Part of the series: 2026 Policy Updates
- PT PMA Regulations 2026: What Every Bali-Based Foreign Investor Needs to Know
- PT PMA Compliance 2026: What Existing Bali-Based KBLI Holders Need to Know and Do Before 18 June
- PT PMA Establishment 2026: Pre-Formation Framework for Bali-Based Enterprises
- Bali Property in 2026: Perda No. 4 of 2026, the Nominee Prohibition, and the Compliant Investment Structure
Bali Policy Update 2026 | Article 2 of 4
Article 1 in this series sets out the full regulatory landscape: the Governor’s letter, the categorical OSS restriction it has produced, the DPMPTSP’s formal proposal to BKPM, Perda No. 4 of 2026, the Ministry of Investment’s four proposed structural interventions, and the KBLI 2025 migration deadline. Article 3 covers new PT PMA formation in Bali under current conditions. Article 4 addresses property and land exposure under Perda No. 4 of 2026.
The restrictions announced in early 2026 do not cancel existing PT PMA licences in Bali. Your Business Identification Number (Nomor Induk Berusaha, or NIB) and the licences issued under it remain valid. No retrospective revocation has been proposed or implemented.
What has changed is the compliance environment in which your company operates going forward. Three separate developments now run concurrently, each with a specific deadline and specific compliance obligations. The KBLI 2025 migration deadline of 18 June 2026 requires every PT PMA in Indonesia to synchronise its business classification codes with the KBLI 2025 framework. For companies in Bali whose codes carry a low-risk or medium-low risk classification under the OSS risk-based approach, that migration carries a risk the standard process does not. Substance-based field inspections are expected to begin in June 2026, assessing whether your actual business activities match your registered classification and whether your declared investment is being realised. Your quarterly LKPM investment reporting must be current and accurate before that inspection window opens.
This article addresses those three obligations in order, explains exactly where the risk points lie, and provides the action sequence you need to work through before 18 June.
Your Existing Licence: What Has Changed and What Has Not
Your existing NIB was issued under the framework that applied when your company was incorporated. The Governor’s letter of 28 January 2026, the categorical OSS restriction it produced, and the DPMPTSP’s February 2026 proposal to the Ministry of Investment are all prospective instruments. They restrict new applications and new OSS interactions. They do not affect licences already in place.
Official records indicate that in excess of 400 PT PMA companies in Bali received sanctions through 2025 and early 2026. Those sanctions arose from investment realisation failures and from operating outside registered classifications. They did not arise from holding a low-risk or medium-low risk code per se. Enforcement focuses on whether your operations substantiate your registered classification and whether your capital is being genuinely deployed.
Two separate risks now apply to your company. The first is procedural: an OSS interaction you need to make may trigger the categorical restriction at the submission stage. The second is substantive: a June 2026 field inspection may identify a mismatch between your registered activities and your actual operations. Neither risk results in automatic NIB cancellation at the point of identification. Both escalate if not addressed.
The Four OSS Trigger Points
Your existing NIB carries no immediate risk provided you do not initiate an OSS interaction that subjects your registration to a fresh system review. Four categories of OSS action create that exposure.
The KBLI 2025 migration is the most immediate. The migration requires synchronisation of your registered classification codes with the KBLI 2025 framework by 18 June 2026. As confirmed by TraceWorthy’s own testing across multiple codes, OSS blocks all low-risk and medium-low risk KBLI classifications for PT PMAs with a Bali Province address. Where your registered code carries a low-risk or medium-low risk classification, the synchronisation may trigger the block at the point of submission. This is addressed in full in the following section.
Licence renewal is the second trigger. Where your NIB or any sector-specific licence falls due for renewal, the renewal requires an OSS submission. The restriction may apply at that point regardless of whether the renewal is otherwise routine.
Amendment of company data through OSS is the third trigger. A change to your registered business activities, your registered address, or capital-related data in your investment plan documentation may require a new OSS filing. That filing is subject to the current restriction framework.
Addition of a new KBLI code or a new license is the fourth trigger. Any application to expand your company’s OSS registration is processed under the current restriction environment. The risk applies not only to the new code being added but to the existing codes already registered, which are subject to the restriction at the point of that OSS interaction.
Where you can sequence your corporate actions, resolve the KBLI migration question first and with legal advice in hand, then address any subsequent OSS interactions from a position of assessed risk.
