Bali’s 2026 PMA Closure: Why Jakarta Registration With a Bali Branch Still Works

Bali Closes PT PMA Low-Risk KBLI and Virtual Offices: Your Legal Path Forward in 2026

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Endah Wahyuningsih - Account Manager of InvestinAsia

A seasoned business professional with 10+ years of experience supporting diverse industries and managing regional partnerships across Southeast Asia. She specializes in legal advisory, immigration, and cross-industry consulting, helping clients navigate regulations and build strong local partnerships.

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Endah Wahyuningsih

Account Manager of InvestinAsia

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Bali’s 2026 PMA closure is the provincial government’s decision to block foreign-owned companies (PT PMA) from registering new businesses in 18 low and lower-medium risk categories through Indonesia’s OSS licensing system. It took effect in the third week of May 2026 and was made public by Governor Wayan Koster on July 22, 2026, after the central government signed off on Bali’s request.

Key Takeaways

  • Bali has blocked OSS registration for PT PMA in 18 low and lower-medium risk KBLI codes, including real estate, retail, consulting, and short-term rentals, effective since the third week of May 2026.
  • The trigger was a governor’s letter to the Minister of Investment/BKPM dated January 28, 2026, reporting that 19,262 PMA entities registered in Bali between 2021 and 2025, about 40 percent of Indonesia’s national PMA total.
  • Virtual office PMA setups received specific scrutiny in the same request, separate from the KBLI list.
  • Companies with an existing, active license in a now-blocked category can keep operating but must keep filing quarterly LKPM reports.
  • A common workaround InvestinAsia advises on: register the PT PMA in Jakarta and add Bali as a business location (branch) once the entity and NIB exist.

What Did the Bali Governor Actually Ask For?

Bali's 2026 PMA Closure
Bali’s 2026 PMA Closure (indonesia.travel)

On January 28, 2026, Governor Wayan Koster sent a formal letter (Nomor B.27.000/642/PM/DPMPTSP) to the Minister of Investment and Downstreaming/Head of BKPM. The letter cited a specific number: 19,262 PMA business actors registered in Bali between 2021 and 2025, roughly 40 percent of Indonesia’s national PMA total, spread across 55,458 projects. Of those, 47.55 percent fell into the low-risk category, meaning they needed only a Business Identification Number (NIB) and no further certificate or permit.

The letter named the KBLI codes doing most of that volume: real estate rental (68111), management consulting (70209), motorcycle and vehicle rental (77311, 77100), travel agency services (79121), and several retail categories in clothing, textiles, and food. Koster’s office argued these codes were functioning as a backdoor route to a stay permit rather than genuine business activity, and asked BKPM to close OSS access for both the low-risk KBLI list and any PMA operating out of a virtual office in Bali.

Which 18 Business Categories Are Now Closed to Foreign Investment in Bali?

BKPM approved the request. According to the official release from Pemerintah Provinsi Bali, OSS access closed for 18 KBLI codes across the province starting the third week of May 2026:

Accommodation and Hospitality

Star hotels under 6,000 square meters, budget hotels (hotel melati), and other short-term accommodation types.

Real Estate and Consulting

Real estate rental or leasing on own or leased property, general management consulting, and industrial management consulting.

Rental and Transport

Car, bus, and truck rental, plus motorcycle rental without an option to purchase.

Retail Trade

Retail clothing, retail textiles, retail food, and mobile retail of agricultural food products.

Food, Wellness, and Recreation

Cafes, traditional medicine shops, custom tailoring, stadium facilities, fitness centers, and sports event promotion.

According to Pemerintah Provinsi Bali, the policy also singles out PMA operating through a virtual office as a distinct enforcement priority, on top of the 18-code list.

Not Sure If Your KBLI Is Still Open in Bali?

InvestinAsia checks your specific business code against the current OSS status before you commit any capital.

Why Did Bali Close These Categories to Foreign Investors?

The stated reason is UMKM protection, not a general retreat from foreign investment. Bali’s evaluation team, working through DPMPTSP with technical agencies, found that low-risk KBLI codes were being used as an entry point into sectors that normally belong to local micro and small businesses, cafes, tailoring, retail clothing, and similar trades.

