balipropertyguidePP 48/2025 in English: when an unused land right can be taken back
An idle plot can cost more than an opportunity. Since November 2025, HGB or hak pakai left deliberately unused can be ended in a procedure measured in weeks, not years.
PP 48/2025, the articles a land-right holder meets, in order
An unused plot in Bali is not only a missed investment. Under Indonesian law a land right carries a duty to use it, and a right left deliberately idle can be ended. The regulation that does it changed in November 2025: PP 48/2025 revoked PP 20/2021 (PP 48/2025 art. 49(b)) and has been in force since 6 November 2025 (PP 48/2025 art. 50).
| Article | What it decides | Used on |
|---|---|---|
| PP 48/2025 art. 1(2) | Abandoned land (tanah telantar) is land under a land right, HPL land, or land held on a basis of control, that is deliberately not worked, used, exploited and/or maintained. | — |
| PP 48/2025 art. 3 | Every holder must work, use, exploit and/or maintain the land, in keeping with its social function, and report on it periodically. | — |
| PP 48/2025 art. 6(1) | The procedure can reach hak milik, HGB, HGU, hak pakai, HPL and land held on a basis of control. | — |
| PP 48/2025 art. 6(2) | Hak milik is reached only if, through deliberate neglect, it has become a settlement, been held by others for 20 years without a legal relationship with the holder, or its social function is unmet. | — |
| PP 48/2025 art. 6(3) | HGB, hak pakai and HPL land are reached from two years after the right is issued, at the earliest. | HGB |
| PP 48/2025 art. 7 | Exempt HPL: customary-community HPL, Land Bank HPL, Batam Authority HPL and Nusantara capital authority HPL. | hak pengelolaan |
| PP 48/2025 art. 4(2) | Abandoned areas under a license include tourism areas, large-scale or integrated housing areas, industrial estates, plantations and mining areas. | — |
| PP 48/2025 art. 10(2)-(3) | The land is inventoried at the earliest two years after the right is issued, on reports from the holder, the land offices' monitoring, ministries, regional government or the public. | — |
| PP 48/2025 art. 23(4) | The evaluation takes 12 calendar days. | — |
| PP 48/2025 art. 23(5)(a) | The holder then has 30 calendar days from receiving the evaluation result. | — |
| PP 48/2025 art. 25(1)-(4) | Then three written warnings, each giving 14 calendar days. | — |
| PP 48/2025 art. 27 | The designation is proposed within 6 calendar days after the third warning is ignored. | — |
| PP 48/2025 art. 28 | Once proposed, no legal act may be done on the plot until the Minister decides. | — |
| PP 48/2025 art. 30(1) | On designation the right ends, the legal relationship is cut, and the land becomes State land directly controlled by the State. | — |
| PP 48/2025 art. 32 | The former holder must vacate within 30 calendar days. | — |
| PP 48/2025 art. 33 | The holder may file an objection under the applicable law. | — |
| PP 48/2025 art. 34(1) | A listed right whose term has ended falls to the State for re-allocation. | — |
| PP 48/2025 art. 35 | Designated land may become a Land Bank asset and/or general State reserve land (TCUN). | — |
| PP 48/2025 art. 37(1) | Land leaves the database on no deliberate neglect, the land is now used, the term has ended, the land has been released, or a final court judgment. | — |
| PP 48/2025 art. 49(b) | Revoked: PP 20/2021. | — |
| PP 48/2025 art. 50 | In force 6 November 2025. | — |
Which rights it reaches, and from when
Abandoned land is land under a land right, HPL land, or land held on a basis of control, that is deliberately not worked, used, exploited and/or maintained (PP 48/2025 art. 1(2)). Every holder must work, use, exploit and/or maintain the land, in keeping with its social function, and report on it periodically (PP 48/2025 art. 3). The procedure can reach hak milik, HGB, HGU, hak pakai, HPL and land held on a basis of control (PP 48/2025 art. 6(1)), but not equally.
