Yesterday someone asked me: “I just read your last post. If I purchase through a developer, they handle operations and management, and I’m just a passive investor using a PT PMA — is that still compliant under the new model? I’ve bought into a resort-style project and now I’m concerned.”
This is exactly the right question to be asking right now.
Let’s break it down in the simplest possible way.
Regulators do not look at whether you are passive or active. They look at licensing and structure. Specifically:
- What KBLI the company holds
- Who is legally operating the rental activity
- Where the revenue flows
- Whether the zoning matches the activity
Being “passive” does not automatically make a structure compliant.
Now, there are two very different scenarios.
First scenario: the developer or resort operator holds the proper tourism/accommodation license. They operate the property, manage bookings, handle staff, collect guest payments, and your PT PMA simply receives lease income, profit share, or dividends.
In this structure, your PT PMA is not operating short-term rentals. It is either leasing the unit to a licensed operator or acting as a shareholder in a properly licensed company. If structured correctly, this model may remain compliant even if KBLI 681 becomes restricted for PT PMA — because your company is not the operator. The licensed tourism entity is.
Second scenario: your PT PMA is the actual operator. If your PT PMA holds KBLI 681 (or similar), lists the unit on Airbnb or Booking platforms, receives nightly rental income directly, and pays operational expenses, then your PT PMA is the short-term rental business.
If KBLI 681 and its subcategories are restricted or removed for PT PMA, this structure could face regulatory issues. Even if you personally do nothing and the developer “assists,” regulators will look at who holds the license and who receives the income. That determines compliance.
This is where many investors get confused. They assume: “I’m passive, so I’m safe.” But legally, passive is not the test. The test is operational control and licensing alignment.
Resort-style and guaranteed return models are not automatically unsafe. But if the structure relies on a PT PMA using a KBLI category that is being restricted — and that PT PMA is effectively the rental operator — then yes, it should be reviewed.
So what should investors do now?
Do not panic. But verify:
- What exact KBLI does your PT PMA hold?
- Is your PT PMA legally classified as the operator?
- Who receives guest payments?
- Does the zoning match tourism/accommodation use?
- Does the developer hold proper operational licensing?
The regulatory direction in Bali appears to be moving toward stricter alignment between license and activity, tighter control over foreign-operated short-term rentals, and less tolerance for structural shortcuts.
Bali is still investable. Resort-style models are not automatically non-compliant. But this is no longer a “set and forget” environment.
Structure now matters more than ever.
For a deeper discussion on structuring your Bali property investment correctly under the latest KBLI and PT PMA regulations, connect directly with Fathi Talib.
👉 Explore his full profile and insights here:
https://harcourtspurbabali.com/blog/agent/fathi-talib/
