- Since the third week of May 2026 the province of Bali automatically rejects new PT PMA applications under 18 KBLI codes, including 68111 “real estate, own or leased”. The measure was announced publicly on 22 and 23 July 2026. The scheme “buy a villa from a foreign company that holds the land, builds and sells” is closed to new companies and under heightened scrutiny for existing ones.
- For three years DOMA worked as a developer. In 2026, together with our lawyers, we rebuilt the structure and the contracts and opened a new company for a new role. DOMA now coordinates the project rather than selling a finished product.
- The villa as an asset lives in two documents where DOMA is not a party. First, the Leasehold Agreement between you and the landowner, with the cadastral number, area, address and term. Second, the construction contract between you and the general contractor, with the specification, storeys, floor area, materials and deadlines.
- Money: the land is registered directly in your name and the construction budget goes directly to the contractor. DOMA's account receives the coordination fee and earmarked payments made on your instruction (for land, the notary and other costs), each backed by a document.
- For the buyer this changes the risk profile. The asset and the building contract are in their name, not the intermediary's. If anything happens to the intermediary, the land and the contractor agreement stay with the owner.
In 2026 DOMA changed how it works with buyers. For three years we were a developer: we found land, designed, built and sold villas as a finished product. Since May 2026 a foreign-owned company in Bali can no longer register under the developer's activity code. For new companies the “everything through one company” scheme is closed, and for older companies it has been left in a grey zone. Together with our lawyers we rebuilt the structure and the contracts and opened a new company for a new role. Below we explain what exactly changed, how land, construction and money are now set up, and which questions to ask any seller on the island.
What changed in the law
Since the third week of May 2026 the province of Bali no longer lets applications from new foreign-owned companies (PT PMA) through the OSS licensing system under 18 low- and medium-low-risk KBLI codes. The list includes 68111 “real estate, own or leased”. This is the very code under which foreign developers held land, built and sold villas. The governor announced the measure publicly on 22 and 23 July 2026, and it is agreed with the investment ministry. Applications under the closed codes are rejected automatically. Already registered companies are not cancelled, but they come under heightened checks and mandatory LKPM reporting. We published the full breakdown in “PT PMA closed in Bali: 18 KBLI codes, including real estate 68111”.
The practical consequence for the market is simple. The scheme where one foreign company leases the land, builds on it and sells you a “villa” under a single contract no longer works for new companies. For existing companies it is formally alive, but every such contract now deserves one question: who runs this activity, under which code, and what happens to my villa if the company loses its licence.
The new model: three documents instead of one
Previously a buyer signed one contract with the developer for “a villa”. Now the property lives in three documents, and DOMA takes part in the first one only.
| Document | Parties | What it contains | What it gives you |
|---|---|---|---|
| Coordinator services agreement | You and DOMA | The obligation to find the plot, run due diligence, select the architects, coordinate construction so the property is completed on time and to the agreed quality, and hand it over into management | Responsibility for the process is fixed in a contract with specific obligations, not in a sales deck |
| Leasehold Agreement | You and the landowner | The exact cadastral number of the plot, area, address, lease term and extension terms | The most important document about your property. The right to the land belongs to you, not to an intermediary |
| Construction contract | You and the general contractor | The technical characteristics of the building: storeys, floor area, materials, architectural plan, specification, deadlines | The build is contracted in your name. The contractor answers to you directly |
In the agreements we support, the lease term is built as 29 + 10 + 30 years, a 69-year horizon in total. How leasehold works for a foreigner and what to check in the agreement is covered in Leasehold in Bali: legal ownership for foreigners.
A villa stops being a “product” sold to you. It is a plot registered in your name and a building contract you signed. The coordinator's job is to make those two things come together on time and to specification.
Where the money goes
The most common question about any scheme in Bali is “whose account am I paying into, and for what”. In our structure the answer is as follows.
- The land is registered directly in your name. The lessee under the Leasehold Agreement is you, named in the notarial deed.
- The construction budget goes directly to the contractor in the stages written into the construction contract, not to a developer's account.
- DOMA's account receives the fee for managing construction and earmarked payments made on your instruction: for land, the notary and other closing costs. Each such payment is backed by a document: a deed, a notary receipt or an invoice.
This does not make the deal risk-free. A build is still a build and land is still land. But it changes who holds the asset if something goes wrong.
