Real Estate in Bali: 68111 Is Closed to New PMA

If there is one sector where foreign capital has poured into Bali fastest, it is property — building, developing, flipping, and renting the very villas and apartments that the rest of this series is about. So it should not be a surprise that property development is one of the 18 business fields Bali's provincial government has actually closed to new PMA licensing — not a threat on the horizon, a decision already in force.

68111: closed, not merely proposed

KBLI 68111 — Aktivitas Pengembangan Bangunan dan Lahan Hunian covers residential building and land development: buying and selling apartment buildings and dwellings, developing houses, flats, and apartments with or without furnishings to be sold or operated. Nationally it is TERBUKA, fully open to foreign ownership at 100% — the "no" here is entirely a Bali-scoped one, not a national restriction. It is also unchanged from the 2020 classification — a direct match — so older references to 68111 describe the same activity.

Its Bali status used to read as a warning: CHIUSO_BALI_PROPOSTO, proposed but not yet applied. That changed. 68111 is one of the 18 named business fields Bali Province closed OSS to new PMA licensing for, from the third week of May 2026, "until further policy," with the approval of the Minister of Investment/BKPM (Bali Provincial Government press release, 24 Jul 2026). Its KBLI-2020 ancestor, 68111, is on that named list (BPS conversion table). The status today is CHIUSO_BALI, HIGH confidence, blocked: true — a settled applied closure, not a candidate for one. That is a different state again from the villa code (55203, reserved for cooperatives/MSMEs) or consulting-adjacent activities Bali closed the same way (70209, also CHIUSO_BALI, effective the same third week of May 2026). 68111 is not in the antechamber anymore — it is on the other side of the door.

For an investor, that is at least an honest state to plan around. "Proposed" used to invite you to race the clock: register now, before the door shuts. There is no race left to run here — the door for a new PT PMA licence on 68111 is shut, and the only structures worth designing are ones that do not depend on it opening again.

Which brings us to the sibling code that stayed on the open side of that same door.

68210: intermediation is open today

KBLI 68210 — Aktivitas Jasa Intermediasi Real Estat (real estate intermediation services) is the brokerage / agency / intermediary side of property: connecting buyers, sellers, landlords, and tenants; managing transactions; acting as the agent rather than the developer-owner. National: open. Bali: not blocked — its risk class at Besar scale runs medium-high to high, so it clears Bali's moratorium reading cleanly, and it is not one of the 18 named applied-closure fields.

The strategic read mirrors the accommodation story almost exactly. Owning and developing the physical asset (68111) is the activity Bali's applied closure actually named, and it is the one that is shut. Acting as the intermediary — the agency, the manager, the transaction facilitator (68210) — keeps your foreign-owned company in the services layer, where the door stays open. Many foreign property businesses in Bali will find that the durable, registrable version of their plan is an intermediation/management company, not a development company.

That is not a consolation prize. The intermediation model carries less land risk, less capital lock-up, and — crucially — no exposure at all to the exact closure that just took 68111 off the table. In a sector where the rules have already tightened once, the business that doesn't own the dirt is the one still standing.

If your heart is set on development specifically, the honest options are narrow: pursue it outside Bali, structure around an existing PMA entity that already held the licence before the closure took effect, or accept that a new PT PMA cannot take 68111 in the province today.

Check the live status of 68111 and 68210 on the Bali Zero KBLI Navigator at balizero.com — the two-branch view states 68111's applied closure explicitly, so you can see whether you're building on a code that's open or one that Bali has already shut.