balipropertyguideWho signs, and which deed the land office will actually register
Somewhere between the checks and the money, a purchase stops being about the property and becomes about documents and the people entitled to make them. Two offices do that work, they are usually the same person, and the difference only surfaces when something has already gone wrong.
The sentence the whole thing rests on
Article 37(1) of PP 24/1997 is not about ceremony. It is about what the land office will and will not enter in the register:
Peralihan hak atas tanah dan hak milik atas satuan rumah susun melalui jual beli, tukar menukar, hibah, pemasukan dalam perusahaan dan perbuatan hukum pemindahan hak lainnya, kecuali pemindahan hak melalui lelang hanya dapat didaftarkan jika dibuktikan dengan akta yang dibuat oleh PPAT yang berwenang…
Transfer of a land right or of strata title by sale and purchase, exchange, gift, contribution into a company and other legal acts transferring rights — except transfer by auction — may only be registered if evidenced by a deed made by an authorized PPAT.
PP 24/1997 art. 37(1)
Read “only be registered” carefully. The deed is not what makes the transfer effective against the world — registration is. The article makes the deed the precondition of registration, so a document that is not a PPAT deed does not fail at the signing. It fails later, at the counter, when there is nothing the land office can act on.
Why “authorized” is doing work in that sentence
The article does not say a PPAT. It says an authorized PPAT. Authority here is an appointment with a defined scope, and a deed made outside that scope is not cured by the quality of the drafting.
Notaris and PPAT are two offices, usually one person
This is the distinction that confuses foreign buyers most, partly because in practice the same individual normally holds both appointments and introduces themselves with one word.
| PPAT | Notaris | |
|---|---|---|
| What the office is | A public official authorized to make authentic deeds over land rights and strata titlePP 37/1998 art. 1(1) | A public official for authentic deeds generally — company documents, powers of attorney, agreements |
| Area of authority | One province. Bali is one provincePP 24/2016 art. 12(1) | Set by its own legislation, which this site has not read and does not quote |
| Why registration needs them | A transfer is only registrable on a PPAT deed PP 24/1997 art. 37(1) | Not the instrument the land office registers a transfer on |
| Which acts | Eight legal acts, listed in the articlePP 37/1998 art. 2(2) | Everything else a transaction needs in writing |
| In practice in Bali | Very often the same person, holding both appointments | Very often the same person, holding both appointments |
We have not read the legislation governing the notarial office and do not quote it. The right-hand column above describes only what the PPAT articles leave to somebody else, which is what a buyer needs from it.
The practical test
Ask one question: are you appointed as PPAT for this province, and will the deed for this transfer be made in that capacity? It is an ordinary question with a documentary answer. It is also the question that separates the two offices without requiring you to understand either.
The area of authority is a province, not a regency
Article 12(1) of PP 24/2016, amending the 1998 regulation, sets the daerah kerja — the area of work — of a PPAT at one province. Article 12A of the same regulation then places the PPAT’s seat in a regency or city inside that province.
Those two articles are easy to conflate and the consequence is a real cost. Bali is a single province containing nine regional governments. A PPAT authorized for Bali is authorized for land in Badung, in Gianyar, in Denpasar and in the six others; the regency only tells you where the office is.
Where this bites. Buyers are sometimes told they must instruct somebody in the regency the land sits in, and change adviser late in a transaction to comply with a rule that says something else. Note the contrast with tax, where the regency genuinely does decide: which regional government sets your acquisition duty is a different question with a different answer.
The eight acts, and where each one touches a Bali purchase
Article 2(2) of PP 37/1998 lists them exhaustively. Most readers need two of the eight, but the list is worth seeing whole, because it shows what this office is for and what it is not.
| The act, as the article names it | What it is in a purchase | |
|---|---|---|
| Jual beliSale and purchase | The transfer deed people call the AJB. This is the one most purchases turn on. | Where it appears here |
| Tukar menukarExchange | Land swapped for land rather than for money. | — |
| HibahGift | A transfer without consideration. Inheritance planning runs into it. | Where it appears here |
| Pemasukan ke dalam perusahaanContribution into a company (inbreng) | Land put into a company as a capital contribution — relevant if a PT PMA is acquiring rather than being sold shares. | Where it appears here |
| Pembagian hak bersamaDivision of jointly held rights | Co-owned land split between holders. The article that matters when several heirs hold one parcel. | Where it appears here |
| Pemberian Hak Guna Bangunan / Hak Pakai atas tanah Hak MilikGrant of HGB or hak pakai over freehold land | One way a foreign purchase is structured: the Indonesian owner keeps hak milik and grants you a registered right over it — for at most 30 years, renewable only by a new deed (PP 18/2021 art. 52(3)). | Where it appears here |
| Pemberian Hak TanggunganGrant of a mortgage | Security over the land. What a buyer checks for when asking whether anything is registered against the certificate. | Where it appears here |
| Pemberian kuasa membebankan Hak TanggunganPower to encumber with a mortgage | A power of attorney to create that security later. | — |
The sixth row is the one to notice. A grant of HGB or hak pakai over land that remains somebody else’s freehold is a PPAT act in its own right — which is the formal machinery behind the structure the hak pakai page describes, and the reason that structure is a registered right rather than a private arrangement. It is also precisely what distinguishes it from a nominee arrangement, which has no deed of this kind because there is no right being granted to the foreigner at all.
What is not on the list
A lease. Hak sewa does not appear among the eight acts, because a lease is a contract rather than a transfer of a registered land right — the same reason it sits outside acquisition duty. If your purchase is a leasehold, the PPAT machinery above is largely not what your transaction runs on, and what the lease document says carries correspondingly more weight.
