Sanur Health Special Economic Zone: How