增值方法论
Permit Calendar: Bali and Lombok, Step by Step
The permit calendar for a villa in Bali or Lombok runs through three statutory gates: KKPR for land suitability, PBG for the building permit, SLF for the right to use the finished building. Each gate has a ceiling in working days, and each ceiling binds the office, not the file. Gili Air sits under a different regency from Uluwatu.
插图要点
- - The PBG technical consultation is capped at 5 examination rounds within 28 working days (PP 16/2021 Article 253, as presented by the Ministry of Public Works, statutory ceiling, not a measured duration).
- - The SLF and the ownership document are issued within 3 working days of the upload of the statement of functional fitness (PP 16/2021 Article 276, Ministry of Public Works and Hukumonline, 2021).
- - Konfirmasi KKPR is automatic and read as 1 day (AMAR Law Firm); Persetujuan KKPR is reported at 5 verification plus 20 assessment working days, 25 in total, but the 20 days are read two ways (Prolegal, industry estimate).
- - The clock stops on PNBP payment, on revision cycles (3 days per review of a corrected file, day type not stated) and on the applicant's own completion of documents, which the Ministry's chart shows with no duration (Prolegal; Kementerian PUPR deck).
- - The SLF must be extended every 20 years for single and row houses and every 5 years for other buildings, so it is a recurring item in the calendar (Hukumonline, reading of PP 16/2021 Article 297).
- - Gili Air sits in Desa Gili Indah, Kecamatan Pemenang, North Lombok, Nusa Tenggara Barat, so its counter is not Bali's; a regional outlet reported on 8 September 2026 that a single district for the three Gilis was being processed (Jadesta; Kicknews, 8 September 2026).
- - Six Bali regencies agreed, as announced on 28 July 2025, to stop encouraging new hotels and restaurants from 2026, with Badung and Gianyar excluded, and the governor stated a halt to productive-land conversion on 15 September 2025 (The Bali Sun, July 2025; Bali Discovery, October 2025; press-reported, no numbered instrument located as of 2 October 2026).
- - Every day count here is a ceiling read from secondary sources, the gazetted texts were not opened, and no elapsed time is given for any project (Victaura Research, 2 October 2026).
本页内容 (10)
What is the permit calendar for a villa in Bali or Lombok?
The permit calendar for a villa in Bali or Lombok is three statutory gates in sequence, and each gate carries a ceiling in working days, not a promise. Land suitability comes first, under the spatial-conformity finding known as KKPR. The building permit, the Persetujuan Bangunan Gedung (PBG), comes second. The certificate of functional fitness, the Sertifikat Laik Fungsi (SLF), comes last. KKPR is filed through OSS, the national licensing platform. PBG and SLF are processed in SIMBG, the national building-management system.
The PBG is the permit that replaced the IMB. PBG is the approval given to an owner to build, alter, extend, reduce or maintain a building in line with the technical standard. Government Regulation 16 of 2021 (PP 16/2021) created it. The Ministry of Public Works describes the change as a move from administrative requirements, such as land-right status and the old building permit, to technical standards for planning, construction, use and demolition.
The SLF is the certificate that lets a finished building be used. SLF is issued by the regional government to state that a building is fit for its function before it is occupied. It is issued together with the ownership document for the building, the SBKBG. The owner must hold it before use.
This article reads the ceilings in the law, and it says so before it says anything else. The PBG and SLF day limits come from the Ministry of Public Works' own explanatory deck, which cites PP 16/2021 article by article. The KKPR limits come from PP 28/2025 as read by Indonesian practitioners. The gazetted texts could not be opened for this piece. Ceilings are caps on how long an office may take. They are not elapsed times, and no elapsed time is given here. The companion article on the day-by-day calendar is the other half of this pair.
What is KKPR, and what does it clear before a drawing is filed?
KKPR is the finding that a planned activity fits the spatial plan for a given plot. The acronym stands for Kesesuaian Kegiatan Pemanfaatan Ruang. PP 28/2025 on risk-based business licensing, listed in the Ministry of Manpower legal register (JDIH) as enacted and promulgated on 5 June 2025, makes it a basic requirement. The same regulation lists the environmental approval, the PBG and the SLF beside it. For business activities, KKPR is processed through OSS.
The regulation splits KKPR into two instruments, and the split decides the clock. Konfirmasi KKPR is issued automatically by OSS where the location conforms. AMAR Law Firm reads the text as a ceiling of one day from the moment the requirements are met, and Prolegal cites Article 15 of PP 28/2025 for automatic issuance by OSS where the location is covered by an integrated detailed spatial plan (RDTR). Persetujuan KKPR is the approval that needs assessment. It is where the calendar starts to matter.
