Invest in Bali: New KBLI Closures and What Foreign Investors Must Do Now

Bali continues to attract foreign entrepreneurs and investors from around the world. But those planning to invest in Bali in 2026 face a significantly tighter regulatory environment than in previous years, driven by two formal letters from the Governor of Bali to the Ministry of Investment that target specific misuses of the PT PMA registration system.

This article focuses specifically on the Bali-level changes: what the Governor requested, why, which KBLI categories are affected, and what existing and prospective PT PMA investors need to do now.

Bali Investment in 2026: A Market Worth Doing Right

Bali investment remains one of the most active foreign investment markets in Southeast Asia, with the province drawing IDR 25.60 trillion in PMA realization in 2025 alone across sectors ranging from hospitality and wellness to digital services and F&B. That sustained appetite from foreign investors is real, and it is well-founded. But it is also exactly what created the conditions the Governor’s letters are responding to: a high-demand market with low-barrier registration options is an easy target for misuse, and Bali’s authorities have decided to close that gap.

Why Bali Moved to Restrict Certain PMA Activities

Bali has recorded remarkable growth in foreign investment registrations in recent years. According to data cited in the Governor’s January 2026 letter to the Ministry of Investment, Bali accounted for 19,262 PMA business actors between 2021 and 2025, representing approximately 40% of all PMA Business Registration Numbers (NIB) issued nationally. These entities generated 55,458 registered projects.

The problem is what lies beneath those numbers. Of those projects, 47.55% were classified under low-risk categories, meaning they required nothing more than a NIB to operate, with no standard certificate and no sector-specific license. Provincial authorities found that a significant portion of these registrations did not reflect genuine business activity at all.

Instead, certain PT PMA companies were using specific KBLI codes and virtual office addresses to obtain legal residency status for foreign nationals, without purchasing land, building facilities, hiring local employees, obtaining environmental permits, or making any meaningful investment contribution to Bali’s economy.

This is the core problem that both letters address.

The Governor of Bali’s Two Official Letters to BKPM

Letter 1: Closure of KBLI 70209 for PMA in Bali

Referensi: B.27.000/5753/PM/DPMPTSP | Date: 10 December 2025

The first letter is specifically about KBLI 70209 (Aktivitas Konsultasi Manajemen Lainnya, or Other Management Consulting Activities). Governor Wayan Koster wrote directly to the Minister of Investment to request that this KBLI be closed to all PT PMA companies in Bali, and he was clear about why.

What the provincial government had been observing was a pattern that had become hard to ignore. Foreign investors were registering under KBLI 70209, obtaining their NIB, and then doing nothing with it in a business sense. No land purchased, no facility built, no environmental permit applied for. The only thing these companies had was a virtual office address and a piece of paper that happened to make staying in Bali a lot easier. The NIB was functioning as a residency tool, not a business registration.

Beyond the obvious mismatch between registration and reality, the Governor pointed to three tangible consequences for Bali. First, companies that do nothing generate nothing in regional tax and retribution revenue, leaving a gap that the province feels. Second, the influx of foreign nationals using this route was adding to population density in ways that spatial planning had no way to anticipate or manage. Third, the scheme was quietly squeezing out legitimate investors and local business owners while also creating a blind spot for environmental oversight and local employment.

The letter also noted a clear regulatory violation: these registrations were failing to meet the minimum investment value of IDR 10 billion per PT PMA required under Presidential Regulation No. 10 of 2021 (amended by No. 49 of 2021), Government Regulation No. 28 of 2025, and BKPM Regulation No. 5 of 2025.

Current Status: The Ministry of Investment has formally approved the closure of KBLI 70209 to PMA in Bali. As of the time of this writing, this is the only KBLI for which a Bali-specific PMA closure has been granted at the national level.

Letter 2: Closure of Low-Risk and Medium-Low-Risk KBLI Categories and Virtual Office PMA

Referensi: B.27.000/642/PM/DPMPTSP | Date: 28 January 2026

Less than two months later, the Governor wrote again, and this time the scope was much wider.

The January 2026 letter was issued as a follow-up to a formal Memorandum of Understanding between the Ministry of Investment/BKPM and the Province of Bali on controlling investment implementation (Ref: KS.01.00/2.S/A.1/2026 and B.36.100.3.7/2767/KS/B.PEMKESRA). In it, the Governor requested the Ministry to close two broader categories through the OSS system:

1. PT PMA companies conducting business activities classified as Low-Risk or Medium-Low-Risk in the Province of Bali.
2. PT PMA companies whose registered business address is a virtual office in the Province of Bali.

