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. The legal alternatives are a leasehold in your own name, Hak Pakai for residents and 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 and why a villa on farmland is now a criminal matter
• Seven investor mistakes and their antidotes

Where the term comes up

• Bali, Thailand or Vietnam? Where a Foreigner Should Buy a Villa in 2026
• Bali or the Gold Coast, why Australian capital is moving into Bali villas (2026)
• How to vet a Bali developer, a 6-step checklist before you pay a deposit
• Leasehold or Hak Pakai? What a KITAS Holder Should Choose in 2026
• What Bali's Construction Moratorium Actually Restricts in 2026
• Can a Foreigner Buy a Villa in Bali? 15 Key Questions

Related terms

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