Persetujuan KKPR is a chain of small clocks. On Prolegal's reading, OSS issues a non-tax state revenue (PNBP) invoice once the polygon and technical plan are registered. The applicant has 7 days to pay, with one extension of 7 days. After payment, the regional office verifies completeness and accuracy within 5 working days. A technical team then validates the file, holds cross-sector meetings and may inspect the site, within 20 working days. Each review of a corrected file adds 3 days, and the applicant gets 5 days to revise; Prolegal does not say whether these are working days.
The 20 days are read two ways, and the difference is material. AMAR quotes the text as the assessment beginning no later than 20 working days after verification. A second Prolegal article states the service level for regular Persetujuan KKPR at a maximum of 25 working days, which is the 5 plus the 20. Which reading is right is a question for the gazetted article, which this piece did not open. Until then, 25 working days is a practitioner reading, graded as an industry estimate.
What changes the KKPR ceiling for coastal, forest or special-condition plots?
The headline KKPR ceiling is for an ordinary plot, and the same commentary lists longer ceilings for other categories of land. Prolegal reports that where the location needs marine-space approval, the ceiling is 31 working days without a technical recommendation and 46 working days with one. For forest areas it reports up to 141 working days. These are ceilings for categories of land. They are not statements about any particular plot, and none of them is a measured time.
Coastal and small-island plots are where the marine category becomes a question. Bali's southern cliffs and the Gili islands are both coastal. Whether a given plot touches marine space is a survey and a map question. The regulation does not answer it for the principal. It should be treated as an open item until a surveyor's overlay says otherwise.
PP 28/2025 also carves out a faster lane for conditions it names. Under Article 27, as cited by Prolegal, Persetujuan KKPR for certain conditions can be issued without the document-assessment stage. Prolegal states the service level for that lane at a maximum of 5 working days. Which plots qualify is defined in the regulation. This article did not test any plot against those conditions, and it does not suggest that any plot qualifies.
Every one of these ceilings sits upstream of the PBG. A KKPR that takes the maximum, or a revision loop that restarts the assessment, can move the date on which the PBG file is registered, if the regency counter requires the KKPR first. The sources read do not settle that practice. What they do settle is that the PBG ceiling starts only when the file is registered in SIMBG. The allocator should read the calendar as two clocks in series, with an untimed hand-off between them.
What does PBG require under PP 16/2021, and what does SIMBG do?
PBG must be in hand before construction starts, and it is applied for in SIMBG. The technical plan documents are submitted to the regional government, or to the central government for special-function buildings, before the construction is carried out (PP 16/2021, Article 253, as summarised by the Ministry). The process runs on SIMBG, the web-based electronic system defined in Article 1 and mandated in Article 326. The applicant registers there, and the scheduling of the consultation is returned there.
Consultation is the technical review, and it is free of charge. The Ministry's deck states that planning consultation is run without a fee. The review is done by the Technical Assessment Team (Tim Penilai Teknis) for houses and by the Expert Profession Team (Tim Profesi Ahli) for other buildings. It proceeds in stages, architecture first, then structure and mechanical-electrical-plumbing (Article 255). The result goes into minutes with a recommendation, either to issue a statement of compliance with the technical standard or to re-register the PBG.
The fee comes after consultation, and it is regional. The statement of technical compliance is used to obtain the PBG, together with a technical calculation for the retribution (Article 258). The retribution value is set from an integrated index based on building function and classification, and from a unit price that the regional government sets (Article 261). The unit price is therefore a local number. This article did not read the Badung or North Lombok schedules, and it quotes no retribution amount.
