- In the developer-with-PT-PMA model the developer's company holds the land on an HGB title or a leasehold in its own name, and you buy the villa under one contract with that company. If the company closes or loses its licence, you argue with the insolvency estate rather than own the asset.
- In the three-contract model the land is leased directly to you by the landowner, you sign the construction contract with the general contractor, and you sign a services agreement with the coordinator. If the coordinator disappears, the land and the build contract stay with you.
- Since May 2026 new PT PMAs in Bali are not registered under 18 KBLI codes, including 68111 real estate. Existing companies operate under heightened scrutiny and LKPM reporting. RTRW, the">Perda 4/2026 added liability for nominee schemes.
- The money flows differently. In the first model the whole sum goes to the developer's account and mixes with its turnover. In the second the land is paid to the landowner, the build to the contractor against stage acts, and the coordinator receives a fee and documented earmarked payments.
- Neither model removes construction or market risk. The difference is whose name the asset is in if something goes wrong, and how much time and money the checks take. In both cases verify primary sources at BPN and OSS, not the seller's PDF.
The direct answer is this. For a buyer, the safer model is the one in which the land and the build are in their name rather than an intermediary's. In 2026 that is the three-contract model, where the leasehold is signed with the landowner in your name, the construction contract with the general contractor, and the coordinator earns a services fee. Buying from a PT PMA developer under one contract can also be legal and workable, if the company was registered before May 2026, its licences are valid and the rights to the villa pass to you rather than stay on the company's books. But in that model you depend on the fate of someone else's legal entity, and the checks need to go deeper. Below we compare both along seven axes, explain what changed in the law and give a checklist for each case.
How the two models work
Developer with a PT PMA. A foreign-owned company with Indonesian registration holds the land on an HGB title or leases it in its own name, builds the villas and sells them to the buyer under one contract. The money for the villa goes to that company's account. The buyer's rights depend on what the contract says. Either the company assigns the plot leasehold to you and hands over the house, or the villa stays on the company's books and you receive a share, a long-term lease or a right of use. Until 2026 most foreign developers in Bali worked this way, including DOMA in its first three years.
Three contracts. The villa lives in three documents with different parties. The first is a leasehold agreement between you and the landowner, with the cadastral number, area and term, certified by a notary. The second is a construction contract between you and the general contractor, with the specification, materials, deadlines and penalties. The third is a coordinator services agreement between you and the company that finds the plot, runs the checks, selects the architects, manages the build and hands the property over into management. The coordinator does not hold the land and does not take the construction budget into its account. How and why DOMA moved to this model is told in why DOMA changed how it works. Here we look not at our history but at the buyer's choice.
What changed in 2026
Since the third week of May 2026 the province of Bali no longer lets applications from new PT PMAs through the OSS system under 18 low- and medium-low-risk KBLI codes. The list includes code 68111 "real estate, own or leased", under which foreign developers held land and sold villas. The governor announced the measure publicly on 22 and 23 July 2026. New companies under this code are not registered, existing ones are not cancelled but come under heightened checks and mandatory LKPM reporting. The breakdown is in PT PMA closed in Bali under 18 codes.
The second change is Bali's Perda 4/2026, which added local liability for nominee land schemes, and the tax office's move to Coretax, where BPN does not re-register a certificate without validation of the seller's and buyer's NIK. The third is the delisting from Airbnb and Booking of properties without an NIB and the correct KBLI from 31 March 2026. All three changes hit models in which the asset is registered to someone other than the person who really owns and uses it.
There is one question for any model. If the company you signed with disappears tomorrow, what do you hold in your hands, and whose name is it in.
