Sources

Which Bali Property Regulation Is Current: 9 Instruments, 2 Repealed

There is a specific sentence at the end of PP 18/2021 that a great deal of English-language writing about Bali property has not caught up with.

Article 103 lists what the regulation revokes. Sub-paragraph (b) is Peraturan Pemerintah Nomor 103 Tahun 2015, on the ownership of residential houses or dwellings by foreigners resident in Indonesia. Not amended. Revoked, with effect from the day PP 18/2021 was promulgated: 2 February 2021.

PP 103/2015 is still, by a comfortable margin, the regulation most often cited in English-language guides to buying property in Bali.

Why this happens

Not dishonesty. Compounding.

Someone writes a good article in 2018, from the regulation in force. Other sites summarize that article. Later writers summarize the summaries. By 2026 the chain is four or five links long and nobody in it has opened the Indonesian text — because at each step the previous link looked authoritative, and because opening the Indonesian text is a genuine amount of work in a language most of the writers do not read.

Then the regulation is replaced, and nothing in the chain notices. There is no mechanism by which it would.

What actually changed

The framework for foreign ownership is now PP 18/2021, with Permen ATR/BPN 18/2021 as the implementing regulation. The current position, with the article attached:

What a foreigner may hold. Article 71(1) of PP 18/2021: a landed house on hak pakai — over state land, over hak milik by a PPAT deed, or over hak pengelolaan — or a strata unit in a building on hak pakai or HGB land. Article 185 of the ministerial regulation repeats it.

The term. Article 52(1): hak pakai runs 30 years, extendable by up to 20, renewable by up to 30. Article 37(1) gives HGB the same ladder.

The limits. Article 186(1)(a) of the ministerial regulation: luxury category, one parcel per person or family, and no more than 2,000 square meters.

Conversion. Article 187(3): where a foreigner acquires a landed house held under hak milik or HGB, the right is converted into hak pakai. Article 158 confirms that a foreigner may only apply to convert those rights, not hold them.

The immigration condition. Article 69(1): a foreigner may own a home while holding a valid immigration document — and the implementing regulation asks for it again at extension and at renewal.

Some of that is similar to what came before. The point is not that everything is different. The point is that a page citing PP 103/2015 has no way of telling you which parts are which, because its author has not looked.

Which instrument governs which question, as of 2026

The reason a repealed regulation survives in circulation is that nobody publishes the map. Here is ours. Nine instruments, one question each, and every one of them was read in the Indonesian original for this site.

The one almost everybody gets backwards in the other direction

PP 24/1997 on land registration was not repealed, and writers who have absorbed “2021 changed everything” now get this wrong in the opposite direction.

Article 103 of PP 18/2021 repealed PP 40/1996 and PP 103/2015 outright. It did not repeal PP 24/1997. What it took from PP 24/1997 was two provisions about announcement periods — articles 26(1) and 45(1)(e) — and nothing else. Article 102 then keeps the implementing regulations of all three alive so far as they do not conflict with PP 18/2021.

So the articles this site relies on from PP 24/1997 — article 32(1) on what a certificate proves, article 37(1) on the PPAT deed, article 4(3) on mandatory registration — are current law. What a certificate does and does not prove rests on that, and who may make the deed on the other.

Partial repeal is the normal case, not the exception

The lesson generalises past this one instrument. Indonesian regulations are routinely amended in fragments: two sub-articles removed here, one paragraph replaced there, the rest untouched. “Is PP X still valid?” usually has no yes-or-no answer, and a summary that gives one is a summary that did not open the closing provisions.

That is why every citation on this site carries an article number rather than only an instrument. An article number is checkable. A regulation name is not.

The ten-second test

Open any page about foreign property ownership in Bali and look for article numbers.

Pages written from the primary text cite them, because that is how you find anything in an Indonesian regulation and because the author had the text open. Pages written from other pages describe rules in prose — “foreigners can own property on a 30-year leasehold which can be extended” — with nothing to check.

Then look for which instruments are named. PP 103/2015 as a live regulation is conclusive: whatever else is on the page, its sources are at least five years stale.

Three more tells, in descending order of reliability

“IMB” described as the current building permit. PP 16/2021 replaced it with the PBG, and an IMB issued before that regulation stays valid only until it expires, under article 346(2). A page calling the IMB the thing you apply for today is working from pre-2021 material.

A single national figure for acquisition duty. Law 1/2022 caps the rate and hands the operative number to regional by-law. Bali has nine regional governments, so a page that prints one “Bali rate” has not read the delegation — which is a different question with a different answer in each regency.

A minimum purchase price for foreigners, stated as settled fact. Article 187(2) of Permen ATR/BPN 18/2021 delegates it to a Ministerial Decision. That decision is not in the national legal database the rest of these instruments come from. A figure may well be correct; a page that prints it without saying where it read the instrument has not read one.

What we do about it here

Every regulation cited on this site was downloaded as the official PDF from the Indonesian national legal database, converted to text, and read in Indonesian. Article numbers appear next to rules so you can check the same source we did. Where we quote, we print the Indonesian alongside the English so you can see what has been translated and what has been interpreted.

And where we could not read the instrument, we say so instead of filling the gap. The clearest case is the minimum purchase price for a foreign buyer: article 187(2) of Permen ATR/BPN 18/2021 delegates it to a Ministerial Decision, that decision is not in the database the rest of these rules came from, so we print no figure for it. Other sites do. They may well be right. We cannot show you the instrument, so we will not state it as fact.

How we check everything on this site, including what we refuse to publish and why.

All posts · Lease ROI calculator · Ownership structures