For years, the first question a foreigner asked about a business in Indonesia was "is it open to foreign ownership?" In Bali, since 13 May 2026, that is the wrong first question. The question that now decides your fate is colder and less intuitive: what risk class does the OSS system assign your activity?
Risk class used to be a back-office detail — it set how much licensing paperwork you'd face. Now it is the gate. Under the Bali moratorium, risk class decides whether you can register at all.
The four classes, and the line that matters
Every KBLI activity in the OSS system is rated, scale by scale, into one of four risk bands. In rising order they are:
- Rendah — low risk
- Menengah Rendah — medium-low risk
- Menengah Tinggi — medium-high risk
- Tinggi — high risk
The Governor's letter (B.27.000/642/PM/DPMPTSP) draws one line through that ladder: it blocks new PMA registration for everything rated low or medium-low (Rendah and Menengah Rendah), island-wide. Above the line — medium-high and high — survives. Below the line — the supposedly "easy," low-paperwork activities — is shut.
So the intuition inverts. The businesses that used to be easiest to license (low risk, automatic NIB, minimal inspection) are now the ones a foreigner cannot have. The ones with heavier risk profiles are the ones that pass.
Why a PT PMA reads the Besar row
There is a crucial mechanical detail. The OSS system rates each activity separately at each business scale — Mikro, Kecil, Menengah, Besar. A PT PMA is, by law, a large-scale (Besar) enterprise. So the only risk row that matters for a foreigner is the one.
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