The investment list reserves Vila 55193 to cooperatives. That code ceased to exist on 18 December 2025

Every agency deck in Bali ends on the same slide. You cannot own the land, so you own a company; the company buys the building, holds the licence, lets the villa by the night. That company is a PT PMA, and the last clause is the one nobody checks: checking it means opening two annexes the ministry publishes as page images.

The claim is not confirmed. The document that decides which fields a foreign investor may enter reserves every accommodation code it names to cooperatives and small enterprises, and has since 2021. What we cannot do is call it refuted: the annex in its current wording is not published.

Where does the story about 18 closed activities come from?

Not from the ministry. The account circulating since mid-year is that 18 business activities were closed to new foreign investment from the third week of May 2026, announced on 23 July 2026. We could trace none of it to an instrument, and we did not open the reporting that carries it: our search budget was spent before discovery began. This is an absence in the issuer’s catalogue, not a proven absence everywhere.Unverified

The account also names what was closed: small star hotels under 6,000 m2, melati hotels, real estate held or leased on own account, management consulting. None is in the annex that caps foreign ownership.Unverified Treat it as unsourced until somebody produces the instrument. The real restriction on accommodation is older and broader.

What do the annexes actually say?

Perpres 10/2021 opens in the investor’s favour: Pasal 2(1) declares all business fields open except those closed and those reserved to the central government. Pasal 3 then sorts the open fields into four classes and leaves only the fourth, the residue, to every investor.^{Source: 1}Kementerian Investasi dan Hilirisasi/BKPM, Last reviewed 14/10/2026Estimate Accommodation is not in the residue.

Lampiran II, item 51, is headed Jasa Penginapan and lists five codes: Hotel Bintang Satu 55110, Hotel Melati 55120, Pondok Wisata 55130, Guest House 55199 and Vila 55193. Each carries a tick in the column DIALOKASIKAN UNTUK KOPERASI DAN UMKM — allocated to cooperatives and to micro, small and medium enterprises. The next column, KEMITRAAN, partnership, is empty on all five rows.^{Source: 1}Kementerian Investasi dan Hilirisasi/BKPM, Last reviewed 14/10/2026Estimate The regulation offers two routes into such a field, allocation and partnership with a large enterprise; the annex ticks only the first.

The restriction is not a cap, then, but an allocation — one annex away from where everyone looks.

The other half of the mechanism is in the body. Pasal 7(1) admits a foreign investor only at Large Enterprise scale, with an investment value above Rp 10.000.000.000,00 excluding land and buildings.^{Source: 1}Kementerian Investasi dan Hilirisasi/BKPM, Last reviewed 14/10/2026Estimate That is about USD 558,000 at this publication’s standing rate, IDR 17,917 per USD for 05.10.2026.^{Source: 8}Bank Indonesia, Last reviewed 14/10/2026Estimate Pasal 5(2)(c) gives, as a criterion for allocating a field to cooperatives, that the activity’s business capital does not exceed the same figure.^{Source: 1}Kementerian Investasi dan Hilirisasi/BKPM, Last reviewed 14/10/2026Estimate One article admits a foreigner only above that line; the other sends a field to the cooperatives because it sits below.

Why do the list and the licensing system speak different languages?

Because the vocabulary the list is written in was abolished while the list stood still. Peraturan BPS 7/2025 revoked the 2020 edition of Indonesia’s industrial classification at Pasal 6 and gave every user six months to adjust. In the signed file the promulgation date and the gazette number are unfilled placeholder glyphs; the 18 December 2025 date comes from the publisher’s record page.^{Source: 3}Badan Pusat Statistik, Last reviewed 14/10/2026Estimate

The activities did not disappear. The numbers did.

The fourth column is ours, matched on activity names, except the last row. There the licensing system publishes its own conversion record: KBLI 55193 becomes 55203, one to one, under a disclaimer that this is a reference and not a legal decision.^{Source: 6}Kementerian Investasi dan Hilirisasi/BKPM, Last reviewed 13/10/2026Confidence: Verified

The definitions moved with the numbers: 55203 is short-stay accommodation in private houses let to tourists and managed by the owner himself; 55201, the new homestay code, is a dwelling occupied by its owner and partly let, the guest sharing the owner’s daily life.^{Source: 3}Badan Pusat Statistik, Last reviewed 14/10/2026Estimate That second definition is pondok wisata, renamed — the category our reading of Article 1559 and the pondok wisata licence turns on.