A comparison along seven axes
| Axis | Developer with a PT PMA, one contract | Three contracts |
|---|---|---|
| Who holds the land | the developer's company, HGB or leasehold in its name | you, a leasehold in your name from the landowner |
| Who is the party to the build | the developer, the contractor owes you nothing | the general contractor answers to you directly |
| Where the money goes | the whole sum to the developer's account | land to the landowner, build to the contractor against acts, a fee to the coordinator |
| If the company closes | you are a creditor of the insolvency estate | the land and the build contract stay with you, the coordinator changes |
| KBLI regulatory risk | depends on the company's 68111 licence | independent, no document requires a PT PMA |
| Stage control | inside one contract, on readiness | payment 30/30/30/10 against stage acts, specification in the contract |
| Simplicity for the buyer | one contract, one counterparty | three documents, three parties, more reading |
Who owns the land in each model
This is the main axis. In the one-company model the land is registered to the developer's company. If it is HGB, the title belongs to the legal entity and you receive rights through a contract with it. If it is a leasehold in the company's name, you are a sub-lessee or an assignee, and your right is no longer than the company's. In both cases a third-party legal entity with its own debts, taxes and licences stands between you and the land.
In the three-contract model the leasehold is signed directly between you and the landowner. Your name is in the notarial deed, the term and extension formula are fixed in the agreement, 29+10+30 years in DOMA projects. The coordinator is not a party to this document. That means the right to the plot depends neither on the coordinator's licence nor on its balance sheet. What to check in the leasehold itself is covered in leasehold in Bali for foreigners, and whose name the land is in under different models in PT PMA versus leasehold.
What happens if the company closes
The scenario is not theoretical. Since May 2026 existing PT PMAs under 68111 are under heightened scrutiny, and licence revocation or liquidation has become a real risk rather than an insurance event. In the one-company model, on the developer's liquidation or bankruptcy the land and unfinished villas go into the insolvency estate. The buyer becomes a creditor, and their claim competes with banks, contractors and the tax office. If the contract provided for a leasehold assignment to the buyer after full payment, and payment was made before handover, the assignment may never happen.
In the three-contract model the coordinator closing is unpleasant but not catastrophic. The land is already registered to you after the first payment. The construction contract is signed with the general contractor, and its obligations to you remain. You need to find a new coordinator or run the build yourself, which costs money and time, but it is not a loss of the asset. If the general contractor closes, you hold a contract with it, signed acts for completed stages and have paid only for finished work, because tranches follow acts. How to act when deadlines slip is covered in the developer missed the deadline.
Where the money goes
In the one-company model the whole villa price arrives in the developer's account and mixes with its turnover. Where it went next, to your build, to another project or to debts, you cannot see. The developer's instalment plan is tied to the calendar or to readiness as the developer judges it. The price includes VAT of 11–12% on the building and a margin of 15–25%, but neither is usually shown as a separate line.
In the three-contract model the money goes to three recipients and every payment has a basis. The land payment goes to the landowner through the notary and is documented by a deed in your name. The construction budget goes to the general contractor in stages after an act is signed for each, 30/30/30/10 in DOMA projects. The coordinator receives a services fee under its agreement and earmarked payments on your instruction, for example for the notary or permits, each with a receipt or invoice. This does not make the build cheaper, but it makes it transparent, and you see where the margin is and where the tax is. If the notary holds funds in escrow until the act, the protection is stronger.
Running the numbers
Compare entry into a 2BR villa in Ubud under the two models on the site's data to see exactly where the difference lies.
One-company model, a finished villa at $220,000 (the median 2BR leasehold per DUVI, Q3 2026). Added to the price are VAT on the building if not included, the notary at 0.5–1%, registration at about 1%, legal due diligence at $1,000–2,500. By the benchmarks in the article on villa cost, a developer purchase with VAT adds up to 16–17% to the price, so the full amount can reach $255,000. The main question for the seller is which taxes are already inside the price, and the answer must be in writing.
Three-contract model, an off-plan villa from $139,000 (Mirador, 2BR 72 m², handover September 2027). From the villa-cost article the cost of such a property breaks down as follows. Leasehold land about $36,000, construction $61,000, pool and terrace $18,000, furniture and appliances $20,000, design, permits and legal $9,000. Each line is paid to its own recipient. The land payment comes first, the build 30/30/30/10 against acts. On top come the notary and checks, $3,000–5,000, but there is no developer's VAT on the villa as a product, because you are not buying a finished product but paying for land and a build contract.
What the numbers show. The price difference between the models comes not from "honesty" but from structure. In the first you pay for a finished product with tax and margin inside, in the second for components separately and wait 12–18 months for construction. The second is cheaper to enter and more transparent, the first gives you a finished house now. But to the question "what remains mine if the company disappears" the answers differ, and that is not counted in dollars.
