Yes, in the regulation. A foreigner with immigration documents may hold a strata certificate over an apartment unit in Indonesia, in their own name, on a block that stands on Hak Pakai or HGB land, at a price of at least IDR 2 billion in Bali. That is the answer the guides give, and it is correct as far as it goes. The land ministry counted 131 properties registered to foreigners across the country between 2017 and 2023, houses and units together. The only running count of certificates handed to foreigners on record is from Batam, where Bisnis put it at “at least 36” in August 2023. In Bali, under the rules in force since 2021, we have found none. What Bali’s apartment projects sell to foreigners, by Colliers’ account in January 2026, is a lease of 25 to 35 years.
Two questions follow. What does the certificate give, if a project can deliver one? And what is on offer when it cannot?
In short
- Government Regulation 18 of 2021 opens strata title to foreigners with a visa, passport or stay permit; the land ministry’s 2021 procedure says how, and its Article 188 says what a foreigner’s certificate on HGB land leaves out: the share of the land.
- Bali’s apartment market is a leasehold market. Colliers, the developers’ own launch statements and the listings say so.
- The one-year window to sell after losing eligibility was in the 2015 regulation. The 2021 regulation that replaced it has no window.
What the regulation says
Three texts matter, and the guides cite one of them. Government Regulation 18 of 2021 lists who may hold ownership of a unit (hak milik atas satuan rumah susun, HMSRS) in Article 67: Indonesian citizens, Indonesian legal entities, foreigners “holding a permit under the applicable laws”, foreign legal entities with a representative office, and foreign states and international bodies. Article 69 narrows the foreigner to one “holding immigration documents”, which the explanatory note defines as a visa, a passport or a stay permit, and lets the unit pass to heirs, who need the same documents. Article 71 says where the block may stand: on Hak Pakai or HGB over state land, over state management land (HPL), or over privately owned land, and in a special economic zone, a free trade and port zone, an industrial zone “or another economic zone”. Article 72 adds four limits: a minimum price, a land area, a number of units, and residential use.
The second text fills in the numbers. The land ministry’s decree of September 2022 sets the minimum price by province: for an apartment in Bali, IDR 2 billion, about USD 112,000; for a landed house, IDR 5 billion. Hukumonline notes that no sanction is written anywhere for buying below the floor; the land office has nothing to register, and that is the whole penalty.
The question the law firms asked in 2021 was how a unit certificate could be issued to a foreigner at all when the block stands on HGB, a right a foreigner cannot hold. ABNR wrote in May 2021 that it was “difficult to see how”; a Bali notary writing in January 2026 still argues the rule contradicts the agrarian law. The third text answers them, and nobody quotes it. The ministry’s procedural regulation of 2021, in Articles 185 to 188, says a foreigner’s unit must be in a block classed as commercial housing, says that the conversion of HGB to Hak Pakai applies to landed houses only, and then, in Article 188, says what a foreigner’s certificate on HGB land contains: a joint share that “consists of the common parts and the common property, and does not include the common land”, with the obligations attached to that land still attaching to the foreigner. The certificate covers the walls and the lift. The ground stays HGB, in the developer’s or the association’s hands.
One phrase in Article 71 has no definition anywhere we can find: “another economic zone”. KSF Legal’s 2022 commentary reads it as covering urban and tourism areas. IHF Partners, writing on Mondaq in 2023, read the article as limiting foreign strata to the named zones. The explanatory note that would settle it sits in a PDF the government’s own site blocks from being read by machines, and no ministry statement on record addresses Bali by name.
What has been issued
The land ministry’s director-general gave the national figure on 16 May 2023: 131 properties registered to foreigners between 2017 and 2023, 52 before the 2021 reform and 79 after, with a peak of 55 in 2021 and a decline since. On 3 August 2023 the same official said the ministry was drafting a cap of 30 to 40% on foreign-held units per project; the developers’ association, the same day, said Batam alone had more than 100 foreigners on preliminary agreements that had not become certificates, and Bisnis reported that at least 36 property certificates had been handed to foreigners there. No cap has been enacted since, and no later count has been published.
