Bali closes low-risk KBLI codes for foreign investors: what's already in force and what's coming next
Status as of 26 May 2026. Regulatory audit by Legal Indonesia.
If your PT PMA in Bali is registered under one of the so-called "easy" KBLI codes - management consulting, real estate, rentals, restaurants and cafes, travel agency, fitness - this article is for you. One KBLI code for foreign investors in Bali is already closed. Six more are in the queue. And the OSS (Online Single Submission) electronic registration system, according to legal portals reporting in May 2026, is already rejecting new applications from foreigners with a Bali address under low-risk categories - without waiting for the final ministerial decrees.
This is a follow-up to our article on the transition to KBLI 2025. But this time it is not about the technical migration of codes - it is about Bali launching, for the first time in Indonesia's history, a regional closure of KBLI codes targeted specifically at foreign investors.
What happened — a short timeline
28 January 2026. The Governor of Bali, Wayan Koster, sent an official letter to the Ministry of Investment (BKPM) marked "urgent". The key points:
Between 2021 and 2025, Bali issued 19,262 foreign company registrations - around 40% of the national total.
Almost half of the 55,458 projects are low-risk, requiring only a Business Identification Number (NIB) without additional certificates.
These codes are used as an "easy entry" by foreigners to obtain residence permits - without any actual business activity or investment.
The letter listed 9 KBLI codes and a request to ban the registration of foreign companies at virtual offices on Bali.
9 February 2026. Bali's Investment and One-Stop Service Office (DPMPTSP), led by I Ketut Sukra Negara, formally submitted the request to the Ministry. By this point the list was narrowed down to 7 KBLI codes: retail codes were removed, while restaurants and cafes, entertainment, and fitness were added.
February–March 2026. The Bali Provincial Legislative Council (DPRD) backed the initiative, and the Ministry gave a preliminary green light.
End of February 2026. First approval: KBLI 70209 - management consulting - was officially closed for new foreign companies in Bali.
March–May 2026. In practice, OSS started rejecting foreign company applications with a Bali address across a wider list of low-risk KBLI codes. According to legal consultants, Bali-based clients have been receiving automatic rejections.
According to the Ministry, 423 companies in Bali were sanctioned in 2025–2026 for operating outside their registered KBLI scope.
The 7 KBLI codes: closed and pending
KBLI | Activity | Status as of 26.05.2026 |
70209 | Management Consulting | Closed for new applications |
68111 | Real Estate (own/lease) | Under review |
79110 | Travel Agency Activities | Under review |
77100 | Car and Motorcycle Rental | Under review |
56100 | Restaurants and Cafes | Under review |
93290 | Other Amusement and Recreation | Under review |
93130 | Fitness Centers | Under review |
Important: even for codes marked "under review", OSS is already in practice rejecting new registrations with a Bali address. The Governor's letter is being used by the office as a working basis, without waiting for the final formal decrees.
In parallel — four additional measures
While discussing the Governor's request, the Ministry proposed four additional measures. As of 26 May, none of them have been formalised as a separate decree - but the office is already signalling enforcement:
Moratorium on the registration of foreign companies under KBLI codes with repeated violations.
Ban on virtual offices as the legal address for foreign companies in Bali.
Mandatory paid-up capital of IDR 10 billion specifically for foreign companies operating in Bali.
Compliance documentation required before commercial operations begin.
The virtual office point matters the most. If you were planning to set up a foreign company in Bali using a virtual office as the legal address - that window is closing. The Bali office is already refusing applications under KBLI 70209 with a virtual address, and selectively under other codes.
What it means for existing foreign companies
If your company is already registered under one of these 7 KBLI codes:
Your NIB stays valid. Current licenses remain in force. No one is forcibly revoking permits from already-operating companies.
Any change triggers reclassification. Changes in corporate documents, directors or commissioners, expansion of activities, adding new KBLI codes - all require a code review. And if your current KBLI is closed by then, you will not be able to come back to it.