The KBLI 2025 Migration: The Risk Event Before 18 June 2026
The KBLI 2025 migration is mandated by a joint instrument from the Ministry of Investment (BKPM), the Ministry of Law (AHU), and the Central Statistics Agency (BPS). The deadline is 18 June 2026. For PT PMAs across Indonesia whose codes do not carry a low-risk or medium-low risk classification, the migration is largely automatic. Previously issued licences, NIBs, and permits remain valid throughout the transition.
For PT PMAs in Bali Province with low-risk or medium-low risk codes, the migration is not automatic. The synchronisation requires active OSS engagement, and the system may apply the categorical restriction at the submission stage. A company that has operated in Bali for years under an existing registration without interference may find that initiating the migration brings its registration into the active review process where the block is applied.
KBLI 70209 presents a further complication beyond the categorical restriction. That code carries forward unchanged from KBLI 2020 to KBLI 2025 without receiving a new designation. It has also received formal national-level approval for closure, specifically for PT PMAs registered in Bali Province. A company registered under KBLI 70209 in Bali cannot migrate to a 2025 equivalent under the same classification. The migration must be structured under an alternative code that accurately reflects the company’s actual business activities and does not carry a low-risk or medium-low risk classification in Bali Province. Identifying that code requires legal analysis, and the preparation window before 18 June 2026 is narrow.
After 18 June 2026, a NIB not aligned with KBLI 2025 may be blocked in OSS, preventing license renewals, permit applications, and LKPM (Laporan Kegiatan Penanaman Modal — Investment Activity Report) submissions. The LKPM quarterly investment reporting system is integrated with your KBLI codes. Reporting under a code that does not exist in the 2025 framework may cause OSS to reject the submission, initiating the administrative enforcement sequence.
If your company’s registered code carries a low-risk or medium-low risk classification, the KBLI migration deadline should be treated as a compliance event requiring legal preparation, not an administrative task to be completed directly through OSS.
Substance-Based Compliance and the June 2026 Inspection Programme
Following joint socialisation sessions conducted by BKPM and the Bali Provincial Government, field inspections and substance-based compliance enforcement are expected to begin in June 2026. The Ministry of Investment has established an Investment Desk in Bali to coordinate this programme. The timing aligns with the KBLI migration deadline, creating a compliance period in which your KBLI alignment and your operational substance are assessed concurrently.
Substance-based compliance means that inspectors evaluate whether your company’s operational activities reflect its registered KBLI code and whether the capital you declared is being realised in genuine business activity. The most consistently identified compliance violation through 2025 and early 2026 is the mismatch between registered classification and actual revenue source. KBLI 68111 under KBLI 2020 authorised long-term real estate operations. It did not cover short-term tourist accommodation. Under KBLI 2025, introduced by BPS Regulation No. 7 of 2025, KBLI 68111 has been further refined: it now specifically covers residential development for sale, while long-term residential rental has been reclassified to KBLI 68112. A PT PMA that was generating income from short-term villa rental under KBLI 68111 was therefore operating outside its registered classification in two respects simultaneously. Short-term tourist accommodation in Indonesia is also reserved for Indonesian UMKM entities under Presidential Regulation No. 49 of 2021, which governs the Positive Investment List. PT PMA entities are excluded from operating short-term tourist accommodation other than hotels. A company using KBLI 68111 for daily villa rental was not simply in the wrong code category. It was generating revenue from a sector in which PT PMA investment is prohibited.
The administrative enforcement sequence for substance-based compliance failures runs in four stages. An initial written warning is issued through OSS. A second warning follows if the non-compliance is not resolved. A third warning or temporary suspension of business activity authorisation is then applied. Continued non-compliance results in revocation of the business license and NIB. These are administrative sanctions arising from the substantive compliance failure. Where the arrangement also involves nominee land ownership, Perda No. 4 of 2026 introduces separate criminal exposure that is addressed in Article 4.
The practical preparation for the inspection programme is a written review of whether your revenue sources and operational activities correspond to your registered KBLI code. That review should be in documentary form because a documented internal review constitutes a defensible compliance record if an inspector raises a question, and it surfaces any mismatch in advance of the inspection window when there is still time to act.
LKPM Reporting and the Capital Realisation Requirement
Every PT PMA in Indonesia is required to file an LKPM quarterly through OSS. The LKPM records your company’s realised investment activity for each period. The OSS system automatically initiates administrative sanctions where a PT PMA records zero capital realisation across four consecutive quarters.
