**Indonesia’s Positive Investment List fixes the maximum foreign ownership for every activity a PT PMA can run, indexed by KBLI code. As of 2026 the default is 100% open across most sectors, but Bali startups face a live catch: OSS-RBA has been rejecting low-risk codes at Bali addresses. Treat what follows as outlook, not prediction — and verify your codes before you form.**
If you are planning a foreign-owned company in Bali, the single document that decides whether you can own 100%, must take a local partner, or are locked out entirely is the Positive Investment List — the Daftar Positif Investasi introduced under Presidential Regulation No. 10 of 2021 and amended by No. 49 of 2021, administered by BKPM under the Ministry of Investment. Every revision re-prices who can build what. Here is where things stand in mid-2026, the dated signals pointing into 2027, and the checks a founder should run before signing a deed.
What is the Positive Investment List, and why does it set your ceiling?
Before 2021, Indonesia ran a “Negative Investment List” that named what foreigners could not do. The logic flipped. The Positive Investment List now starts from the presumption that a sector is open to full foreign ownership unless a specific rule says otherwise. That single change moved hundreds of KBLI business-classification codes to 100% foreign-eligible.
Your KBLI codes are the hinge. Every PT PMA selects one or more codes at registration, and each code carries its own foreign-ownership ceiling, minimum-capital reading, and risk rating under the OSS-RBA system. Picking them is strategy, not paperwork — the codes you choose decide your ownership cap, your licensing path, and increasingly whether the online system will even accept your Bali address. This is why serious [company formation in Bali](/offshore-company-formation-bali/) starts with code selection, long before company names or logos.
The capital math is separate from the ownership question but runs in parallel. A PT PMA still carries a minimum investment plan of IDR 10,000,000,000 — roughly USD 660,000 to 700,000 as of 2026, depending on the exchange rate — with minimum paid-up capital generally 25% of that, IDR 2,500,000,000, about USD 150,000 to 175,000. According to Emerhub, that IDR 2.5 billion paid-up floor is set by Article 26(10) of BKPM Regulation No. 5 of 2025. Figures are date-stamped and subject to change.
Which sectors are open, conditional, or closed as of 2026?
The table below groups common startup sectors by their 2026 posture. These are illustrative clusters, not a substitute for the exact code lookup in OSS — caps and conditions attach to individual KBLI numbers, and two neighbouring codes can behave very differently.
| Sector cluster | Example KBLI area | Status as of 2026 | What to watch into 2027 |
|---|---|---|---|
| Software, SaaS, IT services | 62-series (e.g. 62019 software development) | Open — 100% foreign | Stable; flagged as a digital-economy priority |
| Management & business consulting | 70209 | Open — 100% foreign | Stable |
| Tourism accommodation / villa operation | 55130 and related | Open, with capital and licensing conditions | Bali address friction — watch OSS behaviour |
| Food & beverage service | 56-series | Mostly open; partnership pressure at small scale | Threshold rules for small outlets under review |
| Construction & property development | 41- and 68-series | Conditional — permits, capital-heavy, some caps | Property-rights reform frequently floated |
| Distribution, wholesale, retail trade | 46- and 47-series | Conditional — retail often restricted or partnered | E-commerce carve-outs the key variable |
| Land transport & logistics | 49-series | Conditional / capped | Ongoing |
| MSME-reserved small trades | various low-capital activities | Closed to PT PMA (reserved for local/MSME) | Enforced through Bali OSS blocks |
| The absolute prohibitions | narcotics cultivation, gambling and casinos, listed endangered-species fishing, coral harvesting, chemical-weapons precursors | Closed — no private investment, foreign or domestic | No change expected |
The honest reading: most software, consulting, and services plays a Bali startup would launch sit in the open column today. The friction shows up in tourism-adjacent, retail, and property activities — exactly the sectors that draw foreign founders to Bali in the first place.
What 2026 signals point to 2027 changes?
No one can promise what the 2027 list will say. What can be tracked are dated 2026 signals that shape the direction of travel:
- A tighter capital baseline is already live. BKPM Regulation No. 5 of 2025 restated the IDR 2.5 billion paid-up floor, per Emerhub — a 2025 rule reshaping every 2026 formation, and a sign the ministry is standardising, not loosening, entry thresholds.
- Bali-specific enforcement is hardening. OSS-RBA has been blocking low and medium-low risk KBLI codes for PT PMAs registered at Bali addresses through 2026. This is an enforcement pattern layered on top of the statute, not a change to the list itself — which makes it harder to predict and easier to trip over.
- Digital-economy sectors keep their priority status, suggesting software and IT codes stay open into 2027.
- Cross-border transparency is rising. Indonesia participates in automatic exchange of information (CRS) with Australia, Singapore, the US, and EU jurisdictions, so ownership structures are increasingly visible to home-country tax authorities.
Read together, these point to a 2027 environment that is more open on paper for tech and services, but more procedurally strict at the Bali counter for tourism, retail, and property. Outlook, not prediction.
Why does a Bali address change the math?
A code that is 100% open nationally can still be refused when the registered address sits in Bali. That is the practical trap of 2026. The Positive Investment List tells you the ceiling; the OSS-RBA platform decides acceptance; and local district authorities issue the domicile letter (SKTU) that ties your entity to a physical Bali location. Registered-address proof requires an office rental agreement, a land certificate, or a building permit (now the PBG). A mismatch between an ambitious code and a Bali domicile is where formations stall.
What should a Bali startup verify before forming?
Run these checks before the notary drafts your deed of establishment:
- Pull each candidate KBLI code in OSS and confirm its 2026 foreign-ownership cap and risk rating — not last year’s figure.
- Test the code against a real Bali address, since national eligibility does not guarantee Bali acceptance.
- Confirm the capital position: the IDR 10 billion investment plan is a commitment; the IDR 2.5 billion paid-up must actually be injected. The initial bank deposit to open the account can be administratively small, often under USD 100 per Bali Villa Realty — a separate step from the capital requirement.
- Check the governance minimum: at least two shareholders, one director, one commissioner. The director must reside in Indonesia; a foreign director needs a KITAS and a personal NPWP, per Indonesia-Investments.
- Consider a KPPA first if you are only testing the market. A representative office does market research, liaison, and promotion — no invoicing, no revenue — and skips the IDR 10 billion requirement. Note that “soft” commercial activity can create permanent-establishment tax exposure for the foreign parent.
What’s the honest bottom line?
The Positive Investment List opened Indonesia far more than the old regime, and for most Bali startups building in software, consulting, or services the 2026 door is open. The risk in 2027 is not a sudden closure — it is procedural: KBLI codes, Bali-specific OSS blocks, and capital compliance. This piece is information, not legal or tax advice. Before you form, confirm your codes and structure with licensed Indonesian counsel and a registered tax consultant, and re-check the list on the day you file — because as of 2026, every figure here is subject to change.