For foreign investors exploring a room hotel investment in Bali, full ownership and operation through a PT PMA may still be possible, provided the project falls within Indonesia’s medium-high or high-risk tier under the OSS system. Since May 2026, Bali has stopped accepting new PT PMA registrations for hotels in the low or medium-low risk tiers, a threshold that many budget and boutique properties may not meet without further assessment.
Indonesia opened nearly all hotel investment to foreign capital when it eliminated the old Negative Investment List. That opening still stands. What changed in Bali is a separate, size-driven gate inside the OSS risk-based system, one that many investors researching the market overlook until they are deep into due diligence.
The OSS Risk-Based Approach (RBA) classifies every business line, hotels included, into one of four risk levels: low, medium-low, medium-high, or high. That classification determines the licensing path, and in Bali specifically, it now also determines whether a new foreign-owned PT PMA can register the business at all.
Since the third week of May 2026, Bali’s provincial government has blocked new PT PMA applications for business activities in the low and medium-low tiers. The restriction runs across 18 selected KBLI classifications, star hotels among them, and was confirmed in an official announcement on 23 July 2026. The stated goal is protecting small and medium local enterprises from foreign-owned businesses entering the market through classifications that required little more than an automatically issued business registration number, without the level of capital investment a PT PMA is meant to bring.
This is a Bali-specific layer on top of Indonesia’s national investment rules. Nationally, the old Negative Investment List no longer applies to most hospitality classifications, and full foreign ownership remains the default position for the hotel sector as a whole. What changed is not whether foreigners can own hotels in Indonesia, but whether a specific scale of hotel can register a new PT PMA in Bali province.
A hotel’s risk tier in Bali is set by three factors together: guest room count, employee headcount, and total building size. None of the three decides it alone, and a hotel that clears one threshold but not the others is classified based on where the combination lands, not on a single number in isolation.
| Risk level | Guest rooms | Employees | Building size (m2) | New PT PMA registration |
|---|---|---|---|---|
| Low | Up to 60 | Up to 40 | Under 4,000 | Closed since May 2026 |
| Medium-low | 61 to 100 | 41 to 99 | 4,000 to 6,000 | Closed since May 2026 |
| Medium-high | 101 to 200 | 100 to 200 | 6,000 to 10,000 | Open |
| High | More than 200 | More than 200 | 10,000 or more | Open |
A hotel needs to clear these thresholds to land in the medium-high or high tier, where a new PT PMA can register directly and hold the license itself. Below that, the path into the sector runs through a compliant arrangement with an existing licensed local company, not a fresh PT PMA registration. A boutique hotel with 40 rooms and a small footprint sits comfortably inside the low tier regardless of its nightly rate or design quality, because the classification tracks scale, not market positioning.
This is worth verifying against current OSS classification tables before acting on it. The three-factor structure comes from Emerhub, a corporate services firm active in Bali, and Indonesia’s risk-based licensing framework has been revised more than once in the past two years, most recently with the KBLI 2025 update in December 2025. A threshold that applied last year can shift with the next revision.
For investors considering a room hotel investment in Bali, a larger star-rated property may be assessed differently from a 40- or 60-room boutique hotel under the OSS risk-based licensing system. However, room count alone does not guarantee access to the medium-high or high-risk tier. Investors must also verify the hotel’s building area, KBLI classification, business scale, zoning, and current OSS requirements before drawing conclusions about foreign ownership.
For a qualifying project, the PT PMA registers directly, holds the land under Hak Guna Bangunan (HGB) title or a registered long-term lease, and carries the license itself. There is no intermediary standing between the investor’s company and the asset. For a smaller project below the threshold, the workaround is a compliant structure through an existing licensed local company, which adds a layer of dependency, and a corresponding layer of counterparty risk, that a fully independent PT PMA does not carry.
Neither path is illegal, and both can produce a working hotel business. The difference is in who holds the license, who controls the entity, and how much the investor’s position depends on a third party staying compliant and cooperative over the life of the investment.
CROSS Bali Uluwatu, developed by Cube Bali (PT The Cube Group) under a Hotel Management Agreement with Cross Hotels & Resorts, is planned at 120 to 130 keys. On room count alone, that places the project inside the 101 to 200 range that the medium-high tier requires, comfortably above the 100-room line where the lower, closed tiers stop.
Room count is one of three factors in the classification, alongside staffing and building size, so a project’s exact tier depends on where all three land together, not room count in isolation. What the figure does show is that a development sized in this range is structurally positioned for direct PT PMA registration and HGB land rights, rather than the workaround structures that smaller projects need.
For investors evaluating a similarly sized opportunity, that structural position, a PT PMA holding its own license and land rights rather than routing through a third-party operator, is one of the clearer signals that a project was sized correctly for full foreign ownership from the outset. Cube Bali’s investment team can walk through how this applies to CROSS Bali Uluwatu and comparable projects.
Room count and overall project scale, not the hotel sector by itself, decide whether a foreign investor can fully own a Bali hotel through a PT PMA. A property in the 101-room-and-up range starts from a materially stronger position than a smaller boutique development, because it is the range where Indonesia’s OSS risk tiers open the door to direct registration rather than a workaround.
Investors weighing a comparable opportunity can review how CROSS Bali Uluwatu applies this structure by reaching Cube Bali’s team through the Invest page.
This article is informational and does not constitute legal advice. Regulatory thresholds in this space have changed more than once in the past two years and can change again. Confirm current requirements with a licensed Indonesian legal or investment consultant before structuring a transaction.
Yes, through a PT PMA, provided the hotel’s scale places it in the medium-high or high risk tier under Indonesia’s OSS system. Since May 2026, Bali no longer accepts new PT PMA registrations for hotels in the lower tiers.
Room count is one of three factors, alongside staffing and building size. On room count alone, 101 or more rooms places a hotel in the medium-high tier, where direct PT PMA registration remains open.
It is Indonesia’s licensing framework that classifies every business activity, hotels included, into low, medium-low, medium-high, or high risk. The classification determines licensing requirements and, in Bali since May 2026, whether a new PT PMA can register the business at all.
A PT PMA is the standard vehicle for full foreign ownership. Projects that fall below the medium-high risk threshold cannot register a new PT PMA directly and instead need a compliant arrangement with an existing licensed local company.
New PT PMA registration for that business line is generally restricted, so a foreign investor needs an alternative structure, such as a partnership with a licensed local entity, rather than direct registration.