BKPM Regulation No. 5 of 2025, effective 2 October 2025, revised the investment thresholds applicable to all PT PMAs. The minimum paid-up capital was reduced from the previous IDR 10,000,000,000 (ten billion Indonesian Rupiah) to IDR 2,500,000,000 (two billion, five hundred million Indonesian Rupiah). Existing PT PMAs structured under the previous threshold may restructure under the revised figure, subject to the conditions set out in the regulation. The minimum total investment value of IDR 10,000,000,000 (ten billion Indonesian Rupiah) per five-digit KBLI code per project location, excluding land and buildings, remains unchanged. The total investment value is the figure tracked through LKPM submissions and assessed during field inspections.
Field inspectors will review LKPM submissions alongside bank statements and financial records to verify that the declared total investment value is being realised through genuine business activity. The NIB revocations that preceded Operation Wira Waspada in early 2025 were a direct consequence of PT PMAs failing to meet the investment realisation requirement over multiple reporting periods.
Where your LKPM submissions reflect zero or minimal realisation over recent quarters, this is the compliance issue requiring the most immediate attention, independent of whether your KBLI code carries a restricted risk classification.
The National Closure of KBLI 70209 in Bali: The Position for Companies Registered Under This Code
KBLI 70209 is the only code among the nine named in the Governor’s letter that has received formal national-level approval for closure from the Ministry of Investment, specifically for PT PMAs registered in Bali Province. That approval is a confirmed ministerial decision in response to the DPMPTSP’s Bali-specific proposal. The other eight codes remain subject to the categorical OSS restriction while the formal national review process continues.
Your existing NIB under KBLI 70209 remains valid as originally issued. The closure applies to new activations, not to existing registrations. Enforcement for companies registered under KBLI 70209 in Bali focuses on two questions: whether actual activities correspond to management consultancy services as classified, and whether the company is seeking to expand its activities or obtain new licences under that code.
Any corporate change requiring a new OSS filing must be structured under an alternative KBLI code. Before initiating any such change, you need to identify a code that accurately describes your actual business activities, confirm that code does not carry a low-risk or medium-low risk classification in Bali Province, and verify that your company’s operational profile supports that alternative classification.
Where a foreign national’s Investor KITAS is sponsored by a company registered under KBLI 70209, the immigration position warrants review alongside the corporate compliance assessment. The Investor KITAS requires a minimum personal share ownership of IDR 10,000,000,000 (ten billion Indonesian Rupiah) per individual investor, as set by the Directorate General of Immigration under Minister of Law and Human Rights Regulation No. 22 of 2023 on Visas and Residence Permits, as subsequently amended. That requirement was not reduced by BKPM Regulation No. 5 of 2025, which reduced only the company-level paid-up capital threshold. The Investor KITAS shareholding requirement and the BKPM paid-up capital requirement are governed by separate regulatory instruments and are independently applicable. A company operating under enhanced supervision, or one flagged in the enforcement programme, is an unstable basis for a residence permit that depends on that company’s compliance position.
Corporate Changes and the OSS Filing Threshold
Whether a corporate change triggers the restriction depends on whether it requires a new OSS filing.
Changes recorded at the Ministry of Law through the company’s notarial deed and AHU registration, where no new OSS application is generated, do not automatically activate the restriction. A director change processed through a notarial deed and updated solely in AHU may not require an OSS submission in every case.
Changes that do require a new OSS submission carry the trigger risk. These include changes to registered business activities, changes to the KBLI codes in your NIB, changes to the registered business address, and capital increases requiring updated investment plan documentation in OSS.
The mapping of which corporate changes require which regulatory filings is fact-specific to each company. Legal analysis of your company’s position, its KBLI code, and the intended change is required before any filing is made.
Virtual Office Addresses and the Additional Restriction
The Governor’s letter requests OSS to close PT PMA applications in Bali Province where the registered business address is a virtual office, regardless of KBLI classification. The Ministry of Investment’s structural proposals include a formal prohibition on virtual office addresses for PT PMAs in Bali, and that proposal is advancing through the national policy process.
For companies already registered to a virtual office address in Bali, the restriction does not apply retrospectively. The risk arises at the same OSS trigger points: migration, renewal, amendment, and any new application. Where a company carries a restricted-classification code and a virtual office address, both restrictions may apply simultaneously when any OSS interaction is initiated.
