Accommodation KBLI codes in Indonesia: villa, homestay, hotel

Eleven rows of the licensing lampiran decide how a villa, homestay or hotel is registered. One column — business scale — decides whether a foreign-owned company can use them at all.

Every accommodation code in PP 28/2025, on one table

The codes, risk levels and licenses for each business activity are in Lampiran I of the licensing regulation (PP 28/2025 art. 5(4)). The tourism section is Lampiran I.L, and the accommodation rows run from page I.L.19 to I.L.27. This is every one of them, with the column a foreign owner tends to skip — business scale — and the Bali position for a new PMA in the last column.

Lampiran page numbers are the official PDF’s own (I.L.19 etc.). The last column combines two sources: the scale column, against Permen Investasi/BKPM 5/2025 art. 26(1), which classes every PMA as classed as a large business; and the Bali list of 18 codes reported by ANTARA (ANTARA (state news agency), 23 July 2026). “Not on the list” means only that: the code is not among the 18.

The villa row, read column by column

The villa entry is KBLI 55193 Villa: micro, small and medium businesses only; medium-low risk; NIB plus a standard certificate, issued automatically; regent or mayor (PP 28/2025 Lampiran I.L, KBLI 55193). Each part of that line decides something different.

Scale: who may hold the code

The scale column names micro, small and medium businesses. It does not name large ones. The same is true of homestay (55130), youth hostel (55191), camping (55192), villa (55193) and other short-term accommodation (55199): micro, small and medium only (PP 28/2025 Lampiran I.L, KBLI 55130-55199). For a domestic business the scale is set by capital or sales; a medium business has business capital above IDR 5 billion up to IDR 10 billion, excluding land and buildings, or annual sales up to IDR 50 billion (Permen Investasi/BKPM 5/2025 art. 25(4)(c)). For accommodation, the land and buildings do not exclude land and buildings (Permen Investasi/BKPM 5/2025 art. 25(6)) — so a villa company that owns the land it trades from can outgrow the medium band faster than the capital figure alone suggests. That last step is our reading of article 25(4) and 25(6) together.

Risk and license: what OSS issues

Medium-low risk means an NIB plus a standard certificate in the form of the business actor's own statement that it meets the business standard (PP 28/2025 art. 131(1)-(2)). “Automatic” in the timing column is that: no verification visit before the certificate issues. The standard is checked afterwards, during supervision.

Obligations: the two documents

The villa obligations are a health-worthiness certificate (sertifikat laik sehat) and a self-assessment document of readiness to apply the villa business standard, covering facilities, organization and staff, service, product and management system. The authority is the regent or mayor — in Bali, the regency where the villa stands.

Why a foreign-owned company does not fit the villa code

Put the scale column next to the investment regulation. A PMA is classed as a large business (Permen Investasi/BKPM 5/2025 art. 26(1)). The villa code is open to micro, small and medium businesses. Read literally, a PT PMA cannot register under 55193 at all — not because villas are closed to foreigners, but because the code is closed to the size of company a foreigner must use.

The codes that do run to large businesses are star hotels (55110) and non-star hotels (55120), small to large; apartment hotels (55194), all four scales; and 55900, whose scope is hotel management services (PP 28/2025 Lampiran I.L, KBLI 55110, 55120, 55194, 55900). Hotels are open to small, medium and large businesses, not micro (PP 28/2025 Lampiran I.L, KBLI 55110 and 55120). Above 6,000 m² of building, a hotel is medium-high risk, a 14-day issuing period, the governor as the authority, and a tourism business standard certificate from a certification body (LSPr) (PP 28/2025 Lampiran I.L, KBLI 55110 and 55120 above 6,000 m2). This is why foreign-owned villa operations are so often registered as something other than a villa; the code on the NIB is the first thing to ask a seller or an operator for. What the company has to be before any of this.

Bali since May 2026: three of the large-business codes closed to new PMAs

The provincial government announced that OSS in Bali has been closed to new PMA applications in 18 low and lower-medium risk KBLI, across Bali, since the third week of May 2026 (Bali Provincial Government release, 22 July 2026). ANTARA’s list of the 18 codes includes star hotels (55110) and non-star hotels (55120) under 6,000 m2, other accommodation (55900), and real estate owned or leased (68111) (ANTARA (state news agency), 23 July 2026). The closure runs until there is a further policy, while existing companies keep filing investment reports until the code is deactivated or removed from the licensing system (same source).

Not on the list: apartment hotels (55194), villas (55193) and hotels of 6,000 m2 and more. For a new foreign-owned accommodation business in Bali, that leaves the large hotel rows and the apartment-hotel row — both medium-high risk, both with the governor as the authority and a 14-day issuing period rather than an automatic one. Whether that is a sensible route for one villa is a business question this table cannot answer; what it shows is that “set up a PT PMA and rent the villa out” skips two filters.

The release does not publish the governor’s letter that requested the closure, and we have not read it. The 18 codes are as reported, not as read in an instrument.

What the table does not tell you

The lampiran sets the license; it does not set the standard. The villa business standard that the self-assessment refers to is issued by ministerial regulation under PP 28/2025 article 5(7), and we have not read it. The table also says nothing about the land: a villa business still needs a land right that allows it and a zone that permits it, and those are the basic requirements of spatial-use conformity (KKPR), environmental approval (PL), and the building approval and fitness certificate (PBG and SLF) (PP 28/2025 art. 12(1)). The zoning check. Renting a villa out, structure by structure.

We do not register businesses or recommend anyone who does. The lampiran is the authority; this table is our transcription of it, page numbers included so you can check every row.

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