The eight files that need to agree
1. Spatial use
Confirm that tourist accommodation is compatible with the parcel under the applicable spatial plan. The formal route may involve a detailed spatial plan (RDTR) and a spatial-use compatibility approval (KKPR). Government Regulation 21/2021 is the national framework for spatial planning. The official OSS guide to KKPR and RDTR explains the digital route.
Keep the dated official result used for the project. A map colour used by an agent, an old screenshot or a neighbour's activity is not a planning decision for the parcel.
2. Land right and operating authority
Check the registered land right, its lawful holder and the contract that allows the project company or operator to use the property. A foreign individual cannot hold Hak Milik freehold title directly. A long lease must state the term, renewal mechanics, permitted use, building rights, assignment conditions and what happens to improvements at expiry.
Ownership and operating authority are different questions. A company may have permission to run accommodation without owning the land, but its lease and corporate documents must give it enough authority to do so.
3. Building approval and completed-building status
The building file is separate from the tourism licence. Compare the physical villa with its building approval (PBG), approved drawings and permitted use. Then check the certificate of proper function (SLF) for the completed building. Government Regulation 16/2021 sets the national building framework, and applications are handled through the official SIMBG portal.
Extensions, additional bedrooms, enclosed terraces and changes of use deserve particular attention. A PBG for an earlier design does not describe work added later.
4. Business classification and OSS licence
Government Regulation 28/2025 governs risk-based business licensing through the Online Single Submission system (OSS). A business identification number (NIB) identifies the operator, but it does not replace every approval or standard attached to the activity.
The classification needs a careful date check. Tourism Ministry Regulation 6/2025 still presents the Villa standard under KBLI 55193, the code used in KBLI 2020. The official KBLI 2020 entry remains visible in OSS. The official KBLI 2025 publication and crosswalk places Aktivitas Vila under 55203. Before filing, confirm the live code and transition treatment in the current OSS portal.
When the regulation was issued, the Villa standard in Tourism Ministry Regulation 6/2025 was medium-low risk. The official regulation and Villa standard refer to a Sertifikat Standar, a readiness self-assessment and a Sertifikat Laik Sehat (SLS). The Ministry of Tourism's SISUPAR portal publishes the standard, readiness assessment and tourism-business certification information. Read the result generated for the operator and location instead of applying a generic checklist from another property.
The code must also match the commercial arrangement. A villa operated by its owner, accommodation managed for a third party, a booking intermediary and a long-term residential lessor do not perform the same activity.
5. National and local tax registrations
First identify the taxpayer and the entity that receives the booking revenue. Then separate three questions:
- national income tax on the operator's taxable result;
- central VAT treatment of the service supplied; and
- the local tax on specified goods and services, known as PBJT, where the local rules apply.
The Directorate General of Taxes explains in PMK 70/PMK.03/2022 which hotel services, including specified villa accommodation, sit outside central VAT and which services remain excluded from that treatment. Law 1/2022 provides the national basis for local taxes, but the relevant regency regulation sets the applicable PBJT rate, registration and filing procedure.
A national taxpayer number (NPWP), a local taxpayer number or a PBJT payment receipt does not prove that the land, building or business licence is compliant. Tax registration and permission to operate answer different questions.
6. Employment records
If the operator employs staff, check employment reporting, written terms and social-security registrations. The relevant systems can include the mandatory company employment report (WLKP), BPJS Kesehatan for health coverage and BPJS Ketenagakerjaan for employment protection. Cash wages and outsourced staffing do not remove the need to identify the legal employer and its obligations.
7. Foreign-guest reporting
Accommodation providers must report foreign guests through the immigration accommodation-reporting system, APOA. The Directorate General of Immigration's official guidance explains the duty to record arrival and departure, and the APOA portal is the reporting channel.
Foreign-guest reporting is an immigration duty that sits alongside tourism licensing. Both remain necessary within their respective files.
8. Groundwater, when the villa uses a well
A functioning well or an old payment receipt is not evidence of current approval. Permen ESDM 4/2026 replaced the 2024 groundwater regulation and distinguishes authorisation routes by use, authority and conservation conditions. The file should record the well, coordinates, intended use, withdrawal volume, metering duties and any earlier approval.
A groundwater specialist must classify the exact use before the required instrument is named. Do not assume that every business well follows one permit package.
Each approval answers a separate question
These records come from different legal systems:
| Question | Main evidence |
|---|---|
| May tourist accommodation operate on this parcel? | RDTR, KKPR and the applicable spatial decision |
| Does the building match its approved design and use? | PBG, approved drawings and SLF |
| May this operator conduct this accommodation activity? | NIB, live OSS result and applicable tourism standard |
| Who declares and pays the relevant taxes? | NPWP, local registration and tax returns |
| Have foreign guests been reported? | APOA arrival and departure records |
Supervision follows the same separation. A business-licensing breach, an unauthorised building change and a spatial-use violation do not automatically carry the same measure. Depending on the legal basis and facts, authorities may require correction, suspend an activity, revoke an approval, close a site or order building measures. Our separate note on non-compliant villas explains why enforcement examples should not be applied to every property as if the underlying breach were identical.
A practical pre-opening file
Before the first paid stay, ask for one indexed folder containing:
- the dated spatial result and parcel plan;
- land certificate, lease and operating-authority documents;
- PBG, approved drawings, SLF and a record of later works;
- corporate documents, NIB, KBLI selection and the complete OSS output;
- the tourism-standard self-assessment, certificates and health document required by the live result;
- national and local tax registrations, with the invoicing and filing flow;
- staff registrations and contracts; and
- APOA access, reporting responsibility and a test procedure.
Add the groundwater file if the property uses a well. The useful test is simple: a reader should be able to follow the same operator, property and activity through every document.
Common questions
My villa is listed on Airbnb. Does that make it legal? No. A platform listing shows that the property can be booked. It does not establish spatial compatibility, building approval, an OSS licence, tax registration or guest reporting.
Is an NIB enough? Not by itself. It identifies the business. Read the full OSS output for the selected activity, operator, scale and location, then collect the standards and approvals named there.
Should a villa charge central VAT on room revenue? Do not answer from the label "villa" alone. PMK 70/2022 places specified hotel and villa accommodation services outside central VAT, but the supplied service must fit the rule. Local PBJT and national income tax are separate. Confirm the treatment and local rate for the operator and regency.
Can I rely on the seller's compliance folder? Use it as a starting point, then verify each document with the issuing system and compare it with the building and operating model you are buying.
Last reviewed: 17 July 2026.
Related: Working legally in Bali · What PP 28/2025 means for villa owners · Bali land zoning explained
For our own mandates, these checks are assigned before opening, with a named person responsible for each file.
Sources reviewed: PP 28/2025; Tourism Ministry Regulation 6/2025 and its official Villa standard; OSS; SISUPAR; PP 21/2021; PP 16/2021; SIMBG; PMK 70/2022; Law 1/2022; Immigration guidance on APOA; and Permen ESDM 4/2026. Checked 17 July 2026. This article gives general information based on our reading of the cited sources. It is not legal, tax or licensing advice. Rules and administrative practice can change. Check the review date and obtain project-specific advice from qualified Indonesian professionals before acting.