Bali Proposes Closing 7 KBLI Categories to Foreign PMA: What Investors Need to Know in 2026

In February 2026, the Bali Provincial Investment and One-Stop Integrated Service Office (Dinas Penanaman Modal dan Pelayanan Terpadu Satu Pintu or DPMPTSP Provinsi Bali) formally submitted a proposal to the Ministry of Investment and Downstream Industry (Kementerian Investasi dan Hilirisasi) to close seven Business Classification Code (Klasifikasi Baku Lapangan Usaha Indonesia or KBLI) categories to foreign-owned companies in Bali.

As of the time of writing, one of those seven categories has already been approved and closed: management consulting services under KBLI 70209. The remaining six are under national review. For any foreign investor currently operating in Bali or planning to incorporate a Foreign Investment Company (Perseroan Terbatas Penanaman Modal Asing or PT PMA) in the coming months, this development is not background regulatory noise. It is an active policy intervention with direct consequences for KBLI selection, existing license validity, and the viability of business models that have been standard in Bali’s foreign investment market for years.

Why Bali Is Moving to Close These Categories

The rationale behind the proposal was stated directly by DPMPTSP head I Ketut Sukra Negara: the seven targeted KBLI categories have been systematically misused by PT PMA entities, often to crowd out local businesses or to establish a foothold in sectors that were never intended for large-scale foreign capital under Indonesia’s investment framework.

The concerns driving this policy move are substantive. In 2024, Bali recorded more than IDR 18 trillion in realized foreign direct investment, nearly ten times its level from 15 years earlier. That growth has been accompanied by widespread compliance failures, including PT PMA entities registered under real estate development codes that were actually operating short-term rental businesses, management consulting registrations used as vehicles for acquiring residential or commercial property, and virtual office addresses used solely to obtain business identification numbers and immigration permits without any operational presence in Bali.

These abuses were not isolated. They were systematic enough to prompt the Ministry of Investment to propose four structural interventions alongside the KBLI closures: a moratorium on KBLI categories with repeated violations, a ban on PT PMA entities using virtual offices as official business addresses in Bali, mandatory proof of IDR 10 billion paid-up capital specifically for PT PMA companies operating in Bali, and mandatory compliance documentation before commercial operations begin. The KBLI closure proposal is the most targeted of these four interventions, and it is the one with the most direct impact on existing and prospective investors.

The Seven KBLI Categories Proposed for Closure

The seven categories submitted in the DPMPTSP’s February 2026 proposal all fall under low-risk and medium-low-risk business classifications. This is by design. The policy concern is that low-risk classifications under the Online Single Submission Risk-Based Approach (Sistem OSS Berbasis Risiko or OSS RBA) have been attractive to PT PMA entities precisely because they require minimal documentation and carry limited regulatory oversight, making them easy to obtain and easy to misuse.

Based on the confirmed DPMPTSP proposal and the categories identified in enforcement proceedings through early 2026, the seven sectors are listed below. Four of these codes were explicitly named by DPMPTSP head I Ketut Sukra Negara in public statements: KBLI 68111 (real estate), KBLI 70209 (management consulting), KBLI 79110 (travel agency), and KBLI 77100 (motorcycle rental). The remaining three are identified from enforcement proceedings and the categories most heavily monitored by the DPMPTSP in 2025 and early 2026. As the full official list has not been published in a single public document at the time of writing, investors are advised to verify the current status of their specific KBLI code directly with the Bali DPMPTSP or through a licensed incorporation consultant before making any corporate decisions.

Real Estate Activities (KBLI 68111) 

This is the highest-profile of the seven. KBLI 68111 covers real estate development on owned or leased land. It has been used extensively by PT PMA entities to build villa developments that are subsequently operated as short-term tourism accommodation, which falls under a different and more heavily regulated KBLI category. The mismatch between the registered activity and the actual operation is the compliance violation that authorities have been identifying through field inspections since 2024.

Management Consultancy and Head Office Activities (KBLI 70209) 

This is the only category that has been formally approved for closure as of early 2026. New PT PMA entities can no longer activate KBLI 70209 in Bali. Existing entities holding this code remain subject to supervision and enforcement, but their current licenses are not retroactively invalidated.

Travel Agency Activities (KBLI 79110) 

Biro perjalanan wisata was identified by the DPMPTSP as a category frequently used by foreign investors to establish a PT PMA that then expands into unrelated activities including property rental and tourism accommodation management.

Motorcycle and Scooter Rental (KBLI 77100) 

Penyewaan motor is one of the most visible sectors in Bali’s tourism economy and one where local businesses have been most directly displaced by foreign-owned operators. Closing this category to PT PMA would reserve it exclusively for domestic enterprises.

Restaurant and Other Food Service Activities (KBLI 56100 series) 

Food and beverage operations at the small and medium scale have been identified as sectors where PT PMA registration has crowded out MSME-level local businesses. The concern is particularly acute in Canggu, Seminyak, and Ubud, where PT PMA entities have established cafes and restaurants at price points and marketing scales that domestic operators cannot match.

Other Amusement and Recreation Activities (KBLI 93290) 

This category covers a range of recreational businesses including surfing schools, yoga studios, and wellness centers, all of which are dominant economic activities in Bali’s tourism-oriented southern districts and areas where foreign-owned operators have grown rapidly.

Fitness Center and Physical Activities (KBLI 93130) 

Gym and fitness facility operations, along with similar wellness-oriented businesses, round out the seven categories under review.