Hak milik is reached only if, through deliberate neglect, it has become a settlement, been held by others for 20 years without a legal relationship with the holder, or its social function is unmet (PP 48/2025 art. 6(2)). HGB, hak pakai and HPL land are reached on a much shorter fuse: from two years after the right is issued, at the earliest (PP 48/2025 art. 6(3)). Those are the rights a foreigner or a foreign-owned company holds. A hak pakai bought as a holiday home and left unbuilt, or a PT PMA’s HGB plot waiting for a better market, sits in the category the regulation reaches first. Hak pakai explained.
Licensed areas are covered separately, as abandoned areas: tourism areas, large-scale or integrated housing areas, industrial estates, plantations and mining areas (PP 48/2025 art. 4(2)). Some HPL is exempt: customary-community HPL, Land Bank HPL, Batam Authority HPL and Nusantara capital authority HPL (PP 48/2025 art. 7).
The procedure, then and now
| Step | PP 20/2021 (revoked) | PP 48/2025 |
|---|---|---|
| Evaluation | 180 days | 12 calendar days (PP 48/2025 art. 23(4)) |
| Time given to start using the land | 180 days | 30 calendar days from receiving the evaluation result (PP 48/2025 art. 23(5)(a)) |
| Written warnings | 90, 45 and 30 days | three written warnings, each giving 14 calendar days (PP 48/2025 art. 25(1)-(4)) |
| Proposal to the Minister | — | within 6 calendar days after the third warning is ignored (PP 48/2025 art. 27) |
Old column: a 180-day evaluation, a 180-day notice to use the land, then warnings of 90, 45 and 30 days (PP 20/2021 arts. 23-25 (revoked)). Both read off the official texts on JDIH BPK.
The arithmetic is the point. Adding the periods, the old procedure ran for well over a year from the start of evaluation to the last warning; the new one runs in about three months. A holder who used to have time to react after the first letter now has weeks. Once the designation is proposed, no legal act may be done on the plot until the Minister decides (PP 48/2025 art. 28) — the plot cannot be sold to escape it.
What designation does
On designation the right ends, the legal relationship is cut, and the land becomes State land directly controlled by the State (PP 48/2025 art. 30(1)). The former holder must vacate within 30 calendar days (PP 48/2025 art. 32); what is left standing becomes an abandoned asset. The holder may file an objection under the applicable law (PP 48/2025 art. 33). The land may become a Land Bank asset and/or general State reserve land (TCUN) (PP 48/2025 art. 35).
Two exits exist before that point. Land leaves the indicated-abandoned database on no deliberate neglect, the land is now used, the term has ended, the land has been released, or a final court judgment (PP 48/2025 art. 37(1)). And a listed right whose term ends before a designation is proposed falls to the State for re-allocation (PP 48/2025 art. 34(1)) — it is not designated, but it is not extended either. For a buyer, that last rule is a reason to ask whether a plot is on the database at all: a right in that position may not reach its renewal. What the land office can tell you.
What we have not read
The procedure’s detail — how the database is kept, how a holder is told — is delegated to ministerial regulations (arts. 13, 21, 36) we have not read, and we do not know of a public search for the indicated-abandoned database.
This is commentary, not legal advice. The official Indonesian text on JDIH BPK is the authority.
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Questions on this page
Is PP 20/2021 on abandoned land still in force?
No. PP 48/2025 article 49(b) revoked it; PP 48/2025 was set and promulgated on 6 November 2025 and took effect on promulgation (art. 50). Implementing rules made under PP 20/2021 remain in force so far as they do not conflict (art. 49(a)).
Can HGB or hak pakai land be declared abandoned?
Yes, if deliberately not worked, used, exploited and/or maintained, counting from two years after the right is issued at the earliest (PP 48/2025 art. 6(3)). On designation the right ends and the land becomes State land (art. 30(1)).
How long does the abandoned-land procedure take now?
Under PP 48/2025: a 12-day evaluation (art. 23(4)), 30 days for the holder to start using the land (23(5)(a)), three written warnings of 14 days each (art. 25), and a proposal to the Minister within 6 days of the third (art. 27). Under the revoked PP 20/2021 the evaluation and notice periods were 180 days each, followed by warnings of 90, 45 and 30 days.
Can hak milik be declared abandoned?
Only in narrower cases: where, through deliberate neglect, it has become a settlement, has been held by others for 20 years with no legal relationship to the holder, or its social function is not met (PP 48/2025 art. 6(2)).
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.