What a foreigner can own in Bali: the list and KBLI codes
Indonesia works the other way round: everything is open to foreigners except what is expressly closed or capped. Only seven fields are fully closed, and ownership limits attach not to an industry but to a specific five-digit KBLI code. Since May 2026, though, Bali has closed 18 popular sectors to new foreign companies — and that reshapes the picture more than any national list.
Updated: 29 September 2026 · Verified by the Malina Visa team
The Positive List: open unless stated otherwise
Until 2021 Indonesia ran a Negative List: it spelled out what foreigners could do, and the rest was closed by default. That logic is now reversed. Presidential Regulation 10/2021, in force since 4 March 2021, and its amendment 49/2021 of 24 May 2021, establish that any field is open to 100% foreign ownership unless it is named as closed or restricted.
The regulation sorts fields into four groups: priority sectors with tax incentives, fields reserved for cooperatives and small business, fields open subject to partnership with local small business, and fields open with an ownership cap. Sources disagree on the exact count in each group, which is why a specific code should always be checked against the annex rather than a summary.
Closed to everyone — foreign and Indonesian alike
The list is short and applies to every investor.
- ✕Cultivation and processing of Class-I narcotics
- ✕Gambling and casinos in any form
- ✕Fishing of species in CITES Appendix I
- ✕Extraction of natural coral for building materials, jewellery and souvenirs
- ✕Chemical weapons manufacturing
- ✕Industrial chemicals that deplete the ozone layer
- ✕Manufacture of alcoholic beverages, wine and malt drinks
How much capital a PT PMA needs
Two figures that are constantly mixed up. Both have applied since October 2025 under BKPM Regulation 5/2025.
| Item | Amount | Measured against |
|---|---|---|
| Paid-up capital | from IDR 2,500,000,000 | The company as a whole |
| Investment plan | above IDR 10,000,000,000 | Each five-digit KBLI and each location, excluding land and buildings |
The difference matters. What you actually have to deposit and evidence with a bank statement is IDR 2.5 billion. The figure above IDR 10 billion is a declared plan, which may be funded from retained earnings, shareholder loans or operating income. Paid-up capital cannot be withdrawn for 12 consecutive months from the date of deposit.
What a KBLI is, and why it is the decision that matters
KBLI is Indonesia's business classification. The code has five digits and it settles four things at once: whether a foreigner may own the company outright, how minimum capital is calculated, which risk level applies, and which licences are needed. Restrictions attach to the code, never to a loose industry label.
Risk level determines the paperwork under GR 28/2025.
| Risk level | What is required |
|---|---|
| Low | NIB business registration number only |
| Medium-low | NIB plus a standard certificate by self-declaration |
| Medium-high | NIB plus a certificate verified by the authority before operations start |
| High | NIB plus a full licence with substantive review |
A useful addition in the same rules: if the authority misses its statutory deadline, approval is deemed to have been granted.
The classification changed: KBLI 2025
This is recent and many have not caught up. Statistics agency regulation 7/2025, dated 18 December 2025, introduced a new edition and repealed KBLI 2020. There are now 22 categories instead of 21, with new codes for digital platforms, data centres, streaming and carbon capture, and the information and communication section split in two.
OSS moved to the new edition on 15 June 2026. Companies on KBLI 2020 codes are converted automatically at their next licensing application. If a company still carries codes from the 2009–2017 editions, however, there is no automatic conversion: the data must first be corrected in the AHU system. Accounts left unmigrated risk having new applications rejected.
Where foreign ownership is capped
The caps are specific rather than sweeping. The ones most likely to matter:
| Sector | Foreign ownership cap |
|---|---|
| Horticulture | 30% |
| Broadcasting, terrestrial and subscription | 20% |
| Newspaper and magazine publishing | 49% |
| Postal services | 49% |
| Interprovincial land transport | 49% |
| Sea and river transport | 49% |
| Construction services | 67%, or 70% for ASEAN investors |
Separately, some fields are reserved entirely for Indonesian capital: fish processing, batik, traditional cosmetics and handicrafts, hajj and umrah services, and traditional shipbuilding.