To illustrate the scale of the problem, the letter cited data showing that between 2021 and 2025, Bali recorded 19,262 PMA business actors, about 40% of all PMA NIBs issued nationally, generating 55,458 projects. Of those projects, 47.55% fell under low-risk classifications, requiring nothing beyond a NIB to operate. The Governor’s argument is straightforward: when registering a company takes almost no effort and carries almost no requirements, it becomes too easy to misuse.

The letter named the following nine KBLI codes as the most frequently used by PMA entities in Bali:

What these codes have in common is that they are all low-risk or medium-low-risk under Indonesia’s Risk-Based Approach framework, meaning a NIB is all that is needed to operate. That minimal barrier is exactly what made them attractive to those looking for the path of least resistance.

The letter was copied to 10 government bodies, including the Coordinating Minister for Economic Affairs, the Ministers of Home Affairs, Trade, Law, Finance, and Immigration, and all Mayors and Regents across Bali. That distribution list alone signals how seriously the province is pushing this.

Current Status: The eight remaining KBLI closure requests and the virtual office restriction are currently under national review by the Ministry of Investment. No additional formal approvals have been issued at the time of this writing, but the direction of travel is clear.

What This Means for PT PMA Investors in Bali Right Now

These letters are formal government correspondence, not informal policy signals. Foreign investors planning to invest in Bali must treat them as active regulatory risk, whether their PT PMA is already registered or still being planned.

If You Currently Hold a PT PMA in Bali

• KBLI 70209 (management consulting) is already closed. If your PT PMA is registered under this code in Bali, you are in the highest-risk category and should seek legal advice immediately on restructuring options.
• If your PT PMA is registered under any of the other eight KBLI codes named in the January 2026 letter, conduct a compliance review now. While formal closure of these codes is still pending national approval, Bali’s DPMPTSP is actively monitoring these categories.
• If your registered business address is a virtual office in Bali, this is directly targeted by the January 2026 letter. Transitioning to a physical address is strongly advisable before any formal OSS-level restriction is implemented.
• If your company has zero demonstrable economic activity, no local employees, no capital expenditure, and no investment realization, you face the clearest risk of enforcement action under the rationale both letters explicitly state.

If You Are Planning a New PT PMA in Bali

• Do not register under KBLI 70209. It is closed for PMA in Bali.
• Avoid registering under any of the other eight named KBLI codes unless your business genuinely and demonstrably operates in that sector with real economic activity, physical presence, local employment, and capital investment.
• Do not use a virtual office as your registered business address. While the national closure approval is pending, registering with a virtual office today puts your company directly in the scope of a formal governor-level request for OSS-level restriction.
• Build a credible and verifiable investment plan that shows capital expenditure, employment, and genuine operational presence in Bali. This is what distinguishes a compliant PT PMA from the structures that prompted both letters.

The Broader Policy Direction: What Bali Wants from Foreign Investment

Both letters reflect a deliberate and consistent policy direction from the Bali Provincial Government. Bali is not closing its doors to foreign investment. It is redirecting foreign investment toward activities that generate real economic value for the province.

The letters are explicit about what Bali does not want: foreign nationals using PT PMA structures as residency instruments, competing in micro-scale sectors reserved for local Balinese entrepreneurs, operating without any physical presence, and contributing nothing to regional tax revenue, employment, or sustainable development.

What Bali does want from foreign investment is equally clear from the sectors that are not on the closure list: hospitality and accommodation, digital and technology services, health and wellness, higher-value food and beverage operations, and businesses that purchase land, build facilities, hire local employees, and commit real capital to the province.

Foreign investors who align their PT PMA with those sectors and who can demonstrate genuine, verifiable economic contribution to Bali will face far fewer regulatory complications. Those who relied on low-risk KBLI codes, virtual offices, or management consulting shells as shortcuts are running out of runway.

Ready to Invest in Bali the Right Way?

Bali remains one of the most exciting and rewarding places in Asia to build a business. The regulatory changes underway are not a signal to walk away. They are a signal to do things properly, and investors who do will find a cleaner, less crowded field with fewer competitors cutting corners. The province is actively making space for foreign capital that contributes real value, and that is ultimately good news for serious investors.

Navigating Indonesia’s investment regulations, KBLI OSS classification, and Bali’s evolving provincial requirements takes experience and up-to-date knowledge. Business Hub Asia has been helping foreign investors establish and operate PT PMA companies across Indonesia for years, with a dedicated team in Bali that understands both the national framework and the local regulatory landscape.

Whether you are starting a new PT PMA, auditing an existing registration for KBLI compliance, restructuring away from a restricted business classification, or simply trying to understand what the latest governor’s letters mean for your situation, our team is ready to help you move forward with confidence. Get in touch with the Business Hub Asia team for a consultation tailored to your investment plans in Bali.