| Step | Body and system | Statutory ceiling (working days unless stated) | What stops the clock |
|---|---|---|---|
| 1. Konfirmasi KKPR (land suitability, where the location conforms) | OSS, automatic issuance (PP 28/2025 Art. 15, per Prolegal) | 1 day from the point requirements are met (AMAR reading) | A non-conforming location sends the file to the approval route |
| 2. Persetujuan KKPR, invoice and payment | OSS, PNBP invoice | 7 days to pay, one extension of 7 (day type not stated; Prolegal reading) | The clock for verification starts only after payment |
| 3. Persetujuan KKPR, verification | Regional office through OSS | 5 after payment | Return of the file for correction |
| 4. Persetujuan KKPR, assessment | Technical team through OSS | 20 (read two ways; 25 in total with verification) | Revision cycles, 3 days per review of a corrected file; 5 days for the applicant to revise (day type not stated; Prolegal reading) |
| 5. PBG, completeness check | Technical office secretariat, SIMBG (ministry chart) | 1 | Incomplete file returned; the applicant's time to complete has no stated duration |
| 6. PBG, technical consultation | Technical Assessment Team or Expert Profession Team, SIMBG (PP 16/2021 Art. 253) | 28 in total, at most 5 rounds | Return of a non-conforming file to the applicant between rounds |
| 7. PBG, retribution and issuance | Technical office and licensing office, SIMBG (Arts. 258, 261) | 2 in one ministry chart, 1 in another | Applicant's payment time is excluded |
| 8. SLF, new building | Building inspector during construction; supervision provider's statement (Art. 272) | No ceiling stated; runs with the works | Works not conforming to the PBG are returned for correction |
| 9. SLF, issuance with SBKBG | Technical office, SIMBG (PP 16/2021 Art. 276) | 3 from upload of the statement of functional fitness | The clock starts only on upload |
| 10. SLF, existing building | Technical office, SIMBG (ministry chart, Art. 282) | 1 + 26 + 1 (completeness, verification, issuance) | Non-conformity returns the file with repair recommendations |
How is the 28-working-day PBG consultation ceiling built?
The ceiling is 28 working days for up to five examination rounds. PP 16/2021, Article 253, as presented by the Ministry of Public Works, says the technical-standard examination is done at most five times within at most 28 working days. That is the law's cap on the consultation stage. It is a cap on the reviewing office. It does not count the time an applicant spends redrawing between rounds.
The Ministry's flowcharts break the cap into smaller ceilings. In one chart the secretariat checks completeness within 1 working day. The technical team then checks the architectural, structural and mechanical-electrical plans in 3 to 25 working days. The secretariat computes the retribution in 1 working day, and the head of the technical office signs the statement of compliance in 1 working day. Issuance of the PBG itself is shown as a stage of at most 2 working days, excluding the applicant's payment time.
The two charts do not agree to the day, and that is disclosed rather than smoothed. A second chart in the same deck shows 1 working day for completeness, up to 27 for consultation and 1 for issuance. Its consultation box reads 3 to 26 days. The Article 253 figure of 28 working days is the one with the legal citation, so the table above uses it and shows the chart splits only as a reading.
What stops the office's clock is the applicant. The charts mark the applicant's completion of the technical-standard documents as having no duration. A non-conforming file is returned to the applicant, and the retribution payment time is excluded from the issuance stage. Each of those is a place where elapsed time can grow while the ceiling stays unchanged. A file that passes all its rounds inside 28 working days of review can still sit in the applicant's hands for much longer.
A statutory ceiling binds the office, not the file. The principal's calendar starts where the ceiling stops counting.
Victaura Research
What does the SLF clock measure, and when does it start?
The SLF ceiling is 3 working days, and it starts only when the owner's declaration is uploaded. PP 16/2021, Article 276, as cited by the Ministry and by Hukumonline, says the SLF and the ownership document (SBKBG) are issued together through SIMBG within at most 3 working days from the upload of the statement of functional fitness. The clock covers the office's last step. It says nothing about the building period that comes before the upload.
For a new building, the SLF rests on inspection during construction. The Ministry's deck says the SLF for a new building is based on inspections by a building inspector while construction runs. The construction supervision or management provider issues the statement of fitness from a checklist built on supervision reports, inspections and commissioning tests (Article 272). The technical office then follows up with the SLF and the ownership document (Article 274). No day limit is stated for the inspection phase, because it runs with the works.
For an existing building, the Ministry's chart is 1, 26 and 1. The functional-fitness inspection is done by a certified technical assessor, either in-house or an outside provider (Article 276). The chart for existing buildings shows at most 1 working day for completeness, 26 for verification of conformity and correctness, and 1 for issuance. The check covers owner identity, building condition, conformity with the city-plan statement (KRK), the PBG documents and maintenance records (Article 282).
The SLF is not permanent. Per Hukumonline's reading of Article 297, it must be extended every 20 years for single and row houses and every 5 years for other buildings. The extension is preceded by a functional-fitness inspection. For an allocator, that makes the SLF a recurring item. Which category a rental villa falls into is a classification question this article did not resolve.
Which office handles a permit on Gili Air, and is it the Bali office?