Sources: DOMA's article on villa cost (2BR cost breakdown, taxes and purchase costs, Magnum Estate, Teville, Balitecture, 2026), the DUVI index (issue 1, Q3 2026), DOMA's breakdown of the OSS restriction on new PT PMAs (in force since May 2026, announced 22–23 July 2026), DOMA's article on Perda 4/2026 and Coretax (Emerhub, DDTC), DOMA agreements in their 2026 edition.
What to check in each case
If you buy from a PT PMA developer. The company's registration date and a valid NIB with code 68111 in OSS, registered before May 2026. The land title at BPN, HGB or leasehold in the company's name, term and encumbrances. KKPR and PBG permits for the specific plot. What exactly passes to you under the contract and when, the leasehold assignment after which payment. What is written about the company's liquidation and the transfer of rights if its licence is revoked. An independent PPAT notary, not the developer's notary. The full checklist is in how to vet a developer.
If you buy through three contracts. The landowner's certificate at BPN is clean and matches the cadastral number in the leasehold. The leasehold is a notarial deed in your name with clauses on extension, inheritance and assignment. The plot zoning allows housing and rental. The construction contract contains the specification, materials, deadlines, penalties and payments tied to stage acts. The general contractor exists as a legal entity, has a portfolio and previous properties you can visit. The coordinator agreement contains specific obligations on the plot, checks, design, deadlines and quality, not yield percentages. The full breakdown is in the article on villa due diligence.
In both cases verify primary sources. The certificate is checked at BPN, zoning at the provincial dinas, the legal entity in OSS and AHU by NIB number. A PDF from the seller is an illustration, not proof.
Who each suits
- Buying from a PT PMA developer suits someone taking a finished villa from a company with a track record of completed properties, registered before May 2026, with a clean title and valid licences, who is ready to pay for the simplicity of one contract with a deep check of the company and its resilience.
- The three-contract model suits someone buying during construction, who wants the land and the build in their name from day one, is ready to read three documents instead of one and values payment transparency over speed.
- Neither suits you if the seller cannot show whose name the land is in, which KBLI code the company operates under and where each payment goes. That is not a question of model but a signal to walk away.
Bottom line. A PT PMA developer and the three-contract model are two ways to structure the same villa, and the difference between them is whose name the asset is in if something goes wrong. In the first model a third-party legal entity stands between you and the land, its 68111 licence has been under heightened scrutiny since May 2026, and the money goes to its account. In the second the land is in your name, the build contract is with the general contractor, the coordinator earns a fee, and its closing does not touch the asset. Neither model removes construction or market risk. But to the question of what you will hold if the company disappears, the second answers more clearly. Check both against the lists above with an independent lawyer, and if you want, we will show all three documents on our own project and answer questions about your deal.
This material is for information only and is not legal advice. The structure of a deal depends on the specific plot, landowner, contractor and seller company. Have any document reviewed by an independent lawyer and a PPAT notary before signing.
FAQ
Can I safely buy a villa from a PT PMA developer in 2026?
Yes, if the company was registered before May 2026, its NIB and KBLI are valid, the land title is clean at BPN, PBG permits are issued, and the contract transfers rights to you rather than leaving the villa on the company's books. Verify all of this in primary sources. A new PT PMA under code 68111 can no longer be registered in Bali.
What happens to my villa if the developer closes the company?
In the one-company model the land and villa are registered to that company, and on liquidation or bankruptcy you become a creditor. In the three-contract model the land is leased in your name and the build contract is with the general contractor, so the coordinator closing does not touch the asset. The coordinator changes, not the owner.
Where does the money go in the three-contract model?
The land payment goes to the landowner through the notary, in your name as lessee. The construction budget goes to the general contractor in stages after acts are signed, 30/30/30/10 in DOMA projects. The coordinator receives a services fee and earmarked payments on your instruction, each backed by a document.
Which model is cheaper?
There is no direct rule. In the one-company model the price includes 11–12 percent VAT on the building and a 15–25 percent developer margin. In the three-contract model you pay the landowner, the contractor and the coordinator separately and see every line. Compare the full amount with taxes and what exactly you own at the end.