Compliance under the microscope. 423 companies have already been sanctioned for code mismatches. If your actual activity is broader than what's registered - you are first in line for inspection.
Director KITAS. OSS, AHU (Ministry of Law) and Immigration now share data more closely than ever. Mismatches between registered and actual scope can surface at the next KITAS renewal.
Virtual office. If your company sits on a virtual office, it's wise to start planning the move to a physical address now - especially if any OSS or Ministry of Law update is coming within the year.
What it means for new investors
If you are only planning to set up a foreign company in Bali:
KBLI 70209 as the "easy door" for an Investor KITAS no longer works. Applications are automatically rejected.
For the other 6 codes, registration is formally still possible - but OSS is already selectively rejecting them. High risk of delays of several months or outright refusal.
Registration with a virtual office is risky. If the business plans to stay on a virtual office for more than 6–12 months, it's worth reconsidering the structure.
IDR 10 billion paid-up capital - not yet officially mandatory specifically for Bali, but actively discussed at the Ministry. Worth factoring into the financial model now.
In practice this means: if your plan is "I'll open a foreign company in Bali under consulting, sit on a virtual office, and get an Investor KITAS" - that path is closed. You'll need to either change the business model (a real operation with a real office and a meaningful KBLI) or look at other KITAS categories - Remote Worker (E33G), family (E31) and others.
Why this is different from regular regulatory changes
This is a regional initiative, not a nationwide one. In Jakarta, Surabaya, or Batam, the same KBLI codes work as before. The closure applies only to the Province of Bali. This is the first time in Indonesia that a region has pushed through the closure of KBLI codes on its own territory.
Practice is ahead of the law. OSS is rejecting applications on the basis of the Governor's letter, before formal decrees are issued. This is highly unusual - and a clear political signal that the capital is listening to Bali and is ready for strict measures.
In parallel, immigration enforcement is intensifying (Dharma Dewata task force, 165 deportations as of May 2026). The KBLI closure is part of a single policy targeting "fake foreign companies + illegal tourists", not a one-off measure.
Action checklist — before 18 June 2026
Check your current KBLI in OSS - exact name and code.
Compare against the list of closed and under-review codes (see the table above).
If your code is on the list - assess how well your actual activity matches what's registered.
If you are on a virtual office - plan the move to a physical address.
Check your migration date to KBLI 2025 - the deadline of 18 June 2026 applies regardless of the closure story.
Existing licenses - leave them alone unless necessary. Changing corporate documents or scope of activity right now means falling under the new rules.
Plan KITAS renewals in advance. If a director's KITAS expires in summer - renew now, while everything still works.
FAQ
Nothing urgent. The registration and licenses are still valid. Don't make changes to corporate documents or scope of activity without speaking to a lawyer. For a planned KITAS renewal - come in early so we can check how OSS will respond.
Check the current status of your OSS application with your agent. If the application isn't approved yet and the address is a virtual office, the risk of rejection is high. Consider switching to an unaffected KBLI code or changing the address.
Plenty. Manufacturing (with a real facility), IT development, education, medical services, export, construction, engineering, agriculture - these are open and usually do not fall into the "easy" categories. The closure targets "fake companies for KITAS purposes", not real business.
Yes, your current KITAS stays valid until expiry. But at renewal there may be additional questions about the company's actual activity. Prepare operational evidence - contracts, invoices, tax filings.
For KBLI 70209 - already approved by the Ministry. For the other six - expected "in the coming months". For virtual offices and IDR 10 billion capital - no specific timeline yet.
How we can help
Legal Indonesia performs KBLI audits and compliance checks for foreign companies across all affected categories. We:
Check whether your current KBLI matches your actual business activity.
Cross-check against the new Bali list - whether you fall under the closure.
Suggest alternative KBLI codes if your current code becomes unsafe.
Handle the move from virtual to physical office - without disrupting operations.
Support KITAS renewals under the new OSS rules.
