Nominee arrangement

A nominee arrangement is when the Hak Milik certificate is in an Indonesian's name while a foreigner "really" paid and controls the land through side agreements: power of attorney, loan, pledge, letter of intent. Indonesia's Supreme Court (decision 3020 K/Pdt/2014) confirmed that transactions concealing foreign ownership of Hak Milik land are void, and under Art. 26(2) UUPA the money paid is not refundable.

Two things changed in 2026. Bali Perda No. 4/2026 introduces liability for the foreigner, the nominee and the intermediaries, up to confiscation. The Coretax tax system cross-matches payments, income and assets, so a mismatch between "who paid" and "whose name" surfaces automatically.

The everyday risks remain: the nominee's death, debts, divorce or a simple change of mind — and you have neither the land nor the money. Legal alternatives: a leasehold in your own name, Hak Pakai for residents, PT PMA with HGB where still available.

Read more in the blog

• The End of Grey Schemes in Bali: Nominee Ownership, Perda 4/2026 and Coretax
• Bali's Rice-Field Law No. 4/2026: why a villa on farmland is now a criminal matter
• Seven investor mistakes — and their antidotes

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Updated: 2026-09-20. Not a public offer. Regulations change — we cite enacted acts only and update the entry when they do.