On January 28, 2026, Bali Governor Wayan Koster sent an official letter to Indonesia’s Minister of Investment and BKPM, requesting the closure of PT PMA registrations for low-risk and medium-low-risk business activities in Bali. The same letter requested a ban on PT PMA using virtual office addresses in Bali. The document has since been applied inside the OSS system, meaning new registrations under these categories are being blocked. If you were planning to register a foreign company in Bali, or currently operate one under a virtual office address there, here is what you need to know and what you can do.
What the Governor’s Letter Actually Says
The letter, numbered B.27.000/642/PM/DPMPTSP, was addressed to the Minister of Investment and Downstream Industry (Menteri Investasi dan Hilirisasi) and signed by Governor Wayan Koster with urgent status (Sifat: Segera).
It cites data from 2021 to 2025: Bali registered 19,262 PT PMA (foreign-owned limited liability company) businesses, accounting for approximately 40 percent of all PMA registrations nationwide, with 55,458 registered projects in total. Of those projects, 47.55 percent were low-risk activities that required only a Business Identification Number (NIB) with no additional permit or standard certification.
Provincial authorities concluded that a significant share of these companies used low-risk business classifications in the OSS-RBA (Online Single Submission Risk-Based Approach) system primarily to obtain residency permits (KITAS) for foreign nationals, without running any real business or contributing to actual investment in Bali.
Based on this, the letter formally asks BKPM to execute closures in OSS for two specific categories:
1. PT PMA operating low-risk and medium-low-risk business activities with a Bali business address.
2. PT PMA using virtual office addresses as their registered business domicile in Bali.
Which KBLI Codes Are Named in the Letter
The Governor’s letter specifically lists nine KBLI (Klasifikasi Baku Lapangan Usaha Indonesia) codes that had been most commonly registered by PT PMA in Bali through the OSS system. All fall under low-risk or medium-low-risk classifications, meaning they only require an NIB to operate.
| KBLI Code | Business Activity |
|---|---|
| 68111 | Real Estate Owned or Leased |
| 70209 | Other Management Consulting Activities |
| 77311 | Motorcycle Rental Without Option |
| 77100 | Car, Bus, Truck and Similar Vehicle Rental |
| 79121 | Travel Agency Activities |
| 47711 | Retail Trade of Clothing |
| 47511 | Retail Trade of Textiles |
| 47249 | Other Retail Trade of Food |
| 47991 | Mobile Retail Trade of Agricultural Commodities |
If your intended business in Bali falls under one of these codes, you can expect a registration block in OSS when selecting a Bali business address or a virtual office domicile in Bali.
Also Read: How to Start a Business in Bali as a Foreigner
Why Bali Is Pushing These Restrictions
The concern here isn’t foreign investment broadly. Bali remains one of Indonesia’s strongest investment destinations. The problem is a specific pattern of misuse that built up over the 2021 to 2025 period.
Foreign nationals were registering PT PMA under one of the KBLI codes above, using a virtual office address as the company domicile, and then applying for an Investor KITAS through that company, without ever running a real business in Bali. The low-risk classification in OSS made this easy: no inspections, no additional permits, just a NIB.
Two things pushed the provincial government to act. Foreign-owned companies had been entering retail and service sectors designed for local Balinese micro and small businesses, crowding them out. And 47.55 percent of all PMA projects in Bali turned out to be low-risk activities with no real economic contribution to the province.
The Ministry of Investment has proposed additional interventions alongside the KBLI restrictions, including mandatory proof of paid-up capital for PMA operating in Bali and mandatory compliance documentation before commercial operations begin.
What This Means for You
For new investors, the practical effect is already in place. New PT PMA registrations under the affected KBLI codes with a Bali business address are being blocked at the OSS level. Virtual office domiciles in Bali face the same block for PMA companies.
For investors with an existing PT PMA in Bali, the risk depends on your situation. If your company runs a genuine operation with a real commercial address and actual revenue, the risk is lower. If the company was registered primarily as a residency vehicle with no real business activity, enforcement scrutiny is increasing through 2026. A quarterly LKPM reporting review is a practical first step to assess your compliance position.
Not sure if your Bali PT PMA is at risk?
InvestinAsia’s team in Jakarta and Bali can review your current structure and recommend the right next step.
The Compliant Solution: Register in Jakarta, Operate in Bali
The Governor’s letter targets PT PMA with a business address located within Bali. It does not restrict foreign investors from running businesses that serve the Bali market through a company domiciled elsewhere.