The licensing system moved on 15 June 2026: OSS states that it and the systems of ministries and agencies have applied KBLI 2025 since that date.^{Source: 5}Kementerian Investasi dan Hilirisasi/BKPM, Last reviewed 13/10/2026Confidence: Verified So an applicant works in a vocabulary the investment list does not contain, and the bridging instrument is missing. OSS points the reader to a joint circular of three ministers and agency heads, offered for download at the words di sini — which carry no hyperlink and no file address anywhere in the page. The circular is in neither issuing body’s catalogue.^{Source: 5}Kementerian Investasi dan Hilirisasi/BKPM, Last reviewed 13/10/2026Estimate

What is actually unpublished here?

The decisive annex. Perpres 49/2021 amends Lampiran I, II and III at Pasal I points 3, 4 and 5, each time by reference to a Lampiran it declares an inseparable part of itself. The file the ministry publishes is six pages and ends at the promulgation page; that Lampiran is not in it. The strings akomodasi, hotel, vila and penginapan occur zero times in the file, against controls Lampiran and alkohol at eight and seven.^{Source: 2}Kementerian Investasi dan Hilirisasi/BKPM, Last reviewed 14/10/2026Estimate

The text of item 51 above is therefore the original 2021 wording. We cannot prove it is the current wording — and neither can a notary or an agency.

Nor can anyone read either annex as text: a full-document extraction finds none of 55110, 55193, Pariwisata or Vila, while the control string 55 is found three times in the body.^{Source: 1}Kementerian Investasi dan Hilirisasi/BKPM, Last reviewed 14/10/2026Estimate The annex pages carry a corrupt font encoding, so both were read as page images, with no OCR available. Two of us read item 51 and all six pages of Lampiran III separately and agree on every cell. The body’s own text layer is an optical reading that turns e into c, so Pasal 7(1)’s threshold is trusted because sepuluh miliar rupiah stands beside the digits.

One more document is in force and unreadable. Peraturan BPS 6/2026 amends the regulation carrying KBLI 2025: the statistics agency records it as in force and serves its PDF as an empty file of zero bytes. Its abstract names other codes, but an abstract is the publisher’s description, not the instrument.^{Source: 4}Badan Pusat Statistik, Last reviewed 14/10/2026Estimate So we cannot say division 55 is untouched, only that nobody outside the agency can check.

The case against this reading

Three arguments cut against us, and the first is strong.

Practice may read through the renumbering. Indonesian administration may treat 55193 in Perpres 10/2021 as continuing to mean the activity now numbered 55203, and the OSS conversion record exists to make that reading work. The regulation leans that way itself. Pasal 5(5) provides that where a KBLI code covers more than one business field, the allocation rule in Lampiran II applies only to the field named in the Bidang Usaha column.^{Source: 1}Kementerian Investasi dan Hilirisasi/BKPM, Last reviewed 14/10/2026Estimate The rule is anchored to the named field as much as to the number, and Jasa Penginapan did not move. On that view only our narrow claim survives: the list is keyed to a revoked classification with no amended list published, which is not the same as a lapsed reservation.

The interlock between the two articles is ours, not the regulation’s. Pasal 7(1) sets a floor under foreign investment; Pasal 5(2)(c) uses the same figure as a ceiling criterion for putting a field on the cooperatives’ list. No article says the two together exclude a foreign-owned company from an allocated field. The counter-reading: those criteria govern how a field gets onto the list, not who may enter it afterwards.

“The codes no longer exist” is an argument about drafting. A classification is a statistical instrument: Peraturan BPS 7/2025 says so at Pasal 4, which sends the use of KBLI outside statistics to other legislation. It changes the code, not the investment rule, and no court is bound to read a renumbering as a repeal.

None of the three touches grandfathering. There is a real protection for existing holders: Pasal 6(4)(a) disapplies foreign-ownership limits to investment approved before promulgation as recorded in the business licence, and Perpres 49/2021 Pasal II(1) does the same for what it amends. Both are keyed to 2021, and neither mentions a company re-coded in 2026.^{Source: 1}Kementerian Investasi dan Hilirisasi/BKPM, Last reviewed 14/10/2026Estimate What happens to an existing registration on migration is governed by the unpublished circular.

The honest position is narrow. On the documents the state publishes, a foreign-owned company has no accommodation code to point to: the five the list names are reserved and abolished, the amending annex is missing, and the transition circular is in neither issuer’s catalogue. That is not advice to anyone. It is the state of the record on 14.10.2026, and we will publish a correction the day somebody sends us the amended Lampiran.