Real estate KBLI codes: 68111, 68200, and the KBLI 2025 split
Developing, letting and brokering property are licensed business lines with their own codes. The brokerage row has a rule most foreign-run agencies would rather you did not read.
The two real estate codes in the licensing lampiran
Property itself is a business line. Developing, selling or letting it is one code; brokering it is another. The licensing regulation’s lampiran prints both, in KBLI 2020 numbering, in two different sectors: development under public works and housing (Lampiran I.H), brokerage under trade (Lampiran I.G).
| Code | Title | Scale | Risk | License | Lampiran |
|---|---|---|---|---|---|
| 68111 (KBLI 2020) | Real estate owned or leased: housing, shopping centers, other and mixed development | Micro to large | Medium-low | NIB + standard certificate, automatic | PP 28/2025 I.H.399–409 |
| 68200 (KBLI 2020) | Real estate on a fee or contract basis — brokers | Micro to large | Medium-high | NIB + standard certificate, 3 days | PP 28/2025 I.G.1–5 |
68111: micro to large businesses; medium-low risk; NIB plus a standard certificate, issued automatically; the regent or mayor, the governor across regencies, the minister across provinces (PP 28/2025 Lampiran I.H no. 66, KBLI 68111). 68200: micro to large businesses; medium-high risk; NIB plus a standard certificate within 3 days; the minister or head of agency (PP 28/2025 Lampiran I.G no. 1, KBLI 68200).
68111: building, selling and letting
The 68111 row runs to eleven pages because it carries four scopes — housing and mixed housing, shopping centers, other development, and mixed development — each with the same scale, risk and license. What differs is the obligations. A housing developer must obtain spatial-use conformity (KKPR) for the housing development, local-government approval of the site plan, the split of the parent HGB certificate per plot, and audited financial reports (PP 28/2025 Lampiran I.H no. 66, KBLI 68111, obligations A-B). That is the list to hold an off-plan developer to: a buyer of a unit in a project should be able to see the KKPR, the approved site plan and the plan for splitting the parent HGB certificate into the individual plots. What KKPR shows. Buying off-plan on a PPJB.
Open to a PMA nationally — and the land counts
Unlike the villa code, 68111 runs from micro to large, so a PMA’s large-business status is not a bar. For property businesses the investment value is counted including land and buildings (Permen Investasi/BKPM 5/2025 art. 26(5)), and for units not in one whole building or complex it is counted excluding land and buildings (Permen Investasi/BKPM 5/2025 art. 26(6)(b)). We found no real estate line in the Perpres 10/2021 lists of allocated or conditional lines. In Bali, however, the province closed OSS to new PMA applications in 68111 from May 2026: the closed lines include 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).
68200: brokers must be Indonesian
The brokerage row sets requirements, not just a license. The business must be a legal entity founded and domiciled in Indonesia (PP 28/2025 Lampiran I.G no. 1, KBLI 68200, requirement 1). Its expert list must show that every property broker is one of the Indonesian citizens (PP 28/2025 Lampiran I.G no. 1, KBLI 68200, requirement 2(a)), with at least one expert in brokerage management, each holding a work-competence certificate. A firm that also manages property or advises on property investment needs an expert in that area too.
The obligations are as specific: a written agreement with the client, the national payment system in every transaction, the license number on the premises and in every advertisement, a commission set under the regulations, and reports to the Minister of Trade (PP 28/2025 Lampiran I.G no. 1, KBLI 68200, obligations 1-8). Two of them are things a buyer can check in a minute. The license number has to appear on every advertisement, so a listing without one is from someone not showing it. And the payment system has to be the national one, which connects to the rule that payment in Indonesia is in rupiah. The rupiah rule.
What the row does not settle is the commission: it says the commission is set under the regulations, and the trade-ministry regulation on property brokers is one we have not read. We print no commission rate.
