How to invest in KEK Sanur means understanding how Indonesia lets foreign capital enter a Special Economic Zone, set up a PT PMA, secure OSS licenses, and obtain land rights over the zone’s HPL. This page breaks down how foreign investors actually enter KEK Sanur in practice — in numbered steps, with current thresholds, and with the regulatory caveats attached.
What is KEK Sanur and why does the entry process matter?
KEK Sanur (Kawasan Ekonomi Khusus Sanur) is a designated Health and Tourism Special Economic Zone in Sanur, Denpasar, Bali, created under Indonesian SEZ regulations and overseen by the National Council for Special Economic Zones (Dewan Nasional KEK) together with a local Administrator and a Business Entity for Zone Development and Management (Badan Usaha Pembangun dan Pengelola / BUPP).
Foreign investors do not buy “freehold” in KEK Sanur, and they do not operate under a separate offshore legal system. You enter Indonesia’s investment and licensing framework, then apply for KEK-specific facilities and land-use rights layered on top of that framework.
Key structural points, as at the latest available regulations (through early 2026):
– Legal entities inside KEK Sanur are Indonesian limited liability companies (Perseroan Terbatas / PT), including PT PMA (Penanaman Modal Asing – foreign direct investment companies).
– Land in the zone is held under HPL (Hak Pengelolaan Lahan – management right) by the BUPP; investors typically obtain HGB (Hak Guna Bangunan – building-use right) or a lease over that HPL.
– Licensing uses Indonesia’s Online Single Submission (OSS) risk-based system, via a Business Identification Number (Nomor Induk Berusaha / NIB) and sectoral permits.
– Fiscal incentives (tax, customs, and other facilities) are based on national KEK rules. Actual eligibility depends on your sector, investment size, and compliance status, and must always be re-verified against the latest regulations.
No administrator, advisor or official can guarantee an approval or a tax incentive. Every investment in KEK Sanur is case-by-case and subject to change in law or policy.
Step 1 – Confirm your sector fits KEK Sanur
The first step in how to invest in KEK Sanur is to confirm that your planned activity is allowed in the zone and can qualify for SEZ facilities under Indonesian law.
1.1 Understand KEK Sanur’s core themes
Based on the SEZ designation and public planning documents, KEK Sanur is structured around:
– Health services (e.g., hospitals, clinics, diagnostic centers, medical tourism services)
– Supporting health infrastructure (e.g., laboratories, pharmacies, rehabilitation facilities)
– Hospitality and tourism (e.g., hotels, resorts, MICE facilities) that support medical and wellness tourism
– Supporting services (e.g., F&B, retail, training and research facilities) that align with the zone’s health-tourism focus
Each activity maps to one or more KBLI (Klasifikasi Baku Lapangan Usaha Indonesia – Indonesia’s standard industry classification) codes. Those KBLI codes drive:
– Foreign ownership limits (if any)
– Minimum investment thresholds for PT PMA
– OSS risk level (low, medium-low, medium-high, high)
– Sectoral permits you must obtain
– KEK incentive eligibility
1.2 Check the Negative List / Positive Investment List
Indonesia moved from a “Negative List” to a “Positive Investment List” under Presidential Regulation 10/2021 and related rules. This list determines:
– Which sectors are open to 100% foreign ownership
– Which are limited (e.g., capped at a certain percentage foreign shareholding)
– Which are reserved for MSMEs or closed to investment
For KEK Sanur, many health and tourism-supporting sectors are open to foreign investors, but some health activities may require:
– Partnership with a local entity
– Specific professional licenses and staffing ratios
– Compliance with health facility classifications
You should:
1. Identify your exact KBLI codes.
2. Cross-check them against the Positive Investment List and any specific health-sector regulations.
3. Confirm that your desired shareholding structure fits those rules.
1.3 Align with KEK-specific development plans
Beyond legality, KEK Sanur’s Administrator and BUPP will evaluate whether your project is consistent with:
– The zone’s master plan and spatial plan
– Themed clusters (health, wellness, hospital, hospitality, supporting services)
– Infrastructure capacity (utilities, access roads, parking, waste treatment)
Projects that match the zone’s planned uses and investment profile have a cleaner path through the KEK Sanur entry process. Misaligned concepts are more likely to stall or be asked to relocate outside the zone.
Step 2 – Form a PT PMA (foreign investment company)
For most foreign investors, the main vehicle for investing in KEK Sanur is a PT PMA. This is mandatory whenever foreign shareholders (corporate or individual) own any portion of the company in a sector open to foreign participation.
