KBLI Restrictions in Bali in 2026: What Foreign Investors Need to Know Before Opening a PT PMA

How to select and verify the correct KBLI for a PT PMA in Bali in 2026, so that the company reflects its actual business activities and avoids registration refusal, OSS restrictions, or problems when amending corporate documents.

As of early 2026, certain KBLI categories are unavailable for the registration of new PT PMA companies in Bali. This mainly affects low-risk and medium-low-risk activities that do not require complex licensing and were frequently used by foreign investors under broad or inaccurate business descriptions.

Affected sectors include:

• real estate and villas;
• motorbike and vehicle rental;
• travel agencies;
• consulting;
• offline retail.

The main change is that it is no longer sufficient to select a code that is generally related to the intended activity. The actual operating model must be reviewed first.
For example, a property business may involve:

• long-term rental;
• short-term rental;
• tourist accommodation;
• property management;
• vehicle or equipment rental;
• agency services;
• retail operations.

These models may look similar from a commercial perspective, but OSS and the licensing authorities may treat them very differently.

If a company was established earlier under an old KBLI, it may formally continue operating as long as it does not amend its corporate documents or update relevant corporate or licensing data in OSS. However, a legal or corporate amendment may trigger a review of the company structure and its business activity codes.

KBLI is Indonesia’s official classification of business activities.

In practical terms, KBLI determines what a company is legally permitted to do. It affects not only the description of the business activity, but also the company’s broader legal and operational structure.

The selected KBLI may determine:

• whether the activity is open to foreign investment through a PT PMA;
• which licenses the company requires;
• the risk classification of the business;
• which requirements appear in OSS;
• whether the selected address can be used;
• which documents may be required after registration;
• whether the company can interact smoothly with banks, licensing authorities, and government systems.

An incorrect KBLI may create a situation in which the company formally exists, but its legal structure does not support its actual business model.

In the past, many projects in Bali were established according to a simple principle: register the company first and adapt it to the actual business operations later.

As of early 2026, this approach has become increasingly risky.

A number of activities are now unavailable to new PT PMA companies in Bali. This especially affects sectors in which foreign investors frequently relied on broad interpretations of business activity codes, including:

• villas and real estate;
• motorbike and vehicle rental;
• travel agencies;
• consulting;
• retail trade;
• small offline businesses.

The correct approach is no longer to select a KBLI that merely resembles the intended activity. The company must first analyze its actual operating model.
For example, the term “villa business” may refer to several different structures:

• long-term property rental;
• short-term rental through Booking.com or Airbnb;
• tourist accommodation;
• property management;
• a mixed rental model.

For the customer, all of these may appear to be the same type of business. For OSS and licensing purposes, however, they may be treated as completely different activities.

The current restriction is not based only on individual KBLI codes. It is primarily connected to the risk classification assigned to the activity.

In Bali, low-risk and medium-low-risk activities are currently unavailable for the registration of new
PT PMA companies. Examples of affected activities are listed below.

KBLI activities classified as medium-high risk or high risk may still be available. Examples may include:

• mining;
• electricity;
• hospitals and medical facilities;
• hazardous chemicals;
• telecommunications network services;
• construction;
• architectural services.

The restriction therefore applies not only to the individual codes listed above, but also to the broader risk category assigned to the activity.

This should be reviewed before the company is registered. If the business model depends on one of these activities, the structure should be reconsidered during the planning stage.

Otherwise, the company may face problems during registration, when working with OSS, or when making future amendments to its corporate documents.

KBLI 68111 was previously used frequently by foreign investors entering the Bali real estate market.
The structure appeared straightforward: establish a company under a real estate activity and then use it for villas, rental operations, or property management.

As of early 2026, this structure is no longer available to new companies in the same way. KBLI 68111 is no longer treated as an appropriate basis for tourist accommodation or conventional villa rental operations.
The main question is now what actually happens with the property.

The operating model may involve:

• long-term rental;
• short-term rental;
• tourist accommodation;
• listing through Booking.com, Airbnb, or another online travel agency (OTA) platform;
• a mixed rental model;
• management of real estate as a commercial asset.

Each structure may involve different requirements, KBLI codes, licenses, and legal restrictions.

For a PT PMA, long-term and short-term rental must be treated as separate business models.

For long-term accommodation, KBLI 55900 — Other Accommodation Services — may be considered. However, an important condition applies: the structure should involve long-term contracts only, without OTA platforms and without tourist accommodation turnover.

KBLI 55900 is therefore not suitable for a model in which some properties are rented long-term and others are rented short-term.

