Condotels in Bali: the apartment-hotel standard and the strata unit

The buyer owns a unit; the operator runs a hotel. The two instruments behind each half, and where they meet.

The apartment-hotel standard, and what a condotel buyer owns

A condotel sells a hotel room as property: the buyer owns a unit, an operator runs the hotel, and the income is shared. Two different instruments govern the two halves — the strata law for what the buyer owns, and the apartment-hotel standard for what the operator must be licensed to do.

The operator: KBLI 55194

The standard covers managing and operating apartments as a hotel for temporary stay, for example apartment hotels and condominium hotels (condotels) (Permenpar 6/2025 Lampiran I, KBLI 55194, item 1). An apartment-hotel business is daily accommodation in residential units in one or more buildings, managed by the apartment-hotel business (Permenpar 6/2025 Lampiran I, KBLI 55194, item 2(b)), rated medium-high risk (Permenpar 6/2025 Lampiran I, KBLI 55194, heading). Under the licensing regulation the code is open to all four business scales, unlike the villa code (PP 28/2025 Lampiran I.L, KBLI 55110, 55120, 55194, 55900). The accommodation codes.

The certificate

The operator must create an OSS account, apply for the standard certificate, enter KBLI 55194, complete and upload the self-assessment (Permenpar 6/2025 Lampiran I, KBLI 55194, item 5(c)(1)-(6)); verification is by a verification team from the provincial tourism office (Permenpar 6/2025 Lampiran I, KBLI 55194, item 5(a)), within 14 working days after complete documents are filed in OSS (Permenpar 6/2025 Lampiran I, KBLI 55194, item 5(b)). The outcome is approved, incomplete, or refused (Permenpar 6/2025 Lampiran I, KBLI 55194, item 5(c)(12)), and the certificate is issued automatically by OSS if verification takes longer than 14 working days (Permenpar 6/2025 Lampiran I, KBLI 55194, item 5(c)(9)). An approval is issued by the provincial tourism office, through OSS (Permenpar 6/2025 Lampiran I, KBLI 55194, item 5(c)(12)(a)) — the province, not the regency, for this code.

The obligations are heavier than a villa’s: a health-worthiness certificate (SLS), and a tourism business standard certificate issued by a certification body (LSPr) (Permenpar 6/2025 Lampiran I, KBLI 55194, item 6(a)-(b)). For a villa or a homestay the certification criteria apply only if the owner chooses certification (Permenpar 6/2025 Lampiran I, KBLI 55193, items 6(c), 6.1-6.3); for an apartment hotel the certificate itself is required.

The buyer: a strata unit

A strata unit is a unit used separately, mainly as a dwelling, with access to a public road (PP 18/2021 art. 1(10)). The owner holds an individual right to the unit, separate from the shared right in the common parts, common fixtures and common land (Law 20/2011 art. 46(1)). Foreigners may own one: yes (PP 18/2021 art. 67(1)(c); Permen ATR/BPN 18/2021 art. 188(1)); the categories who may are Indonesian citizens and legal entities, foreign citizens holding the required permit, foreign legal entities with a representative office, and foreign-state and international representations (Law 6/2023 (Perppu 2/2022) art. 144(1)). Owners must form an association: must form an owners' and occupiers' association (PPPSRS), which is a legal entity (Law 20/2011 art. 74(1), (3)).

Two rules of the strata law bear directly on the hotel arrangement. A lease of a unit must be a written agreement before the authorized official, registered with the PPPSRS (Law 20/2011 art. 45(5)-(6)) — the leaseback or management agreement under which the operator lets the unit is worth reading against that. And no one may change the function and use of a unit (Law 20/2011 art. 99(c)): the unit’s function on the strata deed and the hotel use should match from the start. Our reading of how the two laws meet.

Before buying a condotel unit

Ask for the unit’s own strata certificate (or, if it is off-plan, a PPJB that meets the law: developers are barred from a PPJB that does not match what was marketed, or a PPJB before the art. 43(2) conditions are met (Law 20/2011 art. 98)); the operator’s NIB under KBLI 55194 and its standard certificate; and the management agreement. In Bali the 15-meter height limit (Bali Perda 2/2023 art. 100(2)) caps how tall the building can be. Supervision and sanctions.

This is commentary on the official texts, not legal or investment advice. Returns quoted by condotel developers are contract terms, not regulated figures.

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