2.1 Typical share capital and investment size
Indonesian rules distinguish between:
– “Large” enterprises with higher minimum investment
– Micro, small, and medium enterprises (UMKM) generally reserved for locals
For PT PMA, the national framework has typically required:
– A **minimum total investment** (excluding land and buildings) on the order of **IDR 10 billion per KBLI** or business line (verify current rules, as thresholds may be revised).
– A **paid-up capital** portion that must be injected and documented.
For capital-intensive facilities in KEK Sanur (e.g., hospitals, specialist clinics, high-end hotels), investment amounts often exceed these minimums in practice due to construction and equipment costs.
These are regulatory thresholds, not cost estimates. You must check the latest BKPM/Ministry of Investment rules and any KEK-specific implementing regulations before finalizing your capital plan.
2.2 Shareholding structure and directors
A PT PMA must have at least:
– 2 shareholders (can be individuals or companies, domestic or foreign, subject to sector limits)
– 1 director
– 1 commissioner
Common structures for KEK Sanur include:
– A foreign parent company holding the majority or all shares permitted by law.
– Indonesian partners holding minority stakes where required or strategically desired.
– Local professionals on the board to support licensing and on-the-ground operations (not a formal requirement, but often practical).
2.3 Incorporation process outline
The PT PMA formation process typically runs in parallel with OSS registration. Core steps usually include:
1. Reserve company name (via the Ministry of Law and Human Rights system).
2. Draft the Articles of Association with a notary, detailing:
– Company purpose and KBLI codes
– Share capital and shareholding
– Governance structure
3. Sign the Deed of Establishment before a notary.
4. Obtain legalization from the Ministry of Law and Human Rights.
5. Register the company in the company registry and obtain a Tax ID (NPWP).
In practice, many investors work with local corporate-service or law firms for this step. You remain responsible for ensuring the chosen KBLI and structure match KEK Sanur’s focus and Indonesia’s Positive Investment List.
For introductions to vetted structuring and licensing advisors familiar with KEK Sanur, you can plan your trip and request WhatsApp-based planning support.
Step 3 – OSS: NIB and risk-based licensing
With a PT PMA structure in place (or at least in process), the next part of how to enter KEK Sanur is obtaining your OSS licenses.
3.1 Registering for a Business Identification Number (NIB)
The OSS (Online Single Submission) system is Indonesia’s central business licensing platform. You will:
1. Create an OSS account for your PT PMA.
2. Enter basic corporate details (name, address, NPWP, capital, shareholders).
3. Select your KBLI codes and planned business activities inside KEK Sanur.
4. Declare location and land status (KEK Sanur will later be specified as your operational area).
5. Generate your NIB (Nomor Induk Berusaha).
The NIB functions as:
– A unified business registration number
– Company registration proof for many purposes
– Importer identification for certain activities
– Basic operational license for low-risk sectors
3.2 Risk-based licensing: low to high risk
Indonesia’s risk-based licensing regime categorizes activities as:
– Low risk
– Medium-low risk
– Medium-high risk
– High risk
Each level requires a different combination of:
– NIB only (for some low-risk activities)
– NIB + Standard Certificate (self-declared then verified)
– NIB + specific permits/approvals
Health and medical activities (hospitals, clinics, laboratories) are typically:
– Medium-high or high risk
– Subject to strict sectoral licensing by the Ministry of Health and/or local health authorities
– Bound by facility standards, staffing requirements, and ongoing compliance audits
Hospital/clinic licensing is not a formality; it sits on top of your NIB and may involve:
– Detailed facility design and equipment plans
– Medical waste management systems
– Staffing profiles with registered medical professionals
– Periodic inspections and facility classification
3.3 Sectoral permits linked to KEK Sanur
Once your NIB is issued, you obtain sector-specific permits. For KEK Sanur, typical examples might include:
– Health facility operating licenses (hospital, clinic, lab, pharmacy)
– Tourism and hotel operational licenses
– Environmental approvals (AMDAL/UKL-UPL or equivalent, depending on project size and risk)
– Construction permits integrated in OSS (PBG – building approval, SLF – building eligibility, etc.)
The KEK context may affect:
– Which local authority is the “competent authority” (Administrator KEK vs. standard municipal agencies)
– Additional documentation to prove your project is within the KEK boundary and endorsed by the Administrator/BUPP
Always confirm, before committing capital, whether your full stack of permits is realistically achievable for your specific activity and business model.
Step 4 – Engage the KEK Sanur Administrator and BUPP
Licensing via OSS is necessary but not sufficient. Investing in KEK Sanur also requires a relationship with:
– The KEK Administrator (Administratur KEK Sanur) – the local government body overseeing regulatory implementation in the zone.
