entertainment Tax	Moratorium Impact	PMA 100%	Bali Priority
93116 Fitness	Very Positive	Low (10%)	Medium	✅	⭐⭐⭐⭐⭐
93122 Golf	Stable	Low	High	✅	⭐
93127 Bodybuilding	Positive	Low (10%)	Medium	✅	⭐⭐⭐
93191 Sports Events	Strong Growth	Low (10%)	Low	✅	⭐⭐⭐⭐
93210 Theme Park	Moderate	Low (10%)	High	✅	⭐⭐

*PMA permitted but regulatory environment hostile.

Strategic Recommendations

Tier 1 — Highest Priority for PMA in 2026

93294 (Adventure Tourism): strong government alignment, low tax burden, Bali's natural assets are unmatched, rapid ROI
93296 (Agrotourism): unique political alignment with moratorium, UNESCO subak heritage, farm-to-table premium model
93116 (Fitness Center): proven demand from digital nomad community, no entertainment tax, Uluwatu early-stage opportunity

Tier 2 — Solid Opportunities

93191 (Sports Events): WSL/Ironman/marathon ecosystem, growing B2B sponsorship market
93293 (Gaming/E-sports): first-mover in Bali, low investment, no punitive tax

Avoid in 2026

93291 (Discotek) and 93292 (Karaoke): punitive 40–75% tax + political pressure + moratorium = hostile environment for new PMA entry

2026 Compliance Checklist

RDTR GPS validation before any site commitment: https://oss.go.id/rdtr-interaktif
KBLI 2025 code mapping: verify 2020→2025 for any existing operations before new OSS registration
PBJT classification advisory: for any code with F&B or entertainment component, get written confirmation from Dinas Pendapatan
Halal compliance plan: F&B components at any facility need certification or explicit "non-halal" declaration by October 2026
Agricultural land check: Governor Koster's 2025 ban on building on productive agricultural land — verify site classification before acquisition

Disclaimer: This report is based on normative sources current as of February 2026. PMA ownership status and tax rates require verification with local authorities. Independent Indonesian legal and tax counsel required before investment decisions.