A PT PMA buying or developing property in Indonesia has to clear two separate money thresholds, not one. Peraturan Menteri Investasi dan Hilirisasi/Kepala BKPM Nomor 5 Tahun 2025 sets a paid-up capital floor of Rp2,500,000,000 for every PT PMA, and a separate investment value threshold above Rp10,000,000,000 that applies specifically to property, hospitality, and agricultural businesses. Article 27 then locks whatever capital is deposited for at least 12 months. Three distinct rules, and mixing them up is the most common capital-planning mistake we see from foreign property investors, including a cross-reference quirk in Article 27 that most guides on this topic never mention.
Two Different Numbers Under the Same Regulation
Article 26(2) of BKPM Regulation 5/2025 sets the general rule: a PT PMA needs a total investment value above Rp10 billion, excluding land and buildings, per five-digit KBLI code per project location. This figure describes the project’s planned spend, the number reported in the OSS system when applying for a business license. It is not the amount that has to sit in the company bank account.
Separately, Article 26(9) states that PT PMA entities must also meet a minimum paid-up capital requirement, and Article 26(10) sets that figure at Rp2,500,000,000 per company. This is the actual capital shareholders place into the company, distinct from the project’s total investment plan. Anyone comparing this rule to how a PT PMA is structured for other sectors will recognize the same Rp2.5 billion floor.
The Property-Specific Rule in Article 26(6)
Property is one of six sectors, alongside short and long-term accommodation, farming, plantations, livestock, and aquaculture, where Article 26(5) changes how the Rp10 billion investment value is calculated. For these sectors, land and building value counts toward the threshold, rather than being excluded as it is for most other industries.
Article 26(6) then splits property projects into two categories. A whole building or an integrated housing complex must show an investment value above Rp10 billion including land and buildings. An individual property unit, meaning anything that is not a full building or a full complex, must show an investment value above Rp10 billion excluding land and buildings. A single apartment purchase and a full residential complex are measured on different bases under the same article, regardless of which city the project is in.
This split applies wherever the property sits in Indonesia, and it affects anyone weighing whether they even need a PT PMA to hold the asset. Foreign individuals cannot hold registered land rights directly, which is why a PT PMA is generally the vehicle used to acquire property titles like HGB or Hak Pakai in the first place.
Paid-Up Capital: The Rp2.5 Billion Floor That Applies Regardless of Sector
Whatever the investment value works out to under Article 26(6), the paid-up capital obligation under Article 26(10) stays at Rp2,500,000,000 per PT PMA. This is confirmed by InvestinAsia’s dedicated breakdown of the paid-up capital rule, and it lines up with the exact wording of Article 26(9) to (10), which does not carve out an exception for property.
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The 12-Month Lock-Up Under Article 27
Article 27(1) states that the deposited capital cannot be moved out of the company’s bank account for at least 12 months from the date it was placed, unless the funds are used for buying assets, constructing a building, or covering the company’s operations. Article 27(2) requires this to be formalized as a self-declaration submitted through the OSS system when the business license is requested, using the standard format in Lampiran I of the regulation. Article 27(4) makes clear that breaching this declaration carries administrative sanctions.
A property PT PMA cannot deposit the required capital and immediately transfer it back out, and cannot use the deposited funds for anything other than the company’s own asset purchases, construction, or operating costs during that first year.
A Drafting Detail Worth Knowing Before You Structure Capital
Here is the part most articles on this topic miss. Article 27(1) does not say the lock-up applies to the capital defined in Article 26(10), the general Rp2.5 billion paid-up capital rule. It literally says: “Modal ditempatkan/disetor sebagaimana dimaksud dalam Pasal 26 ayat (6),” meaning the capital referred to in Article 26(6), which is the property-specific investment value provision, not the paid-up capital provision.
Read strictly, that is an odd cross-reference, because Article 26(6) never uses the term “modal ditempatkan/disetor” at all. It only talks about “nilai investasi,” investment value. The provision that actually defines paid-up capital sits three paragraphs later, in Article 26(10). The most likely explanation is a drafting or numbering slip carried through to the gazetted text, since Article 26(6) has no capital-deposit concept for Article 27 to logically point back to.
We cannot confirm with certainty how BKPM will apply this in practice, and we have not seen an official clarification or errata on it. What we can confirm, having checked the gazetted PDF directly, is that the cross-reference to Article 26(6) is exactly as written above, and it creates a genuine textual ambiguity for property PT PMA entities specifically. Do not assume either reading without written confirmation for your own case.
Notes from InvestinAsia Consultants
We have seen this cross-reference trip up first-time applicants who assume Article 27’s lock-up automatically ties to whichever number is larger. In the OSS applications we have handled, the self-declaration is tied to the Rp2.5 billion paid-up capital that was actually deposited, since that is the only figure the system tracks as a bank-account balance. Until BKPM issues a clarification, get your notary or BKPM-facing consultant to confirm the applicable figure in writing before submitting the Article 27 self-declaration.
What This Means for Capital Planning
For a foreign investor buying a single property unit through a PT PMA, the working numbers under the general reading are: paid-up capital of at least Rp2.5 billion placed in the company account, an investment value above Rp10 billion excluding land and building for a standalone unit, and a 12-month restriction on moving the deposited paid-up capital except for asset purchases, construction, or operations. For a whole building or an integrated housing complex, the Rp10 billion investment-value threshold includes land and building, which tends to be reached faster once actual land prices in cities like Jakarta or Bali are factored in.
A wrong assumption at this stage is expensive to unwind once the deed is signed and the OSS declaration is filed. Getting the entity set up correctly, with the capital structure and self-declaration matched to how the project is actually classified, is worth routing through InvestinAsia’s PT PMA registration service rather than piecing it together from separate sources.
Common Mistakes to Avoid
Some investors treat the Rp10 billion investment value as the amount that must be wired into the company bank account, when it is actually the Rp2.5 billion paid-up capital figure that gets deposited and locked. Others assume the 12-month lock applies to any transfer at all, when Article 27(1) explicitly permits use for asset purchases, building construction, and operational costs. Skipping the self-declaration step in OSS is another one we see often, and it triggers administrative sanctions under Article 27(4) regardless of whether the underlying capital was placed correctly. InvestinAsia’s own rundown of common PT PMA setup mistakes covers several of these in more detail.
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References
1. Kementerian Investasi dan Hilirisasi/BKPM. (2025). Peraturan Menteri Investasi dan Hilirisasi/Kepala Badan Koordinasi Penanaman Modal Nomor 5 Tahun 2025 tentang Pedoman dan Tata Cara Penyelenggaraan Perizinan Berusaha Berbasis Risiko dan Fasilitas Penanaman Modal Melalui Sistem OSS, Articles 25 to 27.
https://jdih-storage.bkpm.go.id/jdih/jdih/2025Permeninvesthil005-.pdf
2. Badan Pemeriksa Keuangan. Peraturan Menteri Investasi/BKPM Nomor 5 Tahun 2025, regulation record.
https://peraturan.bpk.go.id/Details/332573/permeninvesbkpm-no-5-tahun-2025