– The BUPP – the entity holding the HPL and responsible for building and managing the zone’s infrastructure.
4.1 Letter of Intent (LoI) and project outline
Foreign investors typically begin by submitting a Letter of Intent (LoI) or investment proposal to the Administrator and/or BUPP, outlining:
– Investor profile (group structure, track record in sector)
– Project description (type of facility, KBLI, target market)
– Investment size (CAPEX, OPEX estimates)
– Land and space needed (plot size, building footprint, phasing)
– Infrastructure needs (power, water, data, medical gases, waste handling)
– Workforce plan (foreign experts vs local staff, training commitments)
This allows KEK Sanur authorities to:
– Assess fit with the zone’s master plan
– Identify suitable land/space options
– Flag any regulatory or capacity constraints early
– Discuss potential KEK facilities (in principle, subject to formal approval later)
4.2 HGB-over-HPL and other land-use structures
KEK Sanur’s land is held under HPL by the BUPP. Foreign investors generally do not obtain freehold (Hak Milik). Common structures include:
– **HGB-over-HPL (Hak Guna Bangunan di atas HPL)**
– BUPP holds the HPL.
– Your PT PMA obtains HGB for a defined term (often up to 30 years, extendable, within the limits of national land law).
– You can develop and use the building/land under HGB, subject to the underlying HPL agreement.
– **Lease or use-right agreements**
– For smaller or flexible tenancies (e.g., clinics within a hospital complex, retail, F&B), structures may involve commercial leases or building-use agreements rather than a standalone HGB title.
Key variables in these structures:
– Term length and extension rights
– Rent or land-use fees (upfront, annual, revenue-based, or hybrid)
– Construction obligations and timelines
– Transferability of rights (e.g., can you sell your HGB or shareholding)
– Conditions tied to KEK facilities (e.g., minimum investment, employment, operating standards)
Any land or space arrangement must be aligned with:
– Indonesian land law
– SEZ-specific regulations
– The zone’s master plan and building codes
4.3 Coordination with licensing and incentives
Your engagement with the Administrator and BUPP is not just real estate. It connects directly to:
– Confirmation that your NIB and sectoral permits are linked to KEK Sanur as the operational location.
– The process of registering your project as a KEK entity eligible for SEZ facilities (subject to meeting criteria).
– Ongoing compliance reporting (investment realization, employment, exports, service volumes, etc.).
This step is where “investing in KEK Sanur” diverges from simply “investing in Bali” or “investing in an Indonesian city”. Without Administrator and BUPP alignment, you may end up with a licensed PT PMA that operates outside the KEK framework — and therefore outside KEK incentives.
Step 5 – Meet minimum-investment thresholds and KEK facilities
How to invest in KEK Sanur as a foreign investor is closely linked to the size and nature of your project. Many fiscal facilities are gated behind minimum investment thresholds and sector-specific rules.
5.1 General PT PMA thresholds
As noted earlier, Indonesian foreign-investment rules have generally required:
– A minimum total investment on the order of **IDR 10 billion per KBLI** (excluding land and buildings), subject to change.
– Compliance with “large enterprise” parameters, not UMKM thresholds.
These PT PMA rules apply whether or not you are in a KEK. In KEK Sanur they are a baseline for operating as a foreign-owned entity.
5.2 KEK-specific incentive thresholds
National KEK regulations provide for facilities such as:
– Corporate income tax reductions or holidays for certain priority investments.
– VAT and import-duty facilities on goods entering the KEK for production or services.
– Simplified customs procedures for movements in and out of the KEK.
– Certain non-fiscal facilities (immigration, manpower, etc.), depending on the zone and sector.
However:
– Tax-holiday tiers are defined centrally by Ministry of Finance regulations and Presidential regulations.
– They often link to **investment value brackets** (for example, tiered corporate tax holidays where larger investments qualify for longer relief periods). The exact IDR thresholds and duration bands must be checked against the latest regulations at the time you invest.
– Not every enterprise in a KEK automatically receives a tax holiday; eligibility is assessed project-by-project, based on formal applications and fulfillment of criteria.
Publicly available KEK rules set the framework, but each project’s actual facilities are subject to:
– Formal application and approval by the relevant ministries and KEK authorities.
– Verification of “realization” of investment, not just commitments on paper.
– Ongoing compliance with reporting and operational requirements.
Any figure cited in presentations or marketing (e.g., “up to X years tax holiday”) is a maximum under law, not a promise.
