Setting up a PT PMA in Bali does not automatically mean that a foreign investor can choose any business activity. Before establishing a company, foreign investors should check whether the intended business activity is open to foreign investment, subject to specific conditions, or completely closed.
The key reference is the Indonesian business classification system, known as KBLI (Klasifikasi Baku Lapangan Usaha Indonesia), together with Indonesia’s investment regulations and the licensing requirements applicable to the specific business activity.
For companies being established in 2026, investors should also be aware of the transition to KBLI 2025 and make sure the business activity is classified under the correct five-digit KBLI code.
What Is KBLI and Why Does It Matter for a PT PMA?
KBLI is Indonesia’s official system for classifying business activities. When establishing a PT PMA (foreign investment company), the company must select one or more KBLI codes that accurately describe the activities it intends to conduct.
The KBLI code can affect:
- whether foreign investment is permitted;
- whether foreign ownership is limited;
- whether an Indonesian partner or cooperative/UMKM partnership is required;
- whether special business licences are required;
- the minimum investment requirements; and
- the permits and operational requirements that apply to the business.
This means choosing a KBLI code is not simply an administrative step. An incorrect classification can create problems when applying for an NIB, business licences, or operating approvals.
Are There Any KBLI Codes Completely Closed to PT PMA?
Yes. Indonesian investment regulations provide that certain business activities are closed to investment.
Under the current investment framework, the six categories of business activities that are closed include:
| Closed business activity | General description |
| Cultivation and manufacturing of Class I narcotics | Production and cultivation of prohibited narcotics |
| Gambling and/or casinos | All forms of gambling and casino activities |
| Fishing of protected CITES-listed species | Catching certain protected fish species listed under CITES |
| Coral extraction from nature | Certain activities involving the taking or use of natural coral |
| Chemical weapons manufacturing | Manufacturing chemical weapons |
| Certain industrial chemicals and ozone-depleting substances | Activities involving specified hazardous chemicals and ozone-depleting substances |
These restrictions apply nationally. They are not special “Bali restrictions”; rather, they are part of Indonesia’s national investment framework.
For a foreign investor, the practical consequence is straightforward: a PT PMA cannot be established to conduct a business activity that is legally closed to investment.
Specific KBLI Codes That Are Closed to Investment
There are also specific alcohol-related KBLI codes that are expressly classified as closed to investment under the current investment regulation.
| KBLI | Business activity | PT PMA status |
| 11010 | Manufacture of distilled alcoholic beverages | Closed to investment |
| 11020 | Manufacture of wine | Closed to investment |
| 11031 | Manufacture of malt beverages | Closed to investment |
These codes should not be confused with every business that sells or serves alcoholic beverages.
For example, a restaurant, hotel, bar, retailer, or distributor dealing with alcoholic beverages may fall under a different KBLI and may be subject to specific licensing and investment conditions rather than being automatically prohibited.
This distinction is important when assessing a proposed Bali business.
Does “Restricted” Mean the Business Is Completely Prohibited?
No.
This is one of the most important points for foreign investors.
Indonesia’s investment framework generally divides business activities into several categories. A business can be:
| Category | What it means for a PT PMA |
| Closed to investment | Foreign investors cannot establish a PT PMA for that activity |
| Open with specific conditions | Investment is permitted but may be subject to foreign ownership limits, Indonesian participation, licensing or other requirements |
| Reserved for or requiring partnership with cooperatives/UMKM | Certain activities may be allocated to Indonesian cooperatives or micro, small and medium enterprises or require a partnership |
| Open to all investors | Foreign investment can generally be made, subject to applicable licensing and other requirements |
Therefore, finding that a KBLI is not on the closed list does not automatically mean that a foreign investor can own 100% of the business.
The foreign ownership rules and other requirements must also be checked.
What About KBLI Codes With Foreign Ownership Restrictions?
Some business activities are open to investment but have additional requirements.
Depending on the activity, these may include:
Foreign ownership limitations. Certain sectors may limit the percentage of shares that can be owned by foreign investors.
Indonesian partnership requirements. Certain activities may require cooperation with an Indonesian cooperative or UMKM.
Special licences. Regulated sectors such as financial services, healthcare, transportation, telecommunications and other regulated industries may require approvals from the relevant government authority.
Location or sector-specific requirements. The business may need to comply with zoning, spatial-planning, environmental, building or sector-specific rules before it can operate.
For this reason, an investor should not determine whether a business is suitable for a PT PMA by looking only at the KBLI title.
What Does This Mean for Bali Businesses?
Bali does not have a completely separate foreign investment blacklist.
The main foreign investment restrictions come from national Indonesian regulations. However, a Bali business may face additional requirements relating to the location and the actual operation of the business.
This is particularly relevant for foreign investors entering the Bali property, hospitality, tourism, food and beverage, wellness and lifestyle sectors.
For example, an investor planning to establish a villa business should not simply choose a KBLI based on the word “villa.” The investor should first determine what the company will actually do.
Is it:
- operating accommodation for guests;
- managing property for other owners;
- leasing property;
- providing hospitality services;
- developing property; or
- providing a different type of tourism-related service?