No, Gili Air is not under Bali. Gili Air is one of the three Gili islands, which form Desa Gili Indah in Kecamatan Pemenang, Kabupaten Lombok Utara (North Lombok), in the province of Nusa Tenggara Barat, per the national tourism-village register Jadesta. Bali is a different province. The PBG is applied for to the regional government under PP 16/2021, so on Gili Air the counter is North Lombok's, and in Uluwatu it is Badung's.
The national ceilings are the same, and the local layer is not. PP 16/2021 and PP 28/2025 are national regulations, so the day limits in the table apply in both provinces. What differs by regency is the retribution unit price, the capacity of the technical team and the local spatial plan the KKPR is tested against. None of those was read for this article. The allocator should not assume that a Bali calendar transfers to Lombok, or the reverse.
Bali's provincial moratorium does not reach Lombok by its terms. Every report read on the moratorium describes a Bali provincial policy and names Bali regencies. None mentions Lombok or the Gili islands. That is a statement about the sources read, as of 2 October 2026. It is not a statement that North Lombok has no restrictions of its own, and this article did not search North Lombok's regulations.
The licensing counter on the Gilis may be about to change. Kicknews, a regional outlet, reported on 8 September 2026 that the North Lombok regency government is processing Gili Trawangan, Gili Meno and Gili Air as a single new district, with the regent saying the regulation process is underway. The reported aims include more focused management of services, environment and business licensing. As of that report the islands remained within Pemenang. A new district would not change the national ceilings. It could change who sits at the counter.
Gili Air is not a Bali permit. It is a North Lombok permit, and a calendar that assumes otherwise is the first error to remove.
Victaura Research
Does Bali's moratorium change the permit calendar in Badung, where Uluwatu sits?
The moratorium was stated in three different shapes during 2025. On 17 January 2025 Skift reported that Governor Koster had dropped the idea of a hotel-building ban, preferring stricter control. On 28 July 2025, Governor Koster announced that six regencies had agreed to stop encouraging hotel and restaurant development from 2026, according to The Bali Sun on 29 July 2025. On 15 September 2025, after floods that killed at least 18 people, Bali Discovery reported the governor saying there would be no further conversion of productive land for hotels and restaurants.
The six-regency arrangement does not name Badung. The Bali Sun reported the six as Tabanan, Jembrana, Buleleng, Bangli, Karangasem and Klungkung, with Badung and Gianyar excluded and Uluwatu among the destinations reported as exempt. It also reported a revenue-sharing arrangement for the six. Uluwatu is in Badung. On that reporting, the six-regency arrangement is not the instrument that touches an Uluwatu file. The Uluwatu project page is Victaura's public record of its site there, and this article says nothing about its permit status.
The September 2025 statement is the one that reaches Badung. Bali Discovery reported it as provincial, tied it to the Ayung river basin and to Denpasar, Badung, Gianyar and Tabanan, and aimed it at productive agricultural land and rainwater-absorption areas. A plot's land classification therefore matters more than its address. Agency commentary read for this piece says the policy operates through executive instruction to regents and mayors, and that no single numbered governor's regulation establishes it. That is directional, from a property-agency site. As of 2 October 2026 this article did not locate the instrument.
What changes in a touched district is the input to the clock, not its length. A policy that works by instruction acts at the front of the calendar, on whether a KKPR finding is favourable and whether a regency counter accepts a file. The ceilings as quoted by the Ministry carry no moratorium exception. A district can leave the ceilings intact and still decline to start the clock. The analysis of the moratorium as scarcity by regulation treats the supply side. This piece treats the calendar side, and its reading is directional.
A moratorium that works by instruction acts on whether the clock starts. The statute decides only how long it may run.
Victaura Research
What stops the clock under PP 16/2021 and PP 28/2025?
Ceilings bind the office, and the clock stops for specific reasons. In the KKPR chain, the verification clock does not start until the PNBP is paid. A revision cycle pauses it, and each review of a corrected file adds 3 days (day type not stated by Prolegal). In the PBG chain, a non-conforming file goes back to the applicant, and the retribution payment time is excluded from the issuance stage. In the SLF chain, the 3 working days start on the upload of the declaration. Each is a stop an allocator can ask about.
The sources read show no deemed approval for these steps. AMAR Law Firm's article on KKPR contains no language saying that silence by the office equals approval. The Ministry material does not state a deemed-approval rule for the PBG or the SLF either. Hukumonline reported on 27 January 2026 that PP 28/2025 provides for a phased application of the deemed-approval (fiktif positif) principle, without saying which steps it covers. The absence above is therefore a gap in the sources read, not proof that the regulations contain none. It is nonetheless the right default for underwriting. On these sources, a missed ceiling is a ground for escalation, not a permit.