5.3 Sector-specific requirements for health facilities
Hospitals, advanced clinics, and diagnostic centers inside KEK Sanur can face additional:
– Minimum-bed or minimum-facility standards, depending on classification.
– Equipment and technology standards for high-end medical services.
– Professional staffing ratios, including minimum numbers of specialists per department.
These requirements do not only drive your CAPEX; they also affect whether you can be classified as the type of facility that can seek certain KEK or health-sector incentives. Sectoral health rules are updated periodically and must be consulted at the time of planning.
Step 6 – Construction, commissioning, and operational compliance
Once your entity is formed, OSS licensing obtained, and KEK Sanur land-use arrangement agreed, the actual build and commissioning phase starts.
6.1 Building approvals and environmental compliance
For construction inside KEK Sanur, you will typically need:
– Building approvals (PBG) for your design, consistent with the KEK’s spatial plan and building codes.
– Environmental documentation (e.g., AMDAL or UKL-UPL) appropriate to your project’s scale and risk.
– Occupational health and safety measures integrated into design and operations.
The Administrator and BUPP often coordinate technical reviews to ensure:
– Infrastructure connections (power, water, sewerage, telecoms) are feasible.
– Traffic, parking, and access comply with the zone’s layout.
– Medical or hazardous waste systems comply with national and local standards.
6.2 Commissioning and sectoral inspections
Before operating a medical or hospitality facility, sector regulators may inspect:
– Built facilities vs approved plans.
– Installation and certification of critical systems (e.g., electrical, fire-safety, medical gases).
– Readiness of clinical or guest services.
For hospitals and advanced clinics, commissioning can include:
– Mock drills for emergency procedures.
– Validation of diagnostic and treatment equipment.
– Verification of medical staff credentials and licensing.
Only after these checks are passed do you receive final operating permits.
6.3 Ongoing KEK compliance
Operating in KEK Sanur typically means periodic reporting on:
– Investment realization (CAPEX injected, timelines vs commitments).
– Employment data (local vs foreign staff, training programs).
– Financial performance for tax and incentive monitoring.
– Import/export or service-delivery metrics, where relevant.
Failure to maintain compliance can lead to:
– Suspension or revocation of KEK facilities.
– Reassessment of fiscal benefits.
– In serious cases, withdrawal of operating licenses.
You should treat compliance as an ongoing project, not a one-time hurdle.
Key documents you will typically need
The exact list varies by sector and project, but most foreign investors entering KEK Sanur will deal with the following document categories.
| Document | Purpose | Who issues / prepares it |
|---|---|---|
| Passport / ID for individual shareholders | Identify foreign individual owners of PT PMA | Shareholders (certified copies as required) |
| Corporate registry & Articles for corporate shareholders | Prove existence and authority of foreign/corporate investors | Home-country registries and company secretaries |
| Power of Attorney / Board Resolution | Authorize representatives to sign incorporation and land documents | Shareholders’ boards; legalized as needed |
| Draft Articles of Association (Anggaran Dasar) | Define PT PMA structure, KBLI, capital, governance | Indonesian notary in consultation with investors |
| Deed of Establishment | Formal incorporation of PT PMA | Indonesian notary; legalized by Ministry of Law and Human Rights |
| Tax ID (NPWP) | Register PT PMA for taxation | Indonesian tax office |
| OSS registration & NIB | Core business identification and basic licensing | OSS system (self-filed or via representative) |
| Sectoral licenses (health, tourism, etc.) | Permit operation in regulated sectors | Relevant ministries/local agencies via OSS |
| Letter of Intent (LoI) to KEK Sanur | Outline project and request entry into the KEK | Investor / PT PMA to Administrator and/or BUPP |
| Land-use agreement / HGB-over-HPL contract | Grant right to build and use land/space in KEK Sanur | BUPP and PT PMA; notarized as required |
| Building approvals (PBG) & environmental docs | Authorize construction and ensure environmental compliance | Local authorities / KEK Administrator |
| KEK facility approval documentation | Grant fiscal/non-fiscal KEK benefits (if approved) | Dewan Nasional KEK / relevant ministries |
| Employment and immigration permits | Legalize foreign experts and staff in Indonesia | Ministry of Manpower and Immigration |
Each of these can involve legalization, sworn translations into Bahasa Indonesia, and consular attestation for foreign-origin documents. Timelines lengthen when these formalities are overlooked.
KEK Sanur vs “standard” Bali investment: a quick comparison
For foreign investors comparing KEK Sanur with investing elsewhere in Bali, the structural differences can be summarized as follows.