Governor Koster framed it directly in his July press release: these sectors were facing unhealthy competition and pressure from foreign entrants who registered through a route that required no meaningful capital commitment, just an NIB. As reported by Pemerintah Provinsi Bali, he stated the goal is to protect the room for growth that these sectors are meant to give local cooperatives and small businesses, not to reject foreign investment outright.

The virtual office issue is a separate but related thread. A number of these registrations used a virtual office as the company’s registered address, with little sign of real premises, staff, or investment behind the NIB. That combination, low-risk KBLI plus virtual office, is what the province flagged as the clearest shell-company pattern.

What Happens to a PMA That Already Holds a License in a Blocked Category?

If your PT PMA already has an active license in one of the 18 categories, you keep operating. The closure blocks new OSS registrations, not existing ones. You still have to file quarterly LKPM (Investment Activity Reports) as usual, and Bali’s provincial government has said it will coordinate enforcement with district heads and mayors against licensing violations. If your existing license is genuine and your LKPM filings are current, this closure does not touch you directly.

What it does mean is that if you want to expand, add a second location, or start a new project in one of these categories in Bali, the OSS door for that specific combination is currently shut.

Notes from InvestinAsia Consultants

Clients who registered a low-risk KBLI in Bali purely to sponsor an Investor KITAS, with no real operating business behind it, are the group this closure targets most directly. If that describes your setup, the safer move now is to make sure the existing entity has real activity and current LKPM filings, rather than trying to add a second low-risk location on top of it.

How Do You Register a Business in Bali Now That These Categories Are Closed?

The structure InvestinAsia’s team most often recommends when a client’s target KBLI sits on the blocked list: incorporate the PT PMA in Jakarta, then register Bali as an additional business location (lokasi usaha) under that same entity through OSS, rather than trying to register the company itself in Bali.

This works because the closure targets new PMA registrations located in Bali for specific KBLI codes. A company incorporated in Jakarta, holding its NIB and legal registration there, with Bali added afterward as a branch location, follows a different registration path than a company registered from the outset as Bali-based. This is not a way around the 18-code restriction itself. If your KBLI is on the blocked list, it stays blocked regardless of where the parent entity is registered. It matters for KBLI codes that are not on the restricted list but where you still want a genuine Bali presence, or where your main revenue activity is legitimately Jakarta-based with Bali as a secondary location.

The mechanics, at a high level:

Incorporate the PT PMA in Jakarta

This covers the notarial deed, Ministry of Law ratification, NPWP, and NIB. Jakarta remains the more established path for company formation, with faster turnaround on notary and Kemenkumham steps than most provinces.

Choose a Jakarta Office Setup

A virtual office is generally sufficient for the Jakarta head office registration if your business does not require walk-in premises there. See InvestinAsia’s virtual office service for what is included.

Add Bali as a Business Location Through OSS

Once the entity and NIB exist, Bali can be registered as an additional operating location under the same company. This is where Bali company registration support becomes relevant, since the local address, zoning, and any sector-specific permit still need to hold up to scrutiny.

Use a Real, Verifiable Bali Address

Given the province’s current enforcement focus on virtual offices, a serviced office or co-working space with actual physical presence is the safer choice for the Bali location, not a virtual-only address.

For the full step-by-step breakdown of PT PMA registration timing and documents, InvestinAsia’s complete guide to PT PMA in Bali covers the process end to end.

Ready to Register in Jakarta and Add a Bali Location?

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How Much Capital Does a PT PMA Need in 2026?

Capital requirements depend on your KBLI code, whether you are pairing the entity with an Investor KITAS, and whether recent capital-threshold changes apply to your sector, and this is genuinely not a question a general article should answer with a single number. Reported figures have shifted over the past year, and the exact threshold that applies to your specific business plan needs a direct check rather than a guess. This is the one part of setting up a PT PMA where getting a number wrong costs real money, so InvestinAsia’s team confirms the current requirement against your specific KBLI and investment plan before you commit anything.

