The Honest Map: Which Bali Business Codes Are Actually Closed to PMA

This whole series has shown you locked doors one at a time — the villa, the café, the minimarket, the consulting firm. This final article steps back and counts them. How much of the Bali business map is actually closed to foreign investment? Not as a slogan, but as a number you can audit — and, this time, a number we got wrong once already and are correcting in public.

So we counted. And because the honest thing to do is show our work, here is exactly what we measured, what changed since we last published this count, and why.

The method

We took the cleaned 2025 classification dataset — the same ground-truth file every article in this series looked up codes against — and counted, mechanically, every code carrying a Bali-status verdict. The dataset holds 1,559 classified codes, each tagged with whether a foreign-owned PT PMA can register it in Bali today: a blocked: true / false flag derived from the code's national ownership status and, separately, from Bali's own applied 2026 closure — not from the risk tier alone.

The count is not a vibe. It is a filter over a file.

The number

Of 1,559 classified KBLI codes, 135 are closed to a new PT PMA in Bali today. That is 8.7%.

Five different kinds of "no" make up that 135 —

• 72 — closed by an ownership restriction on the activity itself (TERTUTUP): 66 of them carry 0% foreign ownership in the national catalogue outright — Bali adds nothing here, they were never open to a PT PMA anywhere in Indonesia. The other 6 show 100% in that same ownership field, and are closed by a rule on the activity rather than by the cap: 69102 legal services (reserved to Indonesian-licensed advocates, UU 18/2003), 69104 notary (a personal office for Indonesian citizens, UU 30/2004 as amended by UU 2/2014), 86201 and 86202 solo general and specialist medical practice (Ministry of Health rules). For 01111 staple-crop agriculture and 47112 minimarkets/supermarkets our data records the reservation without naming the instrument — treat both as closed, and confirm the basis on OSS before you rely on it.
• 40 — closed by Bali itself (CHIUSO_BALI): from the third week of May 2026, Bali Province closed OSS to new PMA licensing in 18 named business fields (KBLI 2020 numbering), "until further policy," with the approval of the Minister of Investment/BKPM (Bali Provincial Government press release, 24 Jul 2026). Mapped to KBLI 2025 through the BPS conversion table, those 18 fields land on 40 of today's codes — six of them hotel codes, 55101 through 55106, and only for buildings under 6,000 m². The code list itself is as reported by ANTARA Bali, 23 Jul 2026.
• 14 — held pending verification: blocked in our data on grounds we cannot yet stand behind at the individual-code level — a moratorium note that does not name the code, a scope that is not settled, or a Bali closure that is still only proposed. Treat as blocked until confirmed live.
• 7 — reserved for cooperatives and MSMEs (CHIUSO_PMA_NO_BESAR): allocated in Annex II of Perpres 10/2021 as amended by 49/2021, so a PT PMA cannot take the bidang usaha at all, at any scale.
• 2 — closed by their own sector regulator: a licensing authority outside OSS/BKPM already excludes foreign ownership from the activity.

That is the whole 135: 72 + 40 + 14 + 7 + 2. Not all 135 rest on the same footing: 106 carry HIGH confidence in our data. The other 29 are a conservative reading we applied ourselves — 16 of the 40 "closed by Bali itself" codes, where the 2025 code merges several 2020 activities and only some of them are on the 18-field list; 12 of the 14 "held pending verification"; and 1 nationally closed code whose verdict is still provisional. Treat those 29 as blocked until you confirm the individual code, not as settled law.

What still needs checking before you file

A much larger group — 383 codes — carries a warning, not a closure. In January 2026, Bali's Governor asked BKPM, by letter, to close OSS to every low- and medium-low-risk PMA activity in the province. That request was never enacted as a blanket rule: the closure Bali actually applied names 18 specific business fields, not a risk tier. These 383 codes sit in that gap — named in the Governor's request, but not in the closure that followed. We do not read them as blocked. We also will not tell you they are open: verify the risk tier and the zoning on OSS before you file, for each one.

Where our count was wrong

Until 15 September 2026, this article counted 518 codes, 33.2% blocked. That number treated the Governor's request letter as if it were the closure itself — every low- and medium-low-risk code, island-wide. It was not. The letter is a request, Lampiran: -; it names no code. What Bali actually applied, per the Province's own press release, touches 18 business fields, not an entire risk tier. Re-measured against what was actually closed instead of what was merely requested, the honest count drops from 518 to 135.

(This is the second correction on this article. The first, early in the series, brought a working figure of "about 945 codes, roughly 39% blocked" down to 518 — a looser, multi-row OSS export miscounted at the scope level instead of the code level. Both corrections point the same way: the narrower and more literal the closure you measure against, the smaller — and the more defensible — the number gets.)

What the map actually tells you

Three readings, not two:

• 135 codes (8.7%) are blocked in our data — 106 at HIGH confidence, 29 on a conservative reading. Even a HIGH verdict can be narrower than the code: the hotel closure covers only buildings under 6,000 m², some reservations cover a single sub-activity, and one closure is still only proposed. Check the individual code before you treat it as final.
• 383 codes (about a quarter) need a live check before you file — the risk tier that worried Bali's Governor, without the closure that would actually block them.
• 1,041 codes carry neither flag — though 60 of them are scope-dependent and 24 unclassified, so "not blocked" still means check the specific code, not just the category.

The map is not "Bali is closed." It is "Bali closed 18 named fields, asked about many more, and everything else still needs a code-by-code check" — three different answers to the same question, and worth telling apart.

We will keep this count current as the OSS data and Bali's own closure evolve — and we will keep showing the arithmetic, because the moment a number can't be reproduced from the file, it stops being journalism and starts being a rumour.

Don't take the aggregate on faith — check your own exact code against the live count on the Bali Zero KBLI Navigator at balizero.com, where every code's national status and Bali verdict sit side by side, drawn from the same data this article counted.