Foreign investors can participate in Indonesia’s villa market, but they cannot use a PT PMA to operate conventional short-term villa accommodation under the applicable villa classification.
Under KBLI 2025, villa accommodation is classified as KBLI 55203 – Aktivitas Vila (Villa Activities), replacing KBLI 55193 under KBLI 2020. The activity is allocated to cooperatives and micro, small, and medium enterprises (UMKM), excluding a PT PMA from operating under this classification.
Long-Term Leasing or Short-Term Villa Accommodation?
Long-term property leasing and short-term villa accommodation are separate business activities.
A foreign-owned company may conduct a permitted property activity where its KBLI, investment structure, and property rights allow it. That does not permit the company to repeatedly offer the property to tourists for short stays under KBLI 55203.
This distinction directly affects the investment model. A villa that can legally generate income through an eligible longer-term lease cannot automatically be used to generate nightly or weekly accommodation revenue.
Before relying on rental income from an Indonesian villa, check the permitted structure with MAP Resources Indonesia: info@mapresourcesindonesia.com.
KBLI 2025 separates short-term accommodation for visitors and travellers from the provision of residential premises, which falls within real-estate activities.
What Has Changed for Foreign Villa Investors in Bali?
Bali introduced additional restrictions on foreign investment in 2026. The provincial government, following approval from the Ministry of Investment/BKPM, blocked new PMA licensing through OSS for 18 business classifications across the province.
The restrictions affect property and accommodation-related activities, adding a Bali-specific constraint to the national rules governing villa accommodation.
Bali authorities have also identified misuse of property-related KBLIs by foreign-owned companies. The Ministry of Investment specifically cited cases involving KBLI 68111 – Aktivitas Pengembangan Bangunan dan Lahan Hunian (Residential Building and Land Development Activities), where companies developed villas on leased land but subsequently used them as short-term tourist accommodation or private residences.
Investing in a Bali villa? Contact MAP Resources Indonesia at info@mapresourcesindonesia.com.
Bali’s 2026 restrictions are separate from the national treatment of villa accommodation. KBLI 55203 is already allocated to cooperatives and UMKM nationally, while Bali has restricted new PMA licensing for additional activities within the province.
The Bali restrictions apply to new PMA licensing for the affected classifications rather than automatically making existing foreign-owned companies illegal.
Can a Property Company Use Another KBLI to Rent Villas Short Term?
No. A property-related KBLI cannot be used as a substitute for the classification covering the activity actually conducted.
A PT PMA established for a permitted property activity does not gain the right to operate villas as short-term tourist accommodation simply because it owns, develops, leases, or otherwise controls the underlying property.
Unsure whether your property structure permits the intended villa activity? MAP Resources Indonesia can advise at info@mapresourcesindonesia.com.
Bali authorities have specifically identified this practice in relation to KBLI 68111, where villas developed on leased land were subsequently being used for short-term tourist accommodation.
If the commercial activity is villa accommodation, registering the company under a different property-related KBLI does not remove the restrictions applicable to that activity.
Why Are Online Villa Rentals Facing Greater Scrutiny?
Online marketing does not change the classification of the underlying business. Listing a villa through Airbnb or another booking platform does not establish that the operator is legally entitled to provide short-term accommodation.
For a PT PMA using a property-related classification while generating revenue from short-term tourist stays, digital listings can also make the difference between the company’s registered activity and its actual operations more visible.
Foreign investors should not include short-term villa bookings in projected returns unless the proposed operating structure is legally permitted to generate that revenue.
Invest in Indonesia’s Villa Market with MAP Resources Indonesia
Foreign investors can participate in Indonesia’s villa and property market, but short-term villa accommodation under KBLI 55203 is not available to a PT PMA.
Contact MAP Resources Indonesia at info@mapresourcesindonesia.com to discuss your villa investment in Indonesia.