Ask InvestinAsia on WhatsApp about the current capital requirement for your KBLI.

What Are the Risks of Trying to Get Around the Bali Closure?

Under Law No. 25 of 2007 on Investment, operating a commercial business in Indonesia without proper licensing carries administrative and, in some cases, criminal exposure. Two specific risks are worth naming directly for this situation:

  1. Using an Indonesian nominee to hold shares. This is illegal under Indonesian investment law regardless of how informal the arrangement looks on paper, and it does not solve the KBLI restriction, since the underlying business activity is still what’s being regulated.
  2. Registering the company outside Bali while the actual business operates inside Bali under a blocked KBLI. Given that virtual office arrangements are the specific pattern the province is watching for, a Jakarta registration with no real Jakarta activity, built purely to disguise a Bali-based blocked business, is exactly the shell pattern this policy targets. It carries real enforcement risk, not just a technical gray area.

Companies that already hold a license in a blocked category keep an obligation to file LKPM as outlined by BKPM’s investment reporting rules. Missing these filings, closure aside, is its own compliance problem that can affect future licensing.

Notes from InvestinAsia Consultants

We get asked fairly often whether a Jakarta registration with a Bali branch is just a paperwork trick to dodge the closure. It isn’t, and treating it that way is how clients end up with a company that looks fine on paper and gets flagged the moment an inspector checks the actual address. The structure only holds up when the Jakarta entity has genuine activity and the Bali location is a real, staffed presence, not a mailbox.

Is Bali Still Open to Foreign Investment in 2026?

Yes, outside the 18 restricted codes. Governor Koster was explicit in his July 2026 statement that this is not a rejection of foreign capital. Bali remains open to investment the province considers quality, responsible, and beneficial to the local economy, aligned with its Nangun Sat Kerthi Loka Bali development vision. Higher-risk business activities, the ones requiring central government verification rather than automatic OSS issuance, are unaffected by this closure and remain open to foreign registration through the normal process.

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References
  1. Governor of Bali. (2026, January 28). Surat Gubernur Bali Nomor B.27.000/642/PM/DPMPTSP: Permohonan Penutupan Penanaman Modal Asing (PMA) pada kegiatan usaha dengan Tingkat Risiko Rendah dan Menengah Rendah dan Penutupan PMA di virtual office pada Provinsi Bali.
    https://dpmptsp.bulelengkab.go.id/informasi/download/76_surat-gubernur-penutupan-pma-tingkat-risiko-rendah-menengah-rendah_2026-02-18-10-52-32.pdf
  2. Pemerintah Provinsi Bali. (2026, July 23). Gubernur Koster Batasi Akses OSS untuk PMA di Sejumlah KBLI, Lindungi UMKM Lokal dari Persaingan Tidak Sehat.
    https://www.baliprov.go.id/web/gubernur-koster-batasi-akses-oss-untuk-pma-di-sejumlah-kbli-lindungi-umkm-lokal-dari-persaingan-tidak-sehat/
  3. Antara News Bali. (2026, July). 18 bidang usaha dengan penanaman modal asing (PMA) di Bali ditutup demi jaga usaha lokal.
    https://bali.antaranews.com/berita/410161/18-bidang-usaha-dengan-penanaman-modal-asing-pma-di-bali-ditutup-demi-jaga-usaha-lokal
  4. Republic of Indonesia. Law No. 25 of 2007 on Investment.
  5. Republic of Indonesia. Government Regulation No. 5 of 2021 on Risk-Based Business Licensing (OSS-RBA).

About the Accuracy of This Article

This article was compiled by the InvestinAsia editorial team and has undergone a review process to ensure that the information provided is relevant and accurate for business owners in Indonesia.

All information is based on applicable regulations regarding the establishment and management of business entities, including provisions from the Ministry of Law and Human Rights, the OSS system, and other relevant regulations. Business regulations are subject to change at any time. We recommend that readers verify the information or consult with a professional before making business decisions.

This article is published solely for educational purposes and does not constitute professional business advice.

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