Bali’s foreign investment block is wider than the headline

In late July 2026, Governor Koster announced that eighteen business classifications are closed to new PT PMA registrations in Bali. The list runs from small hotels, real estate, cafés, vehicle rental and retail through to consultancy.

Anyone who has tried to file changes into OSS recently already knows the system is rejecting more than eighteen codes. It is rejecting new PMA applications across the entire Low and Medium-Low risk tiers for all PT PMAs located in Bali, or with a project address in Bali. The eighteen named codes are the announced face of a considerably wider operational block.

Three things follow from that, and they are the questions clients are asking most.

1. There is no published legal instrument to consult

The change was not made by amending the Positive Investment List under Perpres 10/2021. It is an administrative block inside OSS, effective since mid-May, roughly two months before it was announced. The ministerial approval, technical instructions and transitional provisions have not been published, to the best of our knowledge.

The rules live in how the system behaves rather than in a gazette. You cannot clear yourself by checking your KBLI against a list of eighteen. The question is your activity’s risk classification.

2. The quiet exposure is existing companies, not new entrants

Existing PMAs are not being closed, and licences that are live and valid are not being revoked. But if you add or remove a KBLI, move office, open a second location, or restructure capital, you will be touching OSS, and those changes may be treated as a new or amended application. The announcement is silent on all of it.

A café operating legally since 2022 may find that relocating from Canggu to Ubud is functionally impossible.

If you hold a low-risk KBLI in Bali, treat your current licensing configuration as an asset to preserve, and sequence any corporate action carefully.

3. KBLI 2025 renumbering may trigger reclassification

Some advisors suggest that a renumbered KBLI 2025 code might fall outside the restriction. That is not safe to assume. A renumbered code may carry a different risk classification, or trigger a system shut-down if the risk sits in the Low or Medium-Low tier.

What triggered this

Shell companies with virtual offices and NIB-only registrations competing with local MSMEs. That tells you the direction of travel, and the word for it is substance. Real premises, real activity, LKPM reports filed on time. Higher-risk classifications and well-capitalised structures with genuine operations remain open.

Worth doing this month

• Audit your KBLIs by risk classification, not just against the announced eighteen
• Review the next twelve months of planned corporate actions for OSS touchpoints
• Get your LKPM reporting current

The implementing rules are still taking shape, and practice inside OSS is changing week by week. We will keep clients updated as the picture becomes clearer.