What this changes in the investor's risk
| Risk | “Everything through one company” | Coordinator model |
|---|---|---|
| The intermediary disappears, goes bankrupt or loses its licence | The land and the villa contract sit in its company. The buyer argues with the insolvency estate | The land is in your name and the building contract is with the contractor directly. The coordinator changes, not the asset |
| KBLI regulatory risk | Depends on whether the company keeps its 68111 licence and passes inspections | Independent. No document requires a PT PMA registered under a closed code |
| Contractor misses deadlines | Responsibility is blurred inside one contract | The contractor's liability to you is written into the construction contract. The coordinator must control deadlines under its own contract. The step-by-step response to delays is in a separate article |
| Nominee schemes | Land is often held “in the shadows” by a local nominee of the company | Landowner and lessee are named in the deed, with no nominees. This matters after Perda No. 4/2026 and Coretax |
| Build quality | You inspect what has already been built | Specification and materials are fixed in the contract before work starts. Handover follows a checklist |
What we deliberately do not do: we do not sell a villa as a product, do not hold your land in our company, do not take the construction budget into our account and do not promise yields in the contract. The coordinator's obligations cover the plot, the checks, the design, deadlines and quality. Anything to do with rental income is calculated separately, on market data.
What we kept from three years of building
A change of role is not a change of team. The contractors we built previous projects with, the architects, the specification requirements, the stage-control and handover procedures all moved into the new structure. The difference is that these requirements are now written into the construction contract between you and the contractor, and our job is to make sure they are met. How stage control works is in the article on building a villa in Bali, and what to check on handover day is in the handover checklist.
Five questions for any seller in Bali
We are ready to hear these questions from you. Ask them of everyone whose property you are considering.
- Whose name will the land be in? If it is the seller's company, ask how you obtain the right to it and what happens if its licence is revoked.
- Who is the party to the construction contract? If you do not sign the contract with the builder, you have no direct claim against whoever builds.
- Whose account does the construction budget go to? And how is each tranche documented.
- Which KBLI code does the company operate under, and when was it registered? A new PT PMA under code 68111 cannot be registered in Bali since May 2026. If a seller says otherwise, ask to see the NIB.
- What exactly does the intermediary guarantee, and with what? Look for specific obligations in the contract, not percentages in a deck. How to vet a developer step by step is in the 6-step checklist.
Bottom line: in 2026 a foreign-owned company in Bali cannot be a developer, and we stopped being one. DOMA's new model consists of three documents instead of one: a coordinator agreement with us, a land lease with the landowner in your name, and a construction contract with the general contractor. The land is in your name, the construction budget goes to the builder, and our account receives the coordination fee and documented earmarked payments. It does not remove construction or market risk, but it moves the asset to where it belongs: the owner. If you want the details, we will walk you through them and answer every question about your scenario.
This material is for information only and is not legal advice. The structure of a deal and the wording of contracts depend on the specific plot, landowner and contractor. Have any document reviewed by an independent lawyer before signing.
Sources: our breakdown of the OSS restriction on new PT PMAs under 18 KBLI codes (in force since the third week of May 2026, announced by the governor on 22 and 23 July 2026), DOMA agreements in their 2026 edition: coordinator services agreement, Leasehold Agreement, construction contract.
FAQ
What exactly changed in the law?
Since the third week of May 2026 the OSS licensing system in Bali no longer accepts applications from new foreign-owned companies (PT PMA) under 18 low- and medium-low-risk KBLI codes. The list includes 68111 “real estate, own or leased”, the very activity foreign developers operated under. The governor announced the measure publicly on 22 and 23 July 2026. It is agreed with the investment ministry.
Was DOMA a developer?
Yes, for three years. We found land, designed and built villas and sold them as a finished product. In 2026 the rules changed and we rebuilt the model: same team, same contractors and quality requirements, but in the role of a coordinator under contract. That is what this article is about.
Who are the parties to the contracts for my villa?
Three documents. You sign the coordinator services agreement with DOMA. You sign the Leasehold Agreement with the landowner, and it carries the cadastral number, area, address and lease term. You sign the construction contract with the general contractor, and it carries the specification, plans, materials and deadlines. DOMA is not a party to the second and third.
Where does the money go?
The land payment is made in your name as the lessee. The construction budget goes directly to the contractor in stages under its contract. DOMA's account receives the coordination fee and earmarked payments made on your instruction (for land, the notary and other costs), each backed by a document.
What is the coordinator responsible for?
Under the agreement DOMA undertakes to find the plot, run due diligence, select the architects, coordinate construction so the property is completed on time and to the agreed quality, and hand it over into management. These are service obligations written into the contract, not yield promises.
Is this safer than buying “through one company”?
It is the most transparent structure for a foreigner that we know of today. The asset (the land lease) and the building contract are in the buyer's name, not an intermediary's, and nothing depends on registering a new PT PMA under a closed code. Any scheme should still be reviewed by an independent lawyer. The article gives a list of questions for that review.