Bali appears once in the record. A 2021 law-journal paper describes a condotel in Tuban, by the airport, where 14 units were held by foreigners on Hak Pakai land under the 2015 regulation, every owner a stay-permit holder; the authors note the owners received strata certificates and argue they should not have.
Then the market. Colliers told RRI in January 2026 that Bali’s apartment buyers are mostly foreigners, many of them Russian, that the projects cluster in Canggu, Ubud and Nusa Dua, and that “leasehold arrangements predominate”. The 80-unit project in Canggu that launched in January 2024 told Nusa Bali that about 80% of its buyers were foreigners who “will own the apartments for 30 years”. Two projects on the coast west of Canggu are listed on the Rumavi portal as a 30-year leasehold and a 27-year leasehold with a 10-year extension. C9 Hotelworks, which tracks the sector, records tenure as leasehold of 25 to 35 years across the 70-plus projects it follows.
Why the certificate stays on paper
Start with the land. A block on HGB gives a foreigner the Article 188 certificate, without a land share, and a developer who wants to offer it has to split the block into unit certificates under the condominium law, through a deed of separation and a unit schedule approved by the regency, and then find a land office willing to issue one to a foreign name. A lease of the unit skips every step of that.
Then the landlord above the landlord. Where the HGB sits on state management land, the HPL holder’s consent is needed, and the developers’ association said in May 2023 that HPL holders were halting transfers to foreign buyers. Nusa Dua is 350 hectares of HPL held by the state tourism company ITDC, which in April 2024 asked the ministry to convert its holding to plain HGB; we have not found what came of it.
The banks. The association’s same list of obstacles had banks demanding a stay permit before they would open an account or lend, and the central bank’s position since 2016 has been that no rule stops a bank lending to a foreigner. Permata Bank launched a lease-to-own mortgage for stay-permit holders in June 2025, for one Jakarta project. Nothing like it has been announced for Bali.
And the documents. The regulation says a passport and visa are enough; the association said in 2023 that counterparties asked for a stay permit anyway, and that the tax office had agreed to accept passport numbers in place of a tax number for non-residents.
What Bali sells instead
Three contracts, and the brochure word for all three is “ownership”. A lease of the unit is signed before a notary, with no certificate; the deed is the title, and what the buyer may do with the unit, let it, assign it, extend it, is whatever the deed says. A preliminary agreement (PPJB) with a developer is paid in stages before the unit exists, and holds the buyer against the developer until a final deed that may be a lease or, on the terms above, a certificate. A condotel unit comes with an irrevocable power of attorney to the hotel operator and a share of the pool, and the Constitutional Court ruled in October 2022 that the condominium law does not cover it: no owners’ association, no unit certificate. Which of the three a listing is should be the first line of it, as it is on our Bali apartments for sale. What each gives a buyer, and who runs the block in each case, is in villa or apartment in Bali; the lease clauses that carry the value are in can foreigners buy property in Bali.
If a certificate is on offer: six checks
A project that promises a strata certificate in a foreign name is making a claim about six documents. Ask for each.
- The parent certificate and its land right. Hak Pakai, HGB or HPL with HGB on top, and the expiry date. On HGB, your certificate will not include the land (Article 188); on HPL, the HPL holder’s consent to a foreign transfer, in writing.
- The split. A block becomes units through a deed of separation (akta pemisahan) and a unit schedule (pertelaan) approved by the regency, and only then can a unit have a certificate. Ask whether the split is done or planned.
- A certificate already in a foreign name. One is proof the local land office does it; none means you would be the test case.
- The zone. Which of the Article 71 categories the land office applied, since “another economic zone” is undefined.
- The price and the category. IDR 2 billion or more, in a block classed as commercial housing and the unit as residential.
- The owners’ association. Whether a PPPSRS exists and is active, because the ministry warned in May 2026 that the HGB under a block expires, and that in a block without an active association the units cannot be sold or mortgaged.
A project that answers none of the six is selling a lease under another name.
