Yes. Foreign investors can still develop and operate qualifying hotels in Bali through a PT PMA in 2026. However, Bali now restricts new OSS applications for 18 low- and medium-low-risk business classifications, including star-rated hotels with a building area below 6,000 square metres.
That distinction matters. The confirmed restriction is not a blanket ban on foreign hotel investment, but neither should investors assume that a project qualifies simply because it has a certain number of rooms. The applicable KBLI classification, building area, business risk level, ownership eligibility, location, and project permits must all be checked before capital is committed.
This guide explains what the Bali Government has officially confirmed, what remains subject to OSS and professional verification, and how foreign investors should assess a hotel project in 2026.
The Bali Provincial Government restricted OSS access for foreign-owned companies across 18 low- and medium-low-risk business classifications. According to the province’s official announcement dated 23 July 2026, the restriction had applied across Bali since the third week of May 2026.
The government said the policy followed an evaluation that found indications of misuse of risk-based licensing. Low-risk activities can receive a Business Identification Number (NIB) automatically and may not require a standard certificate or additional business licence. Bali’s government considered that this mechanism could allow foreign-owned businesses to enter sectors commonly served by local micro, small, and medium enterprises.
The official list includes star-rated hotels with a building area below 6,000 square metres, non-star hotels, other accommodation activities, and several non-hospitality activities. The announcement also identifies the use of virtual offices as an area of particular concern.
Official source: Bali Provincial Government — OSS access restrictions for PMA, 23 July 2026
No universal 101-room minimum has been confirmed by the official government source reviewed for this article.
Some professional advisory publications describe hotel risk tiers using room count, employee headcount, and building area. Those figures may help investors understand how OSS could classify a project, but they should not be presented as a definitive rule without checking the intended activity directly in OSS.
For the 2026 Bali restriction, the official provincial announcement specifically identifies star-rated hotels with a building area below 6,000 square metres. It does not state that 101 rooms or 100 employees automatically make a hotel eligible.
A project with different room, staffing, and building-size characteristics may require case-specific classification. Investors should ask a licensed Indonesian adviser or notary to confirm the current OSS treatment of the intended KBLI, location, and project data.
The safest approach is to treat company formation as one part of a wider hotel-development review.
KBLI determines the registered business activity and influences licensing, risk classification, supervising authority, and foreign-ownership eligibility. Investors should verify the current hotel classification in the official OSS KBLI database before it is inserted into a notarial deed.
Do not assume that a villa, guesthouse, apartment hotel, non-star hotel, and star-rated hotel use interchangeable classifications. The operating model and accommodation type must match the activity registered in OSS.
The 2026 Bali policy applies to specified low- and medium-low-risk activities. The intended KBLI should be tested using the actual Bali project address and current project specifications.
A consultancy article or general table is not a substitute for a current OSS check. Classification and application behaviour can change as the system and implementing policy are updated.
A business being technically available in OSS does not automatically mean it is open to foreign ownership. The company structure must also comply with Indonesia’s investment rules and any reservation applicable to the chosen accommodation activity.
This is especially important when distinguishing a hotel from a villa, guesthouse, or other short-term accommodation business. Investors should obtain written advice on the current foreign-ownership position for the exact KBLI rather than relying on a general description of the hospitality sector.
A PT PMA cannot hold Hak Milik freehold title. Hotel projects commonly use rights and contractual structures permitted for companies, such as Hak Guna Bangunan, subject to the underlying land and transaction structure.
Before acquisition or commitment, investors should verify:
· the land title and registered holder;
· tourism or other relevant zoning;
· spatial-use approval and KKPR requirements;
· access, utilities, and development restrictions;
· building approval and completion requirements;
· environmental obligations; and
· whether the proposed hotel use matches the registered business activity.
Zoning should be confirmed for the specific parcel. A general statement that an area is a tourism destination does not prove that an individual site is approved for hotel development.
Company capital, total planned investment, and immigration eligibility are related but separate issues. The applicable requirements may depend on the company’s KBLI, project location, shareholders, and the immigration status being requested.
Investors should verify the current requirements directly against the latest Ministry of Investment/BKPM and immigration rules. Capital figures and Investor KITAS thresholds should not be treated as interchangeable.
Eligibility to apply is only the beginning. A hotel may still require verification, standard certification, site inspection, spatial and building approvals, environmental documentation, and sector-specific compliance before it can operate.
The exact sequence depends on the KBLI and risk level. A practical due-diligence workflow is:
1. Define the accommodation type and operating model.
2. Confirm the intended KBLI and foreign-ownership eligibility.
3. Test the activity and project details in OSS.
4. Verify the land title, zoning, and spatial-use position.
5. Map the required building, environmental, tourism, and operational approvals.
6. Form or amend the PT PMA only after the structure has been checked.
7. Complete the required certifications and inspections before opening.
8. Maintain corporate, tax, and LKPM reporting after registration.
The Bali Government’s July announcement states that companies which already hold licences remain responsible for submitting their Investment Activity Reports (LKPM). It does not, by itself, answer every question about amendments, relocation, added KBLI activities, or pending applications. Those cases require individual review.
Large projects may fall outside the specific restriction on star-rated hotels below 6,000 square metres, but size alone does not prove full compliance.
An investor should still verify:
· the building area used for the OSS assessment;
· the registered KBLI and risk level;
· foreign-ownership eligibility;
· land rights and tourism zoning;
· spatial, building, and environmental approvals;
· the hotel operator or management agreement;
· construction and completion status; and
· the assumptions used in the financial model.
CROSS Bali Uluwatu is one example of this type of large-scale project. Developed by PT THE CUBE GROUP in Pecatu, Uluwatu, and operated under a Hotel Management Agreement with Cross Hotels & Resorts, it illustrates the scale of due diligence a foreign investor should expect from a hotel investment of this size.
Investors reviewing CROSS Bali Uluwatu should request current supporting documents for the project’s land rights, zoning, building approvals, room count, building area, construction status, and hotel management arrangement as part of their due diligence.
Bali did not close the door to all foreign hotel investment in 2026. It restricted OSS access for specified low- and medium-low-risk activities and expressly included star-rated hotels below 6,000 square metres in the official list.
The defensible question is therefore not simply, “How many rooms does the hotel have?” It is whether the exact business classification, building area, ownership structure, location, and permits comply with the rules currently applied in OSS.
Because this policy and its implementation can change, investors should verify the intended activity directly in OSS and obtain Indonesian legal, licensing, tax, and immigration advice before committing capital.
To review the available project information and request the supporting due-diligence documents, visit the CROSS Bali Uluwatu investment overview.
Yes, foreign hotel investment remains possible, but the proposed activity must be open to foreign ownership and pass the current OSS, risk-level, location, and licensing checks. Bali’s 2026 restriction covers 18 low- and medium-low-risk classifications, including star-rated hotels below 6,000 square metres.
The official Bali Government announcement reviewed for this article does not establish a universal 101-room minimum. It refers to star-rated hotels with a building area below 6,000 square metres. Room count and staffing figures reported by advisers should be verified directly in OSS for the proposed project.
A hotel requires a genuine physical site, and the Bali Government has identified virtual-office use as a focus of its tighter oversight. Confirm the accepted company address and project-location requirements with the notary and OSS adviser handling the application.
Registering a company outside Bali should not be treated as a workaround for an activity conducted in Bali. The operating location, business classification, site, and permits must accurately reflect the actual hotel business.
Start with the intended accommodation type, KBLI, foreign-ownership eligibility, OSS risk level, building area, and site zoning. These checks should be completed before the land transaction, company deed, or investment structure becomes difficult to change.
