Policy Risk: A 2025–2026 Rule-Change Calendar

How often do the rules change on Lake Como, in Bali, in Zanzibar and in Ras Al Khaimah?#

On Lake Como, in Bali and on the Gili Islands, in Zanzibar and in Ras Al Khaimah (RAK), the rules that govern a held property changed in eight dated steps between January 2025 and October 2026, in three of the four markets, and no dated step was located in Zanzibar. That count is Victaura Research's own, built from the table below. It counts the events located, not every circular issued. The principal should read it as a floor.

The useful product is a calendar, not a forecast. Unlike demand, a rule arrives by announcement. A rule arrives as a date, a decider and a transition clause, and each of the three can be read and priced. This note reads them market by market, then asks what the calendar implies for a valuation.

The sample is small and the four markets are unlike each other. An Italian national code, an Indonesian provincial regulation, a Zanzibar tax page and an emirate-level development law are not one kind of event. They sit side by side because a holder of property in several places meets all four kinds. Where this site has already told a rule, the note points to the earlier article, as with Bali's moratorium.

The window opens on 1 January 2025 and closes on 29 October 2026. The first date is when the Italian national code became enforceable for every short let. The second is the day the sources were last reopened. Every status below is dated to that day, and a rule published after it is outside the note.

The policy layer defined, and how its figures are graded#

*The policy layer is the set of public rules that decide what an owner may build, let, hold, sell or deduct, and for how long those permissions last.* It sits above title and below the market. Title says what is owned. The policy layer says what the owner may do with it, and how long the answer holds. It includes statutes, regional laws, provincial regulations, licensing portals and tax pages.

Every date and number in this note carries one of four grades. A measured figure is counted or recorded by the source, as with registry data, official statistics or audited results. An industry estimate is produced by a research firm or an industry body with a stated method. A broker-reported figure is published by an agency or a developer about its own market, useful but not independent. A directional figure is a signal whose direction is reliable but whose size is not.

The channel is written beside the grade, never in its place. A law firm summarising a statute, a newspaper reporting a governor and a regional website listing a code are channels. A rule known only from a newspaper is directional, press-reported. A date printed on an official page is measured, and the page is named. Where the text of an instrument was not opened, the note says so in the same line.

Intervals are the note's own arithmetic. A notice period is the gap between the stated announcement and the stated effective date. Where either date is missing, the cell says so and no interval is invented. The intervals are directional even when both dates are measured, because the date of an announcement is not always the date a market learned of the rule.

Lake Como: the Italian and EU rules that changed in 2025 and 2026#

On Lake Como two dated steps fall in the window, one national and one European. The first is the national identification code, the CIN, introduced for short and tourist lets by Article 13-ter of Decree-Law 145/2023, published in the Gazzetta Ufficiale n. 244 of 18 October 2023 and converted with amendments by Law 191 of 15 December 2023 (Normattiva). The Ministry of Tourism's notice of 22 October 2024 set one deadline for everyone to obtain the code, 1 January 2025 (ildiritto.it, 25 October 2024, directional, press-reported).

The CIN reached lets already in operation. The notice replaced the different deadlines that had applied to different groups of owners and fixed a single date for all. The sanction amounts are not stated here. The note on Lake Como short lets reads them from Article 13-ter, and the penalty provision was not reopened for this note.

Lombardy runs its own regional code beside the national one. The Region's page states that every facility governed by regional law 27/2015, apartments let for tourism under law 431/1998 included, must hold the regional identification code, the CIR. The code coincides with the one generated by the ROSS1000 tourist-flow system and is governed by resolution XII/169 of 19 April 2023. The page was inserted on 1 March 2026 and last updated on 13 October 2026 (Regione Lombardia, measured for the dates).

The European step has the longest runway in the calendar. Regulation (EU) 2024/1028 on data collection and sharing for short-term accommodation rental services was adopted on 11 April 2024 and must be implemented by 20 May 2026, about 25 months later (European Commission, Transition Pathways for Tourism, measured for the dates, interval by Victaura arithmetic). It covers platforms that facilitate distance contracts between guests and hosts and excludes hotels and similar accommodation. The page does not detail host duties, and the Official Journal text was not reopened.

For a Lake Como villa the point is the stack, not any single layer. Municipal, regional, national and EU rules each have their own decider and clock. The letting side moved twice in the window, and both moves added identification and reporting rather than a ban. That reading is directional.