The one exception, and why it is not yours
Article 37(2) provides the single route around the PPAT requirement: in circumstances the Minister determines, the Head of the Land Office may register a transfer of hak milik between individual Indonesian citizens on a deed not made by a PPAT, where its truth is considered sufficient to register.
Two qualifications close it. It applies to hak milik, which is the one right a foreigner cannot hold. And it applies between individual Indonesian citizens. There is no reading on which a foreign buyer falls inside it.
It is worth knowing anyway, because it explains something buyers encounter and misread: local transactions that genuinely did proceed on an informal document. That they exist is not evidence that you can do the same.
Where the deed sits in the sequence
The deed is late, and that is the point most often missed. By the time a PPAT is drafting, the questions that decide whether the purchase was a good idea have already been answered or skipped.
- Checks. Certificate against the register, designation, approvals, consents. What each document can and cannot prove.
- The binding contract. Where the terms are actually agreed.
- The PPAT deed. The instrument this page is about.
- Registration. Until this happens the right has not moved. Article 4(3) of PP 24/1997 makes registration of the transfer mandatory, not optional.
The full sequence, and where money is exposed in it.
Conversion happens here too
If you are a foreign buyer acquiring a house currently held as hak milik or HGB, the conversion to hak pakai under Permen ATR/BPN 18/2021 art. 187(3) lands in this part of the process. Who pays for it and what happens if it does not complete are contract questions that are cheap to settle before the deed and expensive afterwards.
We do not introduce, rank or vouch for notaries or PPATs, and we are paid a fixed fee per enquiry that does not move with whether you complete. This page exists so you can tell whether the person in front of you is doing the thing the regulation names.
Read next
What they may charge
The PPAT’s fee is capped at 1% of the deed price; the notary’s by band.
Before the deed
Every document to obtain, and what each one is actually capable of proving.
The whole sequence
Six stages, and the two that are almost always done back to front.
What you can hold
Fourteen listing terms resolved against the right each one actually names.
Hak pakai over freehold
The sixth act on the list: a registered right over someone else’s freehold, for 30 years.
Question about a deed or a document you have been sent?
Five questions. Your details are the last step, never the first.
Your questions are ready to send
Here is what happens after you submit:
- Your answers go to businesses that advertise for Bali purchases.
- No more than three of them may contact you, using the details you gave.
- You decide who, if anyone, you reply to. You are committed to nothing.
We are not an agency, a notary or a law firm, and we do not rank or recommend anyone. Sending this creates no professional relationship.
Questions about who signs
What is a PPAT?
Pejabat Pembuat Akta Tanah. Article 1(1) of PP 37/1998 defines it as a public official given authority to make authentic deeds concerning certain legal acts over land rights or strata title. Article 2(1) is the part that matters to a buyer: the PPAT's principal duty is to carry out part of the land registration activity, by making the deed that becomes the basis for registering the change. It is not a service sitting beside registration. It is a step inside it.
What is the difference between a notaris and a PPAT?
They are two different offices, frequently held by the same person, and the distinction only becomes visible when something goes wrong. A notaris makes authentic deeds generally. A PPAT makes the specific deeds that transfer or encumber land rights, and article 37(1) of PP 24/1997 provides that a transfer may only be registered if evidenced by a deed made by an authorized PPAT. A document drawn by someone acting as notaris but not authorized as PPAT for that land is not the instrument the land office registers on.
Do I need a PPAT in the same regency as the property?
No, and this is worth knowing because buyers are often told otherwise. Article 12(1) of PP 24/2016 sets a PPAT's area of authority at one province. Bali is one province, so a PPAT authorized in Bali is authorized for land anywhere in Bali. Article 12A separately says the PPAT is seated in a regency or city within that province — where their office is, not the limit of what they can do.
What is an AJB?
Akta Jual Beli, the sale and purchase deed. It is the first of the eight acts listed at article 2(2) of PP 37/1998 and it is the deed that transfers the right. People use 'AJB' as though it were the whole completion; it is one document, and registration at the land office is a separate step after it.
Can a transfer ever be registered without a PPAT deed?
There is exactly one carve-out and it does not reach a foreign buyer. Article 37(2) of PP 24/1997 allows the Head of the Land Office, in circumstances the Minister determines, to register a transfer of hak milik between individual Indonesian citizens on a deed not made by a PPAT, where its truth is considered sufficient. Two limits are doing the work: hak milik only, and individual Indonesian citizens only.
Does the PPAT check the property for me?
The PPAT's function is to make the deed and provide the basis for registration. Whether the land is designated for what you intend, whether the building was approved, and whether everyone who must consent has consented are separate enquiries with separate sources. Our due diligence checklist sets out which is which.
Who chooses the PPAT, the buyer or the seller?
That is a matter of negotiation, not law, and the answer is worth settling early. We do not recommend, rank or introduce individual PPATs and we have no view on any of them.
Is the deed in Indonesian?
The deeds a PPAT makes are Indonesian instruments. Where a bilingual version is produced, the English is a courtesy and the question of which version governs is answered by the document itself. Have the Indonesian read by somebody responsible to you.
Sources cited on this page
- PP 24/1997 arts. 4(3), 37 — land registration and the PPAT deed
- PP 37/1998 arts. 1, 2 — the PPAT office and the eight acts
- PP 24/2016 arts. 12, 12A — area of authority and seat
- Permen ATR/BPN 18/2021 art. 187 — conversion on acquisition
Every rule above was read in the Indonesian original on 20 September 2026, not from an English summary. How we check this.