- Legal framework
- KEK Sanur operates under national SEZ regulations plus general investment law; standard Bali investments rely only on general law.
- Land structure
- KEK Sanur uses HPL held by BUPP with HGB-over-HPL or leases; outside KEK, you deal with private or state land (HGB, HGU, lease, nominee risk if misstructured).
- Fiscal facilities
- KEK Sanur offers potential KEK facilities (tax/customs) if criteria are met; standard Bali has general incentives only.
- Authorities
- KEK Sanur adds the Administrator and BUPP to the usual roster of ministries and local governments.
- Sector focus
- KEK Sanur is heavily oriented to health and medical tourism; elsewhere in Bali, broader tourism and property uses are more typical.
- Regulatory scrutiny
- KEK Sanur health projects may face stricter clinical standards and reporting; non-KEK projects can be simpler but lack SEZ benefits.
Neither path is “better” for every investor. KEK Sanur is designed for projects that can leverage its health focus and facilities framework, and that are ready for a higher level of scrutiny and formalization.
Practical tips for foreign investors in KEK Sanur
Align your concept early
Shape your concept around KEK Sanur’s health-tourism positioning from the outset. Retro-fitting a generic hospitality or wellness project into a health-focused SEZ is difficult.
Budget for regulatory and advisory costs
You will need:
– Legal, tax, and technical advisors for PT PMA, OSS, land, and KEK facilities.
– Sector specialists (especially for hospitals and advanced clinics) to interpret clinical standards.
As of the most recent public data, professional fees in Indonesia for mid-sized foreign projects are typically a modest fraction of total CAPEX but significant enough that they must be budgeted from day one (indicative ranges vary widely by scope and are best confirmed directly; last verified June 2026).
Stage your investment to meet thresholds without overcommitting
Many investors:
– Use phased development (core facility first, optional expansions later).
– Ensure phase one already meets PT PMA and KEK threshold logic, rather than counting on distant future CAPEX.
This can reduce the risk of failing to qualify for expected facilities because the project never actually reaches the committed scale.
Insist on time-stamped regulatory advice
Rules move. Always:
– Ask advisors to cite the exact regulation and article they rely on.
– Date every memo or slide deck.
– Reconfirm key points (ownership caps, thresholds, facility eligibility) shortly before each major commitment (land agreement, construction, commissioning).
Use KEK Sanur as a base, not your entire strategy
Many foreign investors use KEK Sanur as:
– A flagship or anchor health-tourism facility.
– A platform integrated with feeder clinics, referral partners, or hospitality assets elsewhere in Indonesia or abroad.
Plan for how the KEK-based asset interacts with your broader network, including referral flows, insurance partners, and technology platforms.
For introductions to advisors, developers, and operators that actively work on KEK Sanur projects, you can plan your trip and request WhatsApp-based planning support; no one can pay to change what we publish, but if you proceed with our partner they may pay us a referral fee at no extra cost to you.
FAQs: KEK Sanur for foreign investors
Can a foreign individual directly own land in KEK Sanur?
No. Land in KEK Sanur is held under HPL by the BUPP. Foreign investors generally invest through a PT PMA that obtains HGB-over-HPL or a lease/usage agreement. Direct freehold (Hak Milik) ownership by foreigners is not the operating model inside the zone.
Is there a fixed minimum investment to get KEK Sanur incentives?
There is no single fixed number that applies to every project. PT PMA rules have typically set minimum investment levels around IDR 10 billion per KBLI (excluding land and buildings), and separate national KEK regulations define tax-holiday tiers based on investment brackets. Both sets of rules are updated periodically and must be re-checked for your sector and timing.
How long does it take to complete the KEK Sanur entry process?
Timelines vary widely. In straightforward service sectors, forming a PT PMA and obtaining a NIB can take weeks, but health-facility licensing, land agreements, construction approvals, and KEK facilities can extend the process into many months or longer. No responsible party can guarantee a specific approval date.
Do all businesses in KEK Sanur automatically receive tax holidays?
No. Being located in KEK Sanur makes you eligible to apply for KEK facilities, but each tax or non-tax incentive is subject to a separate assessment by the relevant authorities. Many businesses in a KEK operate under standard tax rules if they do not meet the criteria or do not apply.
Can I convert an existing Bali business into a KEK Sanur entity?
It is sometimes possible to restructure, relocate, or spin off operations into a PT PMA based in KEK Sanur, but this involves corporate, tax, and regulatory steps. You must re-evaluate licensing, land arrangements, and KEK eligibility rather than assuming existing permits will simply transfer. Professional advice is essential before attempting such a move.