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.<\/p>\n\n\n\n
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.<\/p>\n\n\n\n
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.<\/p>\n\n\n\n
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.<\/p>\n\n\n\n
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.<\/p>\n\n\n\n
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.<\/p>\n\n\n\n
This is the core problem that both letters address.<\/p>\n\n\n\n
Referensi: B.27.000\/5753\/PM\/DPMPTSP<\/a> | Date: 10 December 2025<\/strong><\/p>\n\n\n\n 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.<\/p>\n\n\n\n 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.<\/p>\n\n\n\n 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.<\/p>\n\n\n\n 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.<\/p>\n\n\n\n Current Status:<\/strong> 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.<\/p>\n\n\n\n Referensi: B.27.000\/642\/PM\/DPMPTSP<\/a> | Date: 28 January 2026<\/strong><\/p>\n\n\n\n Less than two months later, the Governor wrote again, and this time the scope was much wider.<\/p>\n\n\n\nLetter 2: Closure of Low-Risk and Medium-Low-Risk KBLI Categories and Virtual Office PMA<\/strong><\/h3>\n\n\n\n