Bali and the Gili Islands: six dated actions in about 19 months#

Bali produced the densest calendar of the four markets, with six dated actions between September 2024 and March 2026. Indonesia's coordinating minister told domestic media in September 2024 that a moratorium on hotels, villas and nightclubs could run up to ten years in Bali's busiest areas (Reuters, 9 September 2024). Governor Koster cancelled it in January 2025 (balipropertyrules.com, directional, specialist-site-reported). The earlier account on this site tells that sequence in full.

The 2025 steps came as announcements, and their timing followed events. On 29 July 2025 The Bali Sun reported that six regencies, Tabanan, Jembrana, Buleleng, Bangli, Karangasem and Klungkung, would stop encouraging new hotels and restaurants from 2026, with Badung and Gianyar outside the agreement. No numbered instrument was located (directional, press-reported). Then floods killed at least 18 people, a state of emergency was declared on 10 September 2025, and on 14 September the governor said no more permits would be issued for hotels, restaurants or other facilities on productive land (Antara, 15 September 2025; Adnkronos, 19 September 2025).

The statement took effect at once and the regulation lagged it. Antara quotes the governor saying that from 2025 no productive land can be converted into commercial facilities, that selective permits would let landowners build houses but not commercial properties, and that a bylaw was expected in 2025. Regional Regulation No. 4 of 2026 was signed on 24 February 2026. It freezes conversion permits until 87% of the remaining rice land is designated as protected, and it prohibits nominee land ownership (Balinews, directional, press-reported).

A licensing deadline then reached the existing stock. Accommodation in Bali marketed through online travel agents had to hold valid business licensing by 31 March 2026, and the source lists the business identification number, the NIB, as a typical requirement rather than a universal one (villa-management-bali.com, directional, specialist-site-reported; the page attributes the deadline to the national Ministry of Tourism and does not limit it to Bali). Beneath it, Indonesia's risk-based licensing regulation, PP 28/2025, promulgated on 5 June 2025, replaced PP 5/2021 and gave the government four months, to about 5 October 2025, to issue implementing rules and adjust the OSS licensing system (Meridian Hukum; Veritask, directional, legal-commentary-reported). The Gili Islands lie in West Nusa Tenggara, outside the Bali measures and inside the national licensing system.

Did Zanzibar change its land and tourism rules in 2025 or 2026?#

No change to Zanzibar's land or tenure statutes in 2025 or 2026 was located in this review, and that absence is not a finding. The House of Representatives website did not respond when reopened on 29 October 2026, so no statute text was reopened for this note. For that reason the note states no lease term, no ownership threshold and no comparison between a statute and a listing. The table cell reads Not graded, with the reason.

Two tourism and tax items can be dated. On 4 July 2024 the Ministry of Tourism and Heritage and the Zanzibar Commission for Tourism presented regulations on non-hotel tourist accommodation, with registration, inspection and a licence (The Citizen, 6 July 2024, directional, press-reported). The text of those regulations was not located. The earlier note on Zanzibar holiday lets sets out their reported terms, and it did not locate the text either.

The Zanzibar Revenue Authority's Hotel Levy page is marked as revised in 2025. It lists 15% of rental value for residential houses rented for tourism, online platforms included, and 12% of the chargeable value of services for hotels and guesthouses, on the basis of the Hotel Levy Act No. 1 of 1995, with a consolidated version labelled 2025 (ZRA, measured for the rates). The page gives no effective date. A revision whose effective date is not stated cannot be given a notice period.

The calendar for Zanzibar is therefore thin, and thin is not calm. A market with few located changes may be one that changes by notice, circular or practice rather than by statute, and those leave no dated trace in public sources. The allocator should ask the Zanzibar Revenue Authority in writing for the current Hotel Levy text and its effective date, have a lawyer admitted in Zanzibar confirm the current land statutes, and carry both questions as open until the answers are in hand.

Ras Al Khaimah: Law No. 10 of 2026 and the off-plan buyer#

In Ras Al Khaimah the 2026 change is a replacement of the development law, issued on 21 July 2026. Law No. 10 of 2026 replaces Law No. 12 of 2023 and applies to real estate development across the emirate, Economic Zones included. It takes effect 60 days after issuance, about 19 September 2026 by Victaura arithmetic (ADG Legal in Legal 500, 26 October 2026, directional, law-firm-reported; the gazetted text was not located).