KBLI 2025: the real estate codes were split
The codes above are KBLI 2020, which Peraturan BPS 7/2025 revoked KBLI 2020 (Peraturan BPS 2/2020); set 17 December 2025, in force on promulgation (Peraturan BPS 7/2025 arts. 6-7). The new classification divides real estate more finely:
| KBLI 2025 | What it covers (Peraturan BPS 7/2025) | Nearest KBLI 2020 code (our reading) |
|---|---|---|
| 68111 | buying, selling and developing homes and flats for more permanent, yearly usePeraturan BPS 7/2025 Lampiran, KBLI 68111 | 68111 (development part) |
| 68112 | renting out and operating residential real estate that is owned or leasedPeraturan BPS 7/2025 Lampiran, KBLI 68112 | 68111 (rental part) |
| 68121–68129 | Non-residential: tourism areas, industrial estates, malls, offices, warehouses, other | 68111 / others |
| 68210 | real estate intermediation in buying, selling and renting, for a fee or commission, online or offlinePeraturan BPS 7/2025 Lampiran, KBLI 68210 | 68200 |
| 68292 | managing residential real estate for a fee or under contract — operations, maintenance, repairs, service chargesPeraturan BPS 7/2025 Lampiran, KBLI 68292 | 68200 (management part) |
The right-hand column is our reading of the titles, not the official conversion table, which we have not read. The licensing lampiran still prints the KBLI 2020 rows; how OSS carries their scale and risk onto the new codes is not something we have seen in an instrument.
Where a long let belongs
One line in KBLI 2025 matters to anyone renting a villa out for a year: accommodation provided for one year or more is real estate (subclass 6811), not accommodation (Peraturan BPS 7/2025 Lampiran, subclass 5590 exclusions and 6811). A nightly or weekly villa is accommodation, division 55; a yearly let is residential rental, now 68112: renting out and operating residential real estate that is owned or leased. The two sit in different sectors with different licensing, and a business that does both is doing two activities. Renting a villa out.
A villa manager is not a broker
KBLI 2025 also separates three things a Bali villa owner tends to buy from one firm. Running the villa for the owner is 55901: a third party running the accommodation for the owner, in day-to-day charge, for a management fee (Peraturan BPS 7/2025 Lampiran, KBLI 55901). Finding guests on a platform is 55400: matching guests and accommodation providers for a fee or commission, on a digital platform or otherwise (Peraturan BPS 7/2025 Lampiran, KBLI 55400). Selling or letting the property itself is 68210: real estate intermediation in buying, selling and renting, for a fee or commission, online or offline (Peraturan BPS 7/2025 Lampiran, KBLI 68210). Asking which of these codes a firm holds is a fair question before signing with it.
We do not broker property and do not recommend anyone who does. The lampiran rows are transcribed from the official PDF; the page numbers let you check each one.
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Questions on this page
What is KBLI 68111?
In KBLI 2020, the code the licensing lampiran of PP 28/2025 uses, 68111 is real estate owned or leased: the development, purchase, sale, rental and operation of housing, shopping centers and other property. It is open to micro to large businesses, medium-low risk, with an NIB plus a standard certificate issued automatically. KBLI 2025 (Peraturan BPS 7/2025) splits it: 68111 is now residential development and 68112 residential rental.
Can a foreigner be a property agent in Bali?
Not as a broker. The licensing lampiran for KBLI 68200 (real estate on a fee basis) requires the business to be a legal entity founded and domiciled in Indonesia, and every property broker on its expert list to be an Indonesian citizen (PP 28/2025 Lampiran I.G no. 1, requirement 2(a)).
Is a long-term villa rental accommodation or real estate?
Under KBLI 2025, accommodation provided for one year or more is classified as real estate (subclass 6811), not as accommodation in division 55. A villa let by the night or week is accommodation; a villa let for a year is residential rental.
Is KBLI 68111 closed to foreign investment in Bali?
For new applications, yes since the third week of May 2026: ANTARA's list of the 18 KBLI closed to new PMA applications in Bali includes 68111, real estate owned or leased, according to its 23 July 2026 report of the provincial decision.
Sources cited on this page
- PP 28/2025 Lampiran I.G and I.H — official text, JDIH BPK
- Peraturan BPS 7/2025 — KBLI 2025
- Permen Investasi/BKPM 5/2025 art. 26
- ANTARA, the 18 business lines closed to PMA in Bali, 23 July 2026
Every rule above was read in the Indonesian original on 20 September 2026, not from an English summary. How we check this.