Register your PT PMA with a Jakarta business address, then add Bali as a secondary operational location through the OSS system. This is a standard structure under Indonesian company law, and the OSS-RBA platform handles it without any special workaround.
For a detailed comparison of what changes and what stays the same between Jakarta and Bali registration, see InvestinAsia’s guide on Jakarta and Bali PT PMA requirements.
Step 1: Incorporate Your PT PMA in Jakarta
Jakarta sits outside the scope of the Bali Governor’s letter. A PT PMA registered in Jakarta can use the affected KBLI codes, including management consulting, vehicle rental, and retail trade, without hitting the Bali-specific OSS block.
Jakarta has a dense commercial zone infrastructure and a wide range of virtual office providers in compliant business districts. Virtual offices there are still legally accepted as PT PMA domiciles outside of Bali, keeping early-stage setup costs manageable. For more on virtual office as domicile for foreign companies, Jakarta remains a fully viable option.
BKPM, the national investment authority, is headquartered in Jakarta. Regulatory processing and approvals happen faster here, without an additional layer of provincial-level restriction.
Step 2: Add Bali as a Branch Location in OSS
After your Jakarta PT PMA is incorporated and the NIB is issued, you can register Bali as an additional business location (lokasi usaha) under the same company through the OSS system. This is not a separate company. It is an extension of your existing entity.
With the Bali branch location registered, your company can operate legally in Bali, issue local tax invoices, hire staff under a local employment structure, and maintain a physical operational presence on the island.
Step 3: Use a Physical Business Address for the Bali Location
For the Bali branch specifically, a proper commercial address strengthens your compliance position significantly. Given the provincial government’s stated concern about virtual offices in Bali, using a serviced office or coworking space in a commercially zoned area for the Bali branch is the cleaner approach.
The Jakarta head office can still use a virtual office. The Bali operational address is where you want a verifiable physical presence, even a modest one.
A Note on PT PMA Capital Requirements
Capital requirements for a PT PMA are set at the national level and apply equally to Jakarta and Bali registrations. These rules have been updated recently under BKPM Regulation No. 5 of 2025. Rather than act on numbers that may be outdated for your specific KBLI code or business structure, speak directly with InvestinAsia’s consultants who work with current BKPM guidelines every day.
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Frequently Asked Questions
Does the Bali Governor’s letter apply to PT PMA already registered in Bali?
The letter primarily targets new registrations going forward. Existing PT PMA using virtual offices or operating under affected KBLI codes with no real business activity face growing enforcement scrutiny through 2026. A compliance review is the sensible first step if you are in this situation.
Can I get an Investor KITAS from a Jakarta PT PMA if I want to live in Bali?
Yes. An Investor KITAS is tied to your shareholding in a PT PMA, not to the province where the company is registered. A Jakarta-incorporated PT PMA can sponsor your Investor KITAS even if you live and operate in Bali. You will need to meet the standard capital and shareholding requirements, which an InvestinAsia consultant can walk you through.
Which KBLI codes are still open for PT PMA in Bali?
The restrictions specifically target low-risk and medium-low-risk classifications. Higher-risk KBLI codes, including hospitality, certain tourism operations, and manufacturing, have not been targeted by this proposal. Check the current OSS status of your specific code before proceeding, as the national review of additional KBLI closures is still ongoing.
Can I still use a virtual office for a PT PMA outside Bali?
Yes. The virtual office restriction in the Governor’s letter applies specifically to PT PMA using virtual offices as their registered domicile in Bali. Virtual offices remain a valid domicile option for PT PMA registered in Jakarta and other provinces, subject to local commercial zoning requirements.
How long does it take to set up a PT PMA in Jakarta with a Bali branch?
Incorporation timelines vary based on document completeness and the specific KBLI codes involved. For a realistic timeline specific to your situation, consult InvestinAsia directly. Attempting to estimate without knowing your full setup introduces too many variables to be useful.
References
Governor of Bali. (2026, January 28). Surat Gubernur Bali Nomor B.27.000/642/PM/DPMPTSP: Permohonan Penutupan PMA Tingkat Risiko Rendah dan Menengah Rendah serta PMA di Virtual Office di Provinsi Bali. Official letter addressed to the Minister of Investment and Head of BKPM. Retrieved from https://dpmptsp.bulelengkab.go.id/informasi/download/76_surat-gubernur-penutupan-pma-tingkat-risiko-rendah-menengah-rendah_2026-02-18-10-52-32.pdf
