balipropertyguidePP 28/2025 in English: business licensing, article by article
The regulation that replaced PP 5/2021 in June 2025. It decides what license a villa business needs, and that the license comes after the land and the building are in order.
PP 28/2025, the articles a property buyer meets, in order
PP 28/2025 replaced PP 5/2021 as Indonesia’s risk-based business licensing regulation. PP 5/2021 is revoked (PP 28/2025 art. 550(b)), and its article numbers — 140(f) for accommodation is the one most often quoted — no longer point at anything. For a property buyer the regulation matters at one moment: when a house becomes a business. These are the articles this site relies on.
| Article | What it decides | Used on |
|---|---|---|
| PP 28/2025 art. 1(3) | A business license (PB) is the legality given to a business actor to start and run a business. | renting it out |
| PP 28/2025 art. 1(12) | The NIB is proof of registration as a business actor. | PT PMA |
| PP 28/2025 art. 4(1)-(2) | To carry on business, a business actor must hold a business license, obtained after meeting the basic requirements first. | — |
| PP 28/2025 art. 5(4) | Codes, scale, risk and license for each activity are in Lampiran I. | accommodation codes |
| PP 28/2025 art. 5(10) | A license is valid for as long as the business actor carries on the business. | — |
| PP 28/2025 art. 12(1) | The basic requirements are spatial-use conformity (KKPR), environmental approval (PL), and the building approval and fitness certificate (PBG and SLF). | KKPR / RDTR |
| PP 28/2025 art. 128 | Risk levels: low, medium-low, medium-high and high. | — |
| PP 28/2025 art. 130 | Low risk needs an NIB, which is both the business identity and the legality to operate. | — |
| PP 28/2025 art. 131(1)-(2) | Medium-low risk needs an NIB plus a standard certificate in the form of the business actor's own statement that it meets the business standard. | villa 55193 |
| PP 28/2025 art. 132(2)-(6) | Medium-high risk needs an NIB plus a standard certificate issued after verification; the unverified certificate covers preparation only. | apartment hotel 55194 |
| PP 28/2025 art. 133(1) | High risk needs an NIB plus a permit (izin). | — |
| PP 28/2025 art. 170 | The tourism sector covers thirteen activities. | — |
| PP 28/2025 art. 170(f) | Providing accommodation is a licensed tourism business activity. | renting it out |
| PP 28/2025 art. 550(b) | PP 5/2021 is revoked. | regulations index |
| PP 28/2025 art. 552 | In force from 5 June 2025. | — |
A license comes after the land is in order
Article 4 puts the order in the regulation itself: a business actor must hold a business license, obtained after meeting the basic requirements first (PP 28/2025 art. 4(1)-(2)). The basic requirements are spatial-use conformity (KKPR), environmental approval (PL), and the building approval and fitness certificate (PBG and SLF) (PP 28/2025 art. 12(1)). Each of those is a property question before it is a business one: KKPR is whether the zone allows the use, and PBG and SLF are the building’s own papers.
So the common sequence — buy, build, then “sort out the license” — runs the regulation backwards. A villa with no SLF does not meet the basic requirements for the license it is being bought to earn. The zoning answer, parcel by parcel. The building papers.
The risk ladder, and where accommodation sits on it
Every activity is graded low, medium-low, medium-high and high (PP 28/2025 art. 128). The grade decides the license:
- Low risk: an NIB, which is both the business identity and the legality to operate (PP 28/2025 art. 130).
- Medium-low: 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)).
- Medium-high: an NIB plus a standard certificate issued after verification; the unverified certificate covers preparation only (PP 28/2025 art. 132(2)-(6)).
- High: an NIB plus a permit (izin) (PP 28/2025 art. 133(1)).
No accommodation code is low risk. A villa is medium-low; a large hotel or an apartment hotel is medium-high. The full table, with the business-scale column that decides whether a foreign-owned company can use a code, is on the accommodation codes page.
Two more articles round it out. A license is valid for as long as the business actor carries on the business (PP 28/2025 art. 5(10)) — there is no renewal date to diarise for an ordinary villa license. And under article 132(7), an unverified medium-high certificate can be revoked if the standard is not met in time and no preparation has happened within a year of the NIB.
Old numbers, new numbers
Because so much English-language material still cites PP 5/2021, here is where the provisions this site uses now sit.
| Provision | PP 5/2021 (revoked) | PP 28/2025 |
|---|---|---|
| Accommodation as a licensed tourism activity | art. 140(f) | art. 170(f) |
| Number of tourism activities | art. 140 | art. 170 |
| Codes, risk and license in Lampiran I | art. 141(1) | art. 5(4) |
| Definition of a business license | art. 1 | art. 1(3) |
| Definition of the NIB | art. 1 | art. 1(12) |
The left column is the numbering this site itself used until 1 October 2026; the substance of these five provisions carried over. The investment rules that sit beside this regulation were replaced too — Permen Investasi/BKPM 5/2025.
One list, and no one may add to it
Article 6(1) is short and does a lot of work: ministries, regional governments, special economic zone administrators and free-zone authorities are prohibited from issuing basic requirements, business licenses or supporting licenses outside those set in the regulation (PP 28/2025 art. 6(1)). Article 6(2) leaves them supervision of what the regulation does set. For a Bali villa owner, that is the test to apply to any “local permit” an agent says is needed on top of the NIB: is it one of the basic requirements, the license for the code, or a supporting license in Lampiran II? If it is none of them, ask which instrument creates it.
The regulation is also built in layers you can follow. Article 5(3) lists what each sector’s licensing covers — the code and scale table, the supporting licenses, the risk-analysis method and the business standards — and article 5(4) to 5(7) sends each to its own place: Lampiran I for the codes, Lampiran II for supporting licenses, Lampiran III for the method, and ministerial regulations for the standards.
What we have not read
PP 28/2025 is long, and this site reads what it uses. Not read: Lampiran II (supporting licenses), Lampiran III (the risk-analysis method), and the ministerial regulations on business standards that article 5(7) delegates to — including the villa standard the self-assessment refers to. The transitional articles for licenses issued under PP 5/2021 are also not read, so this page does not say what happens to an existing villa NIB.
This is commentary, not a translation, and not legal advice. The official Indonesian text on JDIH BPK is the authority.
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Questions on this page
Is PP 5/2021 still in force?
No. PP 28/2025 article 550(b) revoked it. PP 28/2025 was set and promulgated on 5 June 2025 and took effect on promulgation (article 552). Guides that cite PP 5/2021 article 140(f) for accommodation are citing the old number; the same position is now PP 28/2025 article 170(f).
What does PP 28/2025 regulate?
Risk-based business licensing (Penyelenggaraan Perizinan Berusaha Berbasis Risiko): which license each business activity needs, by risk level, issued through OSS. Article 4 requires a business license after the basic requirements are met; article 12(1) lists those as KKPR, environmental approval, and PBG and SLF; Lampiran I sets the KBLI code, scale, risk and license for each activity.
What license does a medium-low risk business need?
Under PP 28/2025 article 131, an NIB plus a standard certificate, which is the business actor's own statement that it meets the business standard. The standard is checked during supervision. Medium-high risk (article 132) needs the certificate verified before operating; high risk (article 133) needs an NIB plus a permit.
How long is an OSS business license valid?
PP 28/2025 article 5(10): for as long as the business actor carries on the business, except licenses issued for international agreements, natural resources, hazardous materials or restricted goods, whose term is set elsewhere (article 5(11)).
Sources cited on this page
Every rule above was read in the Indonesian original on 20 September 2026, not from an English summary. How we check this.