The institutional change is the consolidation of oversight. Licensing, project registration, escrow oversight and enforcement sit in one department, which absorbs functions previously split between the Real Estate Project Development Committee and the Real Estate Regulatory Administration. Marketing agreements with accredited brokers and contracts between developers and sub-developers must now be registered, and the grounds for removing a developer from the register are wider (ADG Legal).

The escrow regime is kept but narrowed. The summary says the 2023 provisions allowing marketing expenditure and limited profit withdrawals are not repeated in the same form, that withdrawals focus on construction and completion costs, and that the trustee holds 5% of construction costs for one year after the completion certificate. Executive regulations are still expected, so the detail is incomplete. The note on escrow and the payment plan on Al Marjan Island sets out how escrow works in that market.

Article 20 reaches contracts already signed. On a purchaser default the developer notifies the department, which verifies the default and the completion percentage. The purchaser then has 30 days to comply before unilateral termination may be authorised. Deductions from the price are capped at 40% where the project is at least 60% complete, 25% below 60%, and 20% where construction has not started for reasons not attributable to the developer. The summary says Article 20 applies to all off-plan agreements, concluded before or after the law took effect, except projects with a completion certificate (ADG Legal).

Holiday homes show the opposite case, a regime that did not move. The emirate's tourism authority simplified its holiday-homes system in January 2023 (RAKTDA, press release), and no change in 2025 or 2026 was located. A calendar needs quiet rows as well as busy ones.

Notice periods across the calendar#

Stated notice runs from 60 days to about 25 months, and some rules state none. The shortest stated figure is the RAK law's 60 days between issuance and effect. The Italian CIN date was fixed 71 days ahead by the ministerial notice of 22 October 2024, although the obligation itself sat in a decree-law published on 18 October 2023 and converted by Law 191 of 15 December 2023, more than a year before it bit. The European regulation gave about 25 months. All intervals are Victaura arithmetic on the dates cited.

Bali's governor gave no stated lead time in September 2025. The statement of 14 September applied from 2025, four days after the emergency declaration of 10 September. In the six-regency agreement the lead was about five months, from the report of 29 July 2025 to the start of 2026. The Indonesian licensing regulation gave the government four months, to about 5 October 2025, to issue implementing rules and adjust the OSS system (directional, legal-commentary-reported).

Notice appears to track the trigger and the decider. Rules made through a legislative process, such as the EU regulation or the Italian decree-law converted by Parliament, gave months. A rule that followed a disaster, announced by an elected governor, gave none. That is a reading of a handful of data points, directional at best, and it is not a law of regulation.

Notice is also worth less than it looks. A 25-month runway helps the holder who reads the Official Journal and does not help one who learns of the rule from a platform. A 60-day window helps a developer with a project team and not an individual buyer on a payment plan. The allocator should ask who actually received the notice, not who was entitled to it.

Who decides, and what happens to a buyer already holding?#

The decider changes the odds of reversal. Four kinds appear in the calendar. Italy's CIN rests on a decree-law of the national government that Parliament converted. The EU regulation was adopted by the European Parliament and the Council. Bali's steps came from a governor, six regencies and a provincial regulation signed by the governor. RAK's change is an emirate-level law. Bali's own history, a moratorium proposed, cancelled and rebuilt in other forms within about a year, shows that a measure decided by one executive can reverse within months.

Transition clauses fall into three types, and the type matters more than the rate. A grandfathering clause protects what exists. A prospective clause applies only to new acts. A retroactive clause reaches contracts already signed. In the calendar, Bali's September 2025 statement was framed for new permits, the CIN reached lets already in operation, and RAK's Article 20 reaches off-plan agreements concluded before the law took effect.

The buyer already holding is protected least where the contract is still running. A completed asset with a permit in hand holds the strongest position in principle, but the sources opened for Bali do not say how permits issued earlier are treated, and the note does not assume it. Regional Regulation No. 4 of 2026 prohibits nominee land ownership, and the Balinews summary states no transition for existing nominee arrangements. The regulation text was not read. An off-plan buyer holds the most exposed position, because the contract is performed across the period in which the rule is rewritten.