Ceilings add up to something that looks like a forecast, so this article does not add them. The KKPR figure has two readings. The PBG figure differs by a day between two charts. Even if a sum were exact, it would count only the offices' time. It would leave out redrawing, payments, site conditions, contractors and the construction period between the PBG and the SLF.
Two systems mean a hand-off the law does not time. KKPR is issued in OSS, and the PBG and SLF run in SIMBG. The ceilings are set per step. Nothing read for this article sets a ceiling on the movement between them, or settles whether a regency counter will register a PBG file before the KKPR is issued. The PT PMA cost and calendar article is the companion on the corporate side of the calendar.
What does this permit calendar not establish about Bali and Lombok?
The gazetted texts were not opened, and that is the first weakness. The BPK and ministry portals returned access errors for PP 16/2021 and PP 28/2025 when this piece was researched. The PBG and SLF ceilings come from a Ministry of Public Works deck that cites the articles, and the KKPR ceilings come from Indonesian practitioner commentary. Article numbers are as the secondary sources give them.
PP 28/2025 may have restated or changed the building-permit steps, and this piece did not check. The Ministry deck was hosted on a regency portal in April 2022, by its upload path, so it predates PP 28/2025. One university briefing deck pairs PP 16/2021 with PP 28/2025 for PBG and SLF, and its contents could not be read. The ceilings here are therefore the PP 16/2021 ceilings as the Ministry explained them, and the principal should confirm them against the current text.
The moratorium reporting conflicts, and the instrument was not found. Reports differ on which districts are covered, from six regencies to a basin-based list that includes Badung. The agency commentary on the absence of a numbered regulation is directional. No Bali provincial regulation and no North Lombok regulation was read. As of 2 October 2026 the status is stated policy, with the legal instrument not located.
No elapsed time is published here. Every day count in this article is a ceiling. This article gives no elapsed time for any project, Victaura's or anyone else's. Retribution amounts, North Lombok local rules, the land classification of any plot and the marine-space question were not examined. An allocator should ask a counterparty for stamped acceptance and issue dates from comparable files, and should treat anything else as unverified.
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.
参考来源
- Republik Indonesia, Peraturan Pemerintah Nomor 16 Tahun 2021 tentang Peraturan Pelaksanaan Undang-Undang Nomor 28 Tahun 2002 tentang Bangunan Gedung (BPK register)
- Republik Indonesia, Peraturan Pemerintah Nomor 28 Tahun 2025 tentang Penyelenggaraan Perizinan Berusaha Berbasis Risiko (BPK register)
- Kementerian Pekerjaan Umum dan Perumahan Rakyat, Persetujuan Bangunan Gedung dan Sertifikat Laik Fungsi (slide deck, 2022 upload)
- Hukumonline, Catat! Ini 3 Dokumen Penting Terkait Bangunan Gedung 2021
- Hukumonline, PP 28/2025 Pertegas Kepastian Perizinan Usaha Berbasis Risiko lewat OSS-RBA 2026
- Hukumonline, Penting! Ini yang Perlu Diperhatikan dalam Proses Pengajuan KKPR Sesuai PP 28/2025 2025
- AMAR Law Firm & Public Interest Law Office, KKPR dalam Rezim Perizinan Berusaha Berbasis Risiko (undated)
- Prolegal, Ketentuan Baru Mengenai KKPR dalam PP 28/2025 (3 July 2025)
- Prolegal, Pengajuan PKKPR di OSS: Berapa Lama Izin Terbit? (3 June 2026)
- Skift, Bali Won't Go Ahead With Hotel Building Ban, 17 January 2025
- The Bali Sun, No New Hotels Or Tourist Developments To Be Built In Top Bali Resorts From 2026, July 2025
- Bali Discovery, Bali to Ban Building More Hotels, Villas, & Restaurants, 5 October 2025
- Bali Property Rules, Bali Building Moratorium 2026: Can Foreigners Still Build? (agency commentary, directional)
- Kicknews, Pemkab Lombok Utara Proses Tiga Gili Menjadi Kecamatan Baru, 8 September 2026
- Kementerian Pariwisata, Jadesta, Desa Wisata Gili Indah (Nusa Tenggara Barat)
- Kementerian Ketenagakerjaan, JDIH, Peraturan Pemerintah Nomor 28 Tahun 2025 (register entry, enacted and promulgated 5 June 2025)
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