The question behind the question
Investors usually ask “do I need a company?” when the real question is “what am I going to do with this property?” The structure follows the activity.
You probably need a PT PMA if…
- you will rent the villa to guests or tenants as a business;
- you are developing units to sell or rent;
- you want to hold HGB (right to build) for a project;
- you have partners and need a vehicle to hold the investment and share returns;
- you want an investor visa tied to the company.
You probably don’t if…
- you are leasing or buying one home for your own use;
- you are holding land for the long term without operating a business on it yet.
In those cases a well-drafted lease, or Hak Pakai on a residential property within the legal limits, may be simpler and cheaper.
What a PT PMA involves
Capital
BKPM Regulation 5 of 2025, in force since 2 October 2025:
- Minimum paid-up capital: IDR 2.5 billion (previously IDR 10 billion).
- Total planned investment: more than IDR 10 billion per business code (KBLI), excluding land and buildings — except for property development and accommodation, where land and buildings count.
Interpretations differ on how the paid-up capital applies with several business codes and for investor visas. We confirm this with the notary for each structure.
Business codes
Each activity needs the right KBLI code, and each code has its own rules on foreign ownership. From June 2026 new registrations use the KBLI 2025 classification.
Bali restrictions (2026)
Since mid-2026 the OSS system blocks new foreign-company applications in Bali for 18 business codes, announced by the Governor in July 2026 with the Minister of Investment’s approval. The reported list includes small hotels, other accommodation, real estate owned or leased, vehicle rental and management consulting. Whether a specific villa-rental code is affected must be checked at the time of set-up.
Ongoing obligations
- Quarterly investment reports (LKPM) by the 15th of the month after each quarter.
- Tax registration and monthly and annual filings.
- Building permits (PBG, SLF) for the business to operate legally.
Common mistakes
- Setting up the company before checking the business code — then finding the activity is closed or restricted.
- Using a nominee instead of a company. Void by law; in Bali expressly prohibited since 2026.
- Copying a shareholders’ agreement from abroad without aligning it to Indonesian company law.
- Treating capital and reporting as formalities. Missed LKPM reports and unrealised investment create problems when licences are reviewed.
From our work
On a 13-residence development in Cemagi, the shareholder agreement had to be adapted from a European draft to Indonesian company law and to the business-code rules before the company and land lease could be finalised. It is typical: the structure is designed around the project, not copied from a template. See the case study.
Where ICM fits
We decide with you whether a company is needed, check the business code, design the shareholding and coordinate the notary and OSS registration. See PT PMA and foreign investment structuring.
General information as of the review date. Rules on foreign investment in Bali changed in 2025–2026 and may change again; confirm the current position before acting.