The correct KBLI can be different depending on the actual business model.
The same principle applies to restaurants, property management companies, construction businesses, real estate activities and digital businesses.
KBLI 2025: An Important Change for New Companies in 2026
Foreign investors establishing a new company in 2026 should also pay attention to KBLI 2025.
The Indonesian Central Statistics Agency (BPS) released KBLI 2025 as an updated classification system. The new classification introduces changes to certain business activities and provides more detailed classifications for some emerging sectors.
The transition also affects how older KBLI 2020 codes are mapped to KBLI 2025.
For new PT PMA registrations, investors should therefore avoid relying solely on an old KBLI list or an outdated article published several years ago.
The current KBLI classification should be checked through the OSS system, together with the applicable investment restrictions and licensing requirements.
Is Every Business in Bali Open to Foreign Investors?
No.
However, it is also incorrect to assume that most businesses in Bali are prohibited for foreigners.
Indonesia’s investment system follows the principle that business activities are generally open to investment unless they fall within a closed category or are subject to specific conditions.
For many common foreign-investor businesses in Bali, the real issue is therefore not whether the business is completely prohibited, but whether the proposed structure complies with the applicable requirements.
For example, a foreign investor may need to consider:
| Question | Why it matters |
| Is the KBLI open to foreign investment? | Determines whether a PT PMA can conduct the activity |
| Is foreign ownership restricted? | Determines the permitted shareholder structure |
| Is an Indonesian partner required? | May affect the company structure |
| What is the minimum investment requirement? | Important for PT PMA registration and business planning |
| What licences are required? | An NIB alone may not be sufficient |
| Is the proposed location permitted? | Zoning and spatial-planning rules may apply |
| Does the actual activity match the KBLI? | Prevents licensing and compliance problems |
| Are sector-specific regulations applicable? | Additional regulators may be involved |
Minimum Investment Is a Separate Issue From KBLI Restrictions
Foreign investors should also distinguish between whether an activity is open to foreign investment and how much investment the PT PMA must plan.
Under the current risk-based business licensing framework, the OSS system checks foreign investment requirements based on the business activity and KBLI.
As a general rule, the minimum investment requirement for a PMA is more than IDR 10 billion per five-digit KBLI per business location, excluding land and buildings, subject to specific exceptions provided by the regulations.
This means that an activity being “open” to foreign investment does not mean that an investor can establish a PT PMA with a small business investment simply because the company itself has a relatively modest operating budget.
The investment requirement should be reviewed together with the company’s intended activities and structure.
Can a PT PMA Have More Than One KBLI?
Yes, a PT PMA can generally have multiple business activities, provided that the activities are legally compatible with the company’s purpose and are permitted for foreign investment.
However, adding more KBLI codes is not necessarily better.
Each additional activity should be reviewed to determine whether it creates additional licensing, investment, ownership or regulatory requirements.
For example, a company that wants to combine property development, construction, property management and accommodation operations should not assume that one general KBLI will cover everything.
The company should identify the actual activities it intends to perform and select the appropriate KBLI codes.
What Should Foreign Investors Check Before Establishing a PT PMA in Bali?
Before signing the company’s establishment documents, a foreign investor should conduct a KBLI and investment eligibility check.
The review should start with the actual business model rather than the KBLI code.
First, define exactly what the company will sell, operate or provide.
Second, identify the appropriate KBLI 2025 code.
Third, check whether the activity is closed, open with conditions, or generally open to foreign investment.
Fourth, check foreign ownership, Indonesian partnership and licensing requirements.
Finally, review the proposed business location, investment amount and operational permits.
This approach is particularly important in Bali because a business may appear commercially straightforward but still require additional checks relating to tourism, land use, building, environmental requirements or local licensing.
Common Mistakes Foreign Investors Make
One common mistake is choosing a KBLI because the description sounds similar to the intended business.
Another is assuming that “not on the closed list” means “100% foreign-owned.” This is not necessarily correct.
A third mistake is using an outdated KBLI 2020 code without checking the KBLI 2025 conversion.
Foreign investors should also avoid registering activities that the company does not actually intend to conduct simply to make the company appear more flexible.
The KBLI should reflect the company’s real business activities and be supported by the appropriate licences.
Conclusion: Check the KBLI Before Setting Up Your Bali PT PMA
For a foreign investor planning to establish a PT PMA in Bali, checking the KBLI should be one of the first legal steps—not something done after the company has already been incorporated.
The current Indonesian framework does not create a general Bali-specific list of prohibited KBLI codes. Instead, national investment regulations determine which activities are closed, which are open subject to conditions, and which can generally be conducted by foreign investors.
The most clearly identified closed activities include narcotics-related activities, gambling and casinos, certain protected-species fishing and coral extraction, chemical weapons manufacturing, specified hazardous chemical activities, and the expressly listed alcoholic beverage manufacturing codes 11010, 11020 and 11031.
For other businesses, the key question is often not simply “Can a foreigner own this business?” but rather “Under what structure and conditions can this business legally operate in Indonesia?”