If a property is offered for short-term accommodation through Booking.com, Airbnb, or similar platforms, the government may treat the activity as part of the tourism sector.
For PT PMA companies in this segment, KBLI 55110 — Star Hotel — may be the main potentially applicable option as of early 2026.

This means that there is no longer a broad choice of business activity codes for short-term villa rental. The accommodation model must be analyzed first, after which the appropriate legal structure can be determined.

A separate situation applies to companies that were established earlier and continue to use old KBLI codes.

Such companies are not necessarily affected by the new restrictions immediately. As long as the business does not amend its corporate documents or update relevant data in OSS, the existing structure may remain valid.
The issue usually arises when the company makes a legal or corporate change.

A review of the company structure and KBLI codes may be triggered by:

• amending the articles of association;
• adding a new business activity;
• changing the corporate structure;
• changing shareholders or investors;
• updating the company address;
• changing the legal form;
• taking action in OSS that affects corporate documents or licenses.

Some companies may also soon be affected by the transition to the updated KBLI classification.
For certain companies, the government authorities may update the codes automatically. Others may receive a notification in OSS requiring them to select and update their business activity codes manually.

Therefore, if the company continues conducting essentially the same activity, it may not be necessary to amend the Akta Pendirian or Anggaran Dasar solely because the KBLI number has changed.
However, an important qualification applies.

After the KBLI update, the following may change:

• the risk classification of the activity;
• licensing requirements;
• office requirements;
• the need to obtain additional permits;
• reporting and compliance obligations.

In practice, an existing company may appear compliant as long as nothing changes. However, once a legal or corporate amendment is initiated, the old KBLI may become a blocking issue.

Existing companies should:

• review notifications in OSS;
• check the email address connected to the company’s OSS account;
• confirm that the new KBLI corresponds to the company’s actual activity;
• review whether the licensing and risk requirements have changed;
• check whether additional permits are now required.

A company should not automatically amend its articles of association solely because the KBLI number has changed, provided that the substance of the business activity remains the same.
However, the old corporate structure should be reviewed before amendments become urgent or unavoidable.

The main risk is not the change in the code itself. The more serious risk arises when the new KBLI requires different licenses or operating conditions, while the company continues operating under the old requirements.

If you have received an OSS notification or are uncertain whether the changes affect your company, contact our manager at SUNRISE Business to arrange a consultation.

In 2025, BPS Regulation No. 7/2025 came into force and introduced an updated KBLI classification.
Some old codes were removed, while others were divided into new categories.

The difficulty is that OSS may still technically operate under the previous classification. As a result, it may not yet be possible to replace the old KBLI codes with the new ones directly.

At the same time, companies are required to bring their activities into compliance by 18 June 2026.
This creates a transitional situation:

Companies that wish to amend their documents during this transition may therefore face additional compliance risks.
Both the new KBLI classification and the current technical status of OSS must be taken into account.

The company address has become an important part of the legal and licensing structure.
The NIB must contain the project’s actual operational address. OSS checks zoning, and the selected activity must be permitted at that specific location.

This is particularly important for:

• real estate;
• hotels;
• villas;
• tourist accommodation.

If the address is unsuitable for the selected activity, the company may face problems during:

• registration;
• licensing;
• company data updates;
• OSS reviews.

In practical terms, the address can no longer be treated as a line included only for documentation purposes.
It must correspond to:

• the actual project;
• the selected KBLI;
• local zoning requirements;
• the company’s operating model.

Further information about OSS and NIB is available in our separate article.

There are three main situations.

Sunrise Business does not begin with company registration or the formal selection of a business activity code.

We first review how the business is actually expected to operate.
This requires an understanding of:

• the business model;
• the company’s actual activities;
• whether the structure involves long-term or short-term rental;
• whether Booking.com, Airbnb, or another OTA platform will be used;
• which KBLI codes are available for PT PMA;
• whether the selected address is suitable;
• whether the existing corporate structure creates risks;
• whether the articles of association can be amended;
• which OSS restrictions may apply.

After the diagnostic stage, we help to:

• verify the KBLI against the actual activity;
• analyze business models involving villas, rental, tourism, consulting, or retail;
• review the existing PT PMA structure;
• assess risks related to the articles of association;
• determine whether the current operating model can be preserved;
• select a workable structure before registration or before amendments are made.

The objective is not simply to select a code.

Contact Sunrise Visa.

We first analyze your business model and then review:

• KBLI;
• the existing corporate structure;
• risks related to the articles of association;
• company address;
• OSS status;
• possible restrictions.

If your project involves villas, short-term rental, real estate, transport, tourism, consulting, or retail, the legal structure should be reviewed before registration or before amendments are made.
This helps prevent you from spending money on a company or corporate amendment that cannot properly support the intended business.