PP 21/2021 in English: spatial planning procedure and KKPR

Where Indonesia's spatial planning law becomes procedure: the KKPR a villa needs, how it is issued, and the three-year clock most sellers do not mention.

PP 21/2021, the articles a buyer or builder meets, in order

PP 21/2021 is where the spatial planning law becomes procedure. It replaced PP 15/2010 on spatial planning and PP 8/2013 on spatial-plan map accuracy (PP 21/2021 (JDIH BPK status: Mencabut)) and was set and promulgated on 2 February 2021 (PP 21/2021, signature and promulgation block). For anyone buying land to build on in Bali, the part that matters is the KKPR: what it is, how it is obtained, and how long it lasts.

Three kinds of KKPR, and which one a villa needs

KKPR is issued for business activities, non-business activities, and activities of national strategic character (PP 21/2021 art. 98(1)). The distinction is not academic. A villa that will be let is a business activity: its KKPR comes through OSS, and the business license is applied for only after the KKPR is obtained (PP 21/2021 art. 100(2)). A house built to live in is not, and its KKPR is obtained through the minister's electronic system, as a confirmation (against an RDTR) or an approval (PP 21/2021 arts. 116(1), 117(1)).

Micro and small businesses take a third path: a self-declaration that the activity conforms to the spatial plan, without a KKPR being issued (PP 21/2021 art. 115(1)-(2)). That is a lighter route, but the declaration is the owner’s, and a false one does not make the use lawful. A foreign-owned company is never micro or small, so this path is not open to it. Why a PMA is always large.

Confirmation or approval, and the three-year clock

Where the location has a detailed plan, the KKPR is a confirmation: a document confirming conformity with the detailed spatial plan (RDTR) (PP 21/2021 art. 1(18)), issued in at most 1 day from registration or payment of the fee (PP 21/2021 art. 105). It states the location, the type of use, the KDB, the KLB, the building rules and the conditions (PP 21/2021 art. 104(2)) — which is why a confirmation is the most useful document in a Bali land file: it puts the building coefficients on paper for that parcel.

Where there is no detailed plan, the KKPR is an approval, used where no RDTR yet exists at the location (PP 21/2021 art. 106(1)) and resting on a tiered study of the regency plan, the provincial plan and the national plans, with a land technical consideration (PP 21/2021 art. 108(2)). The decision is approved, or refused with reasons (PP 21/2021 art. 98(7)).

Either way, on land the KKPR is valid for three years from issue (PP 21/2021 art. 98(4)). A KKPR shown by a seller is a dated document: one issued more than three years ago is, on the face of the regulation, no longer current. Check the date before relying on it. Reading a KKPR.

When the use does not match the KKPR

The regulation’s sanctions chapter is the part sellers least often mention. A KKPR is revoked when the use carried out does not match the KKPR (PP 21/2021 art. 200) — so a KKPR for a house does not protect a building run as a hotel. The sanctions available are a written warning, an administrative fine, suspension of the activity or of public services, closure, revocation or annulment of the KKPR, demolition of the building, and restoration of the space's function (PP 21/2021 art. 195(1)). Written warnings come at most three times (PP 21/2021 art. 198(3)) before the heavier measures.

The fine is calculated from the NJOP, the land and building area, an area index and the size of the impact, and may be progressive (PP 21/2021 art. 199(2)-(3)), so it grows with the value and size of the property; the formula itself is left to each regent or mayor, and we have not read Bali’s. If a regency does not act, the governor, and then the Minister, take over sanctions a regency does not impose (PP 21/2021 art. 194(2)-(3)). For a buyer the practical point is that a non-conforming building is not a past problem the seller takes away with them: demolition and restoration are measures against the building, and after completion the building is yours — our reading of how the sanctions land on a buyer, not a rule the regulation states.

Above it, and around it

The statute this regulation implements decides what happens when a KKPR is wrong — Law 26/2007. The license that follows the KKPR is in PP 28/2025. The detailed plans themselves are regency regulations; Badung’s is one we have not been able to read.

This is commentary, not legal advice. The official Indonesian text on JDIH BPK is the authority.

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