KBLI 2025 and the accommodation sector in Bali: understanding the transition for investors and operators.

"A project can appear fully licensed - with a valid NIB, a registered KBLI, and an auto-issued Standard Certificate from OSS - and still be operating under a classification framework that the law has since superseded. This is the current condition of a significant portion of Bali's accommodation market, and it has a defined resolution window."

The shift began on 18 December 2025, when Indonesia's Central Statistics Agency (BPS) enacted Regulation No. 7 of 2025, introducing KBLI 2025 — a comprehensive reclassification of all business activity codes in Indonesia. For the KBLI 2025 Bali accommodation, real estate and hospitality sector, it introduced something structurally important: specific, granular codes for accommodation activities that previously did not exist in the system.

The regulatory framework has been updated. The operational system that processes licenses — OSS-RBA — is still in the process of integrating it.

What changed with BPS Regulation No. 7 of 2025

Under KBLI 2020, accommodation businesses in Bali operated under broad, approximate codes. A villa rental was often registered under a general hospitality category or, in many cases, under a real estate management code that was not designed for short-term rental operations. The system tolerated this imprecision because the specific codes did not yet exist.

BPS Regulation 7/2025 introduced precision where there was approximation. The new KBLI 2025 framework includes dedicated codes for each accommodation format. All business actors are required to align their registered codes within six months of promulgation — by 18 June 2026.

Alignment deadline: 18 June 2026. All businesses must review and update their KBLI codes in OSS. Non-alignment may result in NIB complications, audit flags, and licensing issues at the point of renewal.

The gap between legal validity and operational integration

The new KBLI codes are legally binding. Their full integration into the OSS Risk-Based Licensing platform (OSS-RBA) — the system through which licenses are actually issued — is still in progress under Government Regulation No. 28 of 2025.

This means that a business applying for licensing today may find that the specific accommodation code it requires does not yet appear as a selectable pathway in OSS. The system may direct it toward the nearest available legacy code, issue a Standard Certificate automatically, and return a result that appears to confirm compliance. On paper, the business is licensed. In practice, it holds a provisional mapping that may require adjustment once final ministerial standards are implemented.

When classification mismatches become relevant

Temporary or approximate KBLI mappings do not create immediate problems. They surface at specific operational moments: when a TDUP (tourism business permit) is sought, when an environmental approval is processed, when a PBG or SLF inspection occurs, or when OSS cross-checks business activity data against taxation and AHU records.

At these points, a mismatch between declared activity and actual use can lead to reclassification, standardization requirements, or administrative review. As PP 28/2025 expands OSS interoperability across government systems, these checks are becoming progressively more systematic. The transition window is defined. Proactive alignment is more straightforward than retroactive correction.

The primary compliance consideration

The licensing concern is not operating without a KBLI. It is operating under a code that does not correspond to the actual tourism activity — and having that misalignment identified during enforcement, renewal, or cross-system verification.

Bali adds a further layer: spatial compliance requirements remain in force

The KBLI transition does not modify Bali's spatial requirements. Even where OSS licensing appears current, every accommodation project must independently satisfy KKPR spatial conformity, RDTR zoning alignment, tourism zone designation, and environmental compliance under Perda Bali No. 2/2023.

A project holding a valid NIB under an interim KBLI mapping can still be denied operational feasibility if zoning alignment cannot be verified at the regency level. The accommodation formats most affected by this layered compliance requirement are those located near LP2B-protected agricultural land, in residential zoning corridors, or in conservation buffer zones.

Indonesia Core Management

We support investors and operators through KBLI alignment, KKPR verification, and licensing pathway structuring. Each project is assessed individually to ensure that statistical classification, zoning, and licensing structure are aligned prior to development and prior to each compliance cycle.