The decider also sets the speed of repair. When a rule bites unevenly, the repair usually comes from the same office that wrote it. Bali's governor cancelled one measure in January 2025 and announced another in September. A ministry notice moved Italy's date once. A statutory regime such as the EU's moves on a legislative clock. The allocator prices the repair time of the decider, not only the rule.

How is rule-change risk priced in a valuation?#

Rule-change risk is priced as a set of scenarios on cash flows and on exit, not as one percentage added to the discount rate. A single premium hides what is exposed. A villa let by the night depends on a licence. A villa held for use depends on title and building rules. An off-plan unit depends on a contract that a development law governs. Each needs its own line.

The register has four fields per exposure. The first is frequency, the number of dated changes per year in that layer, read from a calendar like the one here. The second is notice, the shortest stated lead time seen. The third is the decider, with its record of reversing itself. The fourth is the transition type, grandfathered, prospective or retroactive. Four fields give a scenario, and a scenario can be tested.

Income that depends on a permission is carried at zero until the permission is documented. That is the working rule in this series, and the calendar supports it. Licensing and registration steps in Italy and Bali moved inside the window. A model that assumes a licence is permanent assumes the calendar away. The note on stage-of-completion pricing reads an unfinished unit at four prices, and the transition clause belongs in each of them.

Time, not a rate, absorbs the shortest notice. Where the stated notice is 60 days, no hold can be re-planned inside it. The response is structural. A reserve is sized to a period of lost income, a payment plan does not fall due all at once, and an exit does not depend on a single rule staying put. These are design choices, not forecasts.

No figure is offered here for the premium. The calendar has eight located steps in 22 months across three markets. That is too few to estimate a probability, and a number offered would be invented. The note supplies the inputs for the allocator's own scenario.

Where the calendar is weak, honestly disclosed#

Most of the Bali steps rest on press or specialist sites, not on the instrument. The six-regency agreement has no numbered instrument located. The September 2025 statement is a quotation. Regional Regulation No. 4 of 2026 is read through Balinews, not through the provincial legal gazette. The NIB deadline is read from a specialist site. All are graded directional for that reason.

The RAK law is read through one law-firm summary. The gazetted text of Law No. 10 of 2026 was not located, the effective date is the note's own arithmetic, and the executive regulations the summary expects were not seen. The figures for escrow retention and default deductions are the firm's, and they may differ from the text.

Two primary texts could not be reopened. The House of Representatives of Zanzibar site refused the connection on 29 October 2026, and the EUR-Lex page of the European regulation returned no text to the tool used. The regulation's dates come from the European Commission page. A search summary mentioned a Lombardy regional law numbered 7/2025. That law was not read and is not relied on.

Selection bias is built in. A calendar built from searches finds what is searchable, which favours press-covered events and English-language sources. Municipal ordinances, Italian regional circulars and Indonesian regency decrees are under-represented. The count of eight is a floor, and the comparison between markets reflects coverage as much as activity.

The note gives no legal or tax advice. Each rule is described as its source describes it. A lawyer admitted in the relevant jurisdiction must read the text before any decision rests on it. The Zanzibar statutes and the RAK executive regulations are open, and the CIN penalty amounts were not reread for this note.

What the allocator takes from the calendar#

The first conclusion is that rule change is frequent enough to model. Eight located steps in 22 months across three markets, five of them in Bali and Indonesia, are too few for a rate, and they do not support a model in which the rules stay fixed for a multi-year hold. The pattern is uneven. Bali's calendar is dense, Lake Como's is regular and set by bodies with legislative clocks, RAK's is a single large replacement, and Zanzibar's is thin in what can be located.

The second is that the questions are the same in every market. Who decides. How much notice. What happens to what is already held. A principal who asks them of every asset has a register that can be updated each time a row is added to the calendar.

The third is that quiet rows are information too. A market with no located change is not a safe market. It is one where the change, when it comes, may not leave a trail in public sources. Thin calendars deserve more reserve, not less.

Skin in the game disclosure. Victaura, through its parent Greystone B.V. (Netherlands), develops projects on Lake Como (Italy), in Nungwi, Zanzibar (Tanzania), on Gili Air and in Uluwatu, Bali (Indonesia), and holds an off-plan capital position on Al Marjan Island, Ras Al Khaimah (UAE). Readers should assume commentary may be influenced by, or benefit, these positions. This document is classified as marketing material under MiFID II Article 24(3). It is not investment advice.