The question of whether to relocate to physical premises in advance of the KBLI migration and other required OSS interactions belongs within the overall compliance review. The address question and the KBLI question interact at every OSS trigger point and should be assessed together.
The Action Sequence Before 18 June 2026
Five steps, ordered by dependency.
- Identify the risk classification of every KBLI code registered to your company under the OSS risk-based approach. The categorical OSS restriction in Bali Province applies to all low-risk and medium-low risk classifications. Where none of your codes carry a low-risk or medium-low risk classification, your KBLI migration carries no heightened risk and can proceed through the standard OSS process.
- Prepare a written review of whether your company’s actual revenue sources and operational activities correspond to your registered KBLI codes. This is a documentary record that substantiates your classification in the event of an inspection. Where a mismatch is identified at this stage, you have time to obtain advice and act before the inspection window opens.
- Review your LKPM submission history. Confirm that every quarterly filing has been submitted on time and reflects genuine realised investment activity. Where there is a gap between declared investment value and reported realisation, obtain advice on how to address it before June 2026.
- Obtain specific legal advice on your KBLI migration. That advice should identify which KBLI 2025 code accurately reflects your actual business activities, confirm whether that code carries a low-risk or medium-low risk classification in Bali Province, and determine what the migration filing requires for your specific situation.
- Assess any corporate changes planned for 2026, determine whether they require OSS filings, and sequence them appropriately relative to the migration and the inspection window.
Working through this sequence gives you a defined position on each of the three concurrent obligations before 18 June. Specific legal advice translates this framework into the plan that works for your company’s specific KBLI profile and corporate history.
Frequently Asked Questions
Is my existing Bali PT PMA at risk of being cancelled?
No. Existing NIBs and business licences issued before the restrictions took effect remain valid and legally recognised. Retrospective cancellation has not been proposed or implemented. The risk for existing holders arises at specific OSS interaction points, not from continued operation under an existing licence.
Which codes are restricted for PT PMA in Bali?
OSS blocks all low-risk and medium-low risk KBLI classifications for PT PMAs with a Bali Province address. The restriction operates at the risk classification level, not at the individual code level. Nine codes were specifically named in the Governor’s letter as the primary examples. KBLI 70209 has received formal national-level closure approval from the Ministry of Investment, specifically for Bali Province.
What happens if my code carries a low-risk or medium-low risk classification and I need to migrate to KBLI 2025?
The migration must be structured under an alternative code that carries a different risk classification and accurately reflects your actual business activities. Legal advice is required to identify the correct alternative and prepare the migration filing.
Can I add a new KBLI code to my existing Bali PT PMA?
Any application to add a new code requires an OSS submission. Where the intended code carries a low-risk or medium-low risk classification in Bali Province, it will be blocked. Where it does not, the OSS interaction required to add it may still trigger the restriction against your existing restricted-classification codes at the same submission point. Legal assessment of the full filing position is required before any action is taken.
My company is registered under KBLI 70209. Can I still operate?
Yes, under your existing NIB and licences. The ministerial closure of KBLI 70209 for new activations applies to Bali Province specifically. Existing registrations are not retroactively cancelled. Any corporate change requiring a new OSS filing must be structured under an alternative code that does not carry a low-risk or medium-low risk classification in Bali Province.
What will field inspectors look for in June 2026?
Inspectors will assess whether your company’s actual operational activities match its registered KBLI code and whether your declared investment value is being realised as recorded in your LKPM submissions. Companies generating revenue from activities outside their registered classification, and those with zero or minimal LKPM realisation across multiple quarters, are the primary enforcement focus.
What happens if I miss the KBLI 2025 migration deadline of 18 June 2026?
After 18 June 2026, a NIB not aligned with KBLI 2025 may be blocked in OSS, preventing license renewals, permit applications, and LKPM submissions. The administrative enforcement sequence follows unresolved LKPM submission failures.
This article provides general information only. It does not constitute legal advice and does not address any specific company’s circumstances. The regulatory environment described is active and evolving. The information reflects sources available at the time of publication and will be updated as the policy position develops. Readers should obtain specific advice from a qualified legal adviser before taking any action in relation to their PT PMA or business interests in Bali. TraceWorthy provides advisory and legal drafting services for PT PMAs, foreign investors, and expatriates operating in Bali and across Indonesia.