On construction, a caveat: some publications claim the 2025 rules removed the 67% ceiling. A more recent and more specific analysis, citing the article and the implementing circular, says the cap remains. We proceed on the basis that it does, and for a construction project we advise confirming this before structuring the deal.
Bali: 18 sectors closed to new foreign companies
This is the single most important thing to know in 2026 if you are setting up on the island. In a letter dated 28 January 2026 the Governor of Bali asked the investment ministry to restrict foreign companies in low and medium-low risk fields. The request was approved, and from the third week of May 2026 the province closed OSS access for new PT PMA applications across 18 sectors. It was announced publicly on 22 July 2026.
Legally this is not a new ownership law but a block in the licensing system. For a would-be founder the effect is the same: a new company under these codes cannot be registered in Bali.
- ✕Small hotels under 6,000 m² and budget hotels
- ✕Other accommodation
- ✕Real estate, owned or leased
- ✕Consulting: management and industrial
- ✕Car, bus, truck and motorcycle rental
- ✕Retail: clothing, textiles, food, mobile agricultural retail
- ✕Cafés and drinking establishments
- ✕Traditional medicine shops
- ✕Custom tailoring and dressmaking
- ✕Stadium facilities, fitness centres, sports event promotion
The official reasoning: authorities found that low-risk codes needing only an NIB were being used as an easy route to a residence permit, with no genuine business or investment behind them. The measure targets nominee arrangements and protects local small business.
What happens to companies already trading
Licences already issued are not revoked, and existing PT PMAs continue to operate. That is not a reason to relax.
- ✓All obligations remain, including the quarterly LKPM investment report
- ✓Any corporate change — amending the deed, replacing a director, adding an activity — triggers a review of the code. This is the practical trap
We covered the reporting calendar in our article on PT PMA reporting, and the difference between a foreign and a local company here.
What is not true, despite what you may read
There is a lot of rumour around the Bali restrictions. Separating it from fact:
- ✕An IDR 100 billion minimum investment for a PT PMA in Bali — a provincial proposal, not a rule in force, and one that conflicts with national regulation
- ✕A Bali-specific IDR 10 billion paid-up capital requirement — no reliable source confirms it; the national figure remains IDR 2.5 billion
- ✕A ban on virtual offices — officials announced closer scrutiny, not a prohibition
How we help
We match a KBLI code to what you will actually do and check whether it can still be registered in Bali before you spend money. Then PT PMA registration end to end, plus accounting and reporting. If the company exists mainly to secure a stay permit, start with our index of KITAS types and the investor KITAS threshold — there may be a simpler route.
Frequently asked questions
Can a foreigner own 100% of an Indonesian company?
Yes, by default. Since 2021 a Positive Investment List applies: a field is open to full foreign ownership unless it is expressly closed or capped. What must be checked is the specific five-digit KBLI code, not the industry as a whole.
How much capital does a PT PMA need?
Paid-up capital from IDR 2,500,000,000 for the company, and a declared investment plan above IDR 10,000,000,000 per KBLI code and per location, excluding land and buildings. Both figures have applied since October 2025.
Is it true Bali has closed some sectors to foreigners?
Yes. Since May 2026 the province has blocked OSS access for new PT PMA applications across 18 sectors: small hotels, real estate, consulting, vehicle rental, retail, cafés, fitness and others. Legally it is a filing block rather than a new ownership law.
What happens to my company if it already operates under a closed code?
Issued licences are not revoked. But all obligations remain, and any corporate change — amending the deed, replacing a director, adding an activity — triggers a review of the code.
Which KBLI edition is current?
KBLI 2025, introduced by a regulation dated 18 December 2025. OSS has run on it since 15 June 2026. Codes from the 2020 edition convert automatically at the next application; older editions must first be corrected in the AHU system.
Official sources: Bali provincial government on restricting OSS access, Presidential Regulations 10/2021 and 49/2021, BKPM Regulation 5/2025, GR 28/2025, BPS Regulation 7/2025 on KBLI 2025. Verified on 29 September 2026.
We check your KBLI code before you spend money
Tell us what you plan to do in Bali — we will pick the code, check whether it can still be registered, and give you a realistic budget.
PT PMA registration