← field notes regulation2026 jul 10

Can you still build in Bali? What the moratorium actually closed

Since September 2025 the question investors ask us has changed from where should I build to am I still allowed to. We followed the sequence from the first instruction to the two regional regulations of February 2026, and the national one that landed between them. Here is what actually closed, and what did not.

by François, founder · four projects between the drawing board and the site, in Bali

short answer

Yes, you can still build in Bali in 2026, but only on land the spatial plan already zones for it. What the moratorium closed is the conversion of productive farmland into commercial property. On rice fields that door is now criminal law under Bali's Perda 4/2026, not a gray area, and the same regulation prohibits nominee land ownership with sanctions that reach everyone in the chain. Zoning and permit discipline stopped being best practice and became the entire game.

What people are forwarding

"Bali banned construction." "No new villas until further notice." "Permits are frozen island-wide." The direction is right about the mood and wrong about the scope. Nothing in the moratorium stops a correctly zoned project from being permitted and built. What it stops, with force that did not exist a year ago, is the habit the last cycle was built on: buying a rice field cheap, converting it quietly, and calling the result an investment.

What actually happened, in order

On 10 and 11 September 2025, flash floods hit eight of Bali's nine regencies and killed at least seventeen people. Within days, after a joint meeting with the national Environment Minister, Governor Koster announced a moratorium on new permits for hotels, villas, restaurants and similar commercial facilities on productive land and water absorption areas, and instructed every regent and mayor accordingly. The stated legal footing was the province's 100-year development guidelines, in force since 2025. The one stated exemption: housing for residents on their own land, permitted selectively.

The verbal instruction then became a formal one. Instruksi Gubernur 5/2025 prohibits regents and mayors from issuing agricultural land conversion permits, naming protected food agriculture land (LP2B) and the recorded rice field inventory explicitly.

Then February 2026 turned policy into law twice in one month, and here a detail matters, because two different regulations carry the same number. Jakarta moved first: Perpres 4/2026, a national presidential regulation replacing the 2019 framework, orders official protected rice land maps (LSD) nationwide and attaches incentives for provinces that designate at least 87 percent of their recorded rice land as protected. Bali moved three weeks later, and went further: on 24 February, Governor Koster signed Perda Provinsi Bali 4/2026, which controls the conversion of productive land, rice fields, horticulture and plantations, and, in the same text, prohibits nominee land ownership outright. A second regional regulation signed the same day, Perda 3/2026, tightens what can be built inside beach setback zones.

What is now closed

Converting protected rice land into a villa or any commercial property is a criminal offense, not an administrative irregularity. Conversion permits on remaining rice land are frozen while the protected land maps are finalized. The sanctions ladder runs from written warnings through site closure, permit cancellation, demolition and restoration of the land, to administrative fines and prosecution. And it does not stop at the owner: intermediaries, facilitators and anyone providing the means for a foreigner to control land through a nominee are named in the regulation, and so are civil servants who assist. Two regencies, Tabanan and Gianyar, are designated surveillance priorities, along with the corridor of the Gilimanuk to Mengwi toll route, where land speculation is expected.

The numbers explain the severity. Bali's recorded rice land fell from 70,996 hectares in 2019 to 64,474 hectares by February 2026, a conversion pace of roughly 1,254 hectares a year. A meaningful share of it became exactly the kind of villa this regulation now criminalizes.

If a structure you hold, or a structure a seller is proposing, involves an Indonesian name holding land on a foreigner's behalf, that arrangement is now prohibited by regional law with liability for everyone who helped build it. We wrote about why the nominee route was already the wrong risk in PT PMA vs nominee. The update is that the downside stopped being theoretical.

What remains open

Land the spatial plan already zones for tourism or accommodation use. Nothing in the moratorium or the Perda withdraws that. The path is the one we publish on this site: confirm the zoning against the spatial plan, obtain KKPR then PBG before ground breaks, and the SLF at completion, before a single guest. Valid existing permits continue. Coastal setback rules got stricter, which matters for clifftop and beachfront ambitions.

The moratorium did not lower the ceiling on building in Bali. It removed the floor under building in the wrong place.

What changed in practice is scrutiny. A plot now has to answer harder questions, and the answers got easier for officials to verify against official maps. How zoning actually decides what a plot can carry, category by category, is in our zoning note.

What it does to values

Correctly zoned, correctly licensed land and finished assets just became scarcer relative to demand, because a supply channel the island quietly relied on is closed. Demand did not slow to match: 2025 was a record year for arrivals. Across more than 84,000 active listings the island still averages occupancy near 47 percent, and Harmonie, the asset whose numbers we publish, runs above 80 percent against that same market. How that gap is built has not changed. What changed is that the rules now push the whole market toward the disciplined end of it, which is the thesis of the operator's market, accelerated by law.

Built through all of it

While that sequence unfolded, our own site in Babakan kept pouring concrete: three villas and a shared lobby, in construction through the floods, the instruction and both regional regulations. Not luck. The zoning allowed the project, and the KKPR and PBG were in place before construction began. The SLF belongs to the completion stage, before the asset enters operation. That is the entire difference the new rules reward, and it will be visible month by month in the build diary we will document at every milestone.

Whether a specific plot sits on the right side of these lines is not a matter of opinion, and it is not something a listing description settles. It is the first thing a Go/No-Go verdict answers, with the documents on the table. That is what the first conversation is for. Talk to François.

Questions we get asked directly

Is there a total construction ban in Bali? No. The moratorium targets the conversion of productive agricultural land into commercial property. Correctly zoned land remains permittable through the normal sequence, KKPR and PBG before construction and SLF at completion, under closer scrutiny than before.

Can I still buy a rice field and convert it into a villa? If it sits on protected rice land, no, and anyone telling you otherwise is describing a criminal offense under Perda 4/2026. Land status must be verified against the official maps before any commitment.

Does the moratorium affect villas that are already built and licensed? Valid existing permits are not withdrawn. The pressure lands elsewhere: on unlicensed operation and on new conversion. What licensing enforcement looks like since the March deadline is its own subject.

What is Perda 4/2026 in one sentence? Bali's regional law of 24 February 2026 that criminalizes converting productive farmland into commercial property and prohibits nominee land ownership, with sanctions reaching owners, facilitators and officials. Not to be confused with Perpres 4/2026, the national rice land regulation issued the same month.

last reviewed: july 2026

Related: Bali land zoning explained · PT PMA vs nominee · Run the numbers on your own project

Sources: statements by Governor Wayan Koster, 13 to 15 September 2025, as reported by CNN Indonesia, Kompas and Metro TV News; Instruksi Gubernur Bali 5/2025 as documented by the provincial spatial planning authority (tarubali.baliprov.go.id, January and February 2026 publications); Perpres 4/2026 on rice land conversion control, replacing Perpres 59/2019 (JDIH ATR/BPN); Perda Provinsi Bali 4/2026 on the control of productive land conversion and the prohibition of nominee land ownership, signed 24 February 2026, and Perda Provinsi Bali 3/2026 on beach and beach setback protection, as reported by Kompas and provincial publications; BPN Bali rice land inventory data via tarubali.baliprov.go.id. Checked 9 July 2026. This note explains the regulatory position as we understand it and is not legal advice. Verify the status of any specific plot against the official spatial plan and protected land maps with a licensed Indonesian notary before relying on anything here.