It is important to note that as of the date of this article, only KBLI 70209 has been formally closed at the national level. The remaining six are proposed closures pending ministerial approval from the Ministry of Investment and Downstream Industry. The status of each can change without advance notice. Given that the complete official list of the seven KBLI codes has not been published in a single government document at the time of writing, the specific codes identified in this article should be treated as indicative rather than exhaustive. Investors with exposure to any of the listed categories should verify the current status directly with the Bali DPMPTSP or the Ministry of Investment before taking any corporate action.

What This Means for Existing PT PMA Entities in Bali

For PT PMA entities already operating in Bali under one of the seven proposed KBLI categories, the immediate compliance position is as follows.

Existing licenses are not retroactively cancelled by the proposal or the closure of KBLI 70209. A company that currently holds a valid Business Identification Number (Nomor Induk Berusaha or NIB) under one of the proposed categories can continue operating under supervision. However, the DPMPTSP has made clear that enforcement will focus on two things: whether the company’s actual activities match its registered KBLI code, and whether the company is seeking to expand its activities or obtain new licenses under that code.

The practical consequence is that any PT PMA entity currently operating under one of the proposed categories should not apply for new licenses, expand its registered activities, or attempt to modify its NIB under those codes while the proposal is under review. Any such action creates an enforcement trigger.

For companies that have been using KBLI 70209 for management consulting and whose actual business activities fall within that description, the closed status means that entity cannot renew under that code if it needs to modify its corporate structure. The current NIB remains valid, but any change to the corporate deed, director composition, or business activity that requires a new OSS filing will need to be structured under an alternative classification.

For companies that were using KBLI 70209 as a holding code for other activities, which the DPMPTSP explicitly identified as a misuse pattern, the closure creates a more pressing compliance problem. These entities are exposed to enforcement action if their actual activities do not match their registered classification, independent of the KBLI closure.

What This Means for New PT PMA Incorporations in Bali

For investors planning to incorporate a PT PMA in Bali in 2026, the KBLI closure proposal introduces a constraint that was not present twelve months ago.

The most important practical step is to verify the current status of any intended KBLI code directly through the OSS system and through a licensed incorporation consultant before proceeding. KBLI 70209 is confirmed closed. The remaining six may be closed with ministerial approval at any point. Relying on advice or templates from 2024 or early 2025 is not safe for KBLI selection in Bali in 2026.

For investors in the tourism and hospitality sector, the closure of KBLI 68111 if approved would affect the most common PT PMA structure used for villa development and resort investment in Bali. If this closure proceeds, foreign investors would need to structure their operations through alternative classifications or through partnerships with domestic entities that can hold the tourism accommodation codes that are reserved for MSME operators. Both approaches are viable, but both require more careful legal planning than a straightforward KBLI 68111 incorporation.

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For investors in food and beverage, recreational, and wellness sectors, the proposed closures of KBLI 56100, 93290, and 93130 represent a direct challenge to business models that have been operating without significant restriction under the positive investment list framework. If these closures are approved, new PT PMA entities could not directly register in these categories at all, and existing ones would face the supervision regime described above.

It is also worth noting the broader compliance context in which these closures are occurring. The KBLI 2025 update under BPS Regulation No. 7 of 2025, which has a transition deadline of 18 June 2026, requires all PT PMA entities to align their existing KBLI codes with the new classification system. Any PT PMA that needs to update its KBLI codes for the 2025 transition and whose current codes are in the proposed closure list will need to resolve both issues simultaneously. Attempting to migrate to an equivalent code under the new framework while that code is under review for closure in Bali creates a specific compliance complexity that should be assessed before any OSS filing is made.

The Virtual Office Prohibition

Alongside the KBLI closures, the Ministry of Investment has proposed a ban on PT PMA entities using virtual offices as official business addresses in Bali. This proposal is directly connected to the KBLI enforcement issue: many of the compliance violations identified in Bali involved entities that held a virtual office address for OSS registration and KITAS purposes but had no actual operational presence at that address.

For PT PMA entities currently using a virtual office address in Bali, this proposed ban creates a need to assess whether their current address arrangement will remain compliant under the revised framework. The ban has not yet been formally implemented at the national level, but the DPMPTSP has already signaled that companies using KBLI 70209 specifically cannot activate through virtual office addresses. This restriction is already in effect for that closed category.

For new incorporations, establishing a genuine operational address in Bali is a practical step that both satisfies the emerging regulatory expectation and reduces exposure to the enforcement activity that the DPMPTSP has signaled is intensifying through 2026.

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What Investors Should Do Now

For PT PMA entities already operating in Bali, a KBLI compliance audit is the most important immediate step. This means verifying that the company’s registered KBLI codes accurately reflect its actual revenue-generating activities, that the company is not using a low-risk classification as cover for activities that require a different code, and that the company’s address arrangement meets the operational presence standard that the DPMPTSP is now applying in its supervision activities.

For investors planning to incorporate in Bali, the KBLI selection process requires more careful analysis in 2026 than it did previously. The combination of the national KBLI 2025 transition deadline in June, the confirmed closure of KBLI 70209, and the six additional proposed closures creates a landscape where selecting the wrong code at incorporation creates compliance exposure within months rather than years.

XPND’s team in Bali works with foreign investors on PT PMA establishment, KBLI selection, and ongoing compliance management across Bali, Lombok, and the surrounding islands. For investors who need to assess whether their current KBLI codes are in the proposed closure list and what their options are, or for new investors who want to structure their Bali incorporation correctly from the outset given the current regulatory environment, our Bali office is the appropriate starting point.

For investors who are not yet incorporated and are evaluating whether a PT PMA remains the right structure for their intended Bali business activities, the PT PMA service page covers the current incorporation framework and how KBLI selection intersects with the Bali-specific regulatory context.

A free initial consultation is available for both existing entities assessing their compliance position and new investors planning their entry. Contact our team here.