What a strata purchase costs
The purchase taxes are the same as for any registered title, and the stages that follow are in Bali property taxes for foreigners. Two lines are specific to a unit.
| Item | Rate | Who pays |
|---|---|---|
| Acquisition duty (BPHTB) | Up to 5% of the price or assessed value above the regency allowance, at least IDR 80 million | Buyer |
| Final income tax on transfer | 2.5% of the transfer value | Seller |
| VAT on a new unit from a developer | 12% on 11/12 of the price, an effective 11%; the full 12% and a 20% luxury sales tax from IDR 30 billion | Buyer, charged by the developer |
| Land deed official (PPAT) | Capped: 1% up to IDR 500 million, 0.75% to 1 billion, 0.5% to 2.5 billion, 0.25% above | As agreed |
| Land office registration | One per mille of the value plus IDR 50,000, plus IDR 50,000 for the certificate check | Buyer |
| Annual land and building tax (PBB-P2) on a unit | On the unit’s assessed value plus its share of the common land and parts; 0.1% to 0.2% in Denpasar, capped at 0.5% by the 2022 law | Unit holder |
A tax number is the small question that stops transactions. The land regulation does not ask a foreigner for one. The tax office, by the developers’ association’s account, accepts a passport number for a non-resident. Whether a given notary will register a purchase without an NPWP is a question for that notary.
Leaving, inheriting, losing eligibility
The old rule everyone remembers was in Article 10 of the 2015 regulation: a foreigner who stopped living in Indonesia had a year to transfer the property, after which the State auctioned it and paid them the proceeds. That regulation was revoked by the 2021 one, and the 2021 one does not repeat the year. What it says, in Article 61, is that a Hak Pakai lapses when its holder no longer qualifies as a holder, and in Article 62 that the land then reverts to the State, the HPL holder or the owner. For a unit on HGB land, where the foreigner never held the land share, the regulation says nothing specific. A buyer whose stay permit might end should read that silence as a risk with no procedure attached.
Inheritance is clearer: the unit passes to heirs, and a foreign heir needs immigration documents of their own. Resale is open; the procedural regulation lists sale, gift, exchange and auction as ways a foreigner may acquire, and sets no class of buyer a foreigner may not sell to. The life of the certificate is the life of the HGB under it, 30 years with a 20-year extension and a 30-year renewal under Article 37 of the 2021 regulation, and where the HGB sits on HPL the Jakarta cases show the HPL holder’s consent, and its price, deciding the renewal.
What we don’t know
Whether any Bali land office has issued a strata certificate to a foreigner under the 2021 rules; the ministry gives no provincial figures. What “another economic zone” means, because the explanatory note is unreadable to us and no ruling has tested it. Whether ITDC’s land in Nusa Dua is still HPL. Whether the 30 to 40% cap proposed in 2023 is dead or dormant. Each would change the advice. None has an answer in the public record as of October 2026.
Can foreigners buy an apartment in Bali: FAQ
Can a foreigner mortgage a strata unit in Bali?
The law allows it: a Hak Pakai over state land may carry a mortgage under the 2021 regulation and the mortgage law, and a unit certificate can be charged in the same way. The lenders are the problem. Bank Indonesia said in 2016 that nothing in its rules stopped banks lending to foreigners, and the first product appeared nine years later, Permata Bank’s lease-to-own scheme of June 2025 for stay-permit holders buying into one Jakarta development. A buyer in Bali in 2026 should plan on cash.
Is there a limit on how many units in a block foreigners may own?
Not in force. The 2021 procedural regulation limits a foreigner’s rusun to the commercial-housing category and sets no number of units; the 30 to 40% cap per project was announced as a draft in August 2023 and has not appeared since. A percentage cap quoted in a sales brochure has no regulation behind it.
Does buying an apartment get me a visa?
Only an expensive one. The Golden Visa and the Second Home visa both name an apartment of USD 1 million or more as the property route, by KPMG’s summary of the 2023 immigration regulation; the Second Home visa also takes a USD 130,000 bank deposit instead. As of May 2026, 1,274 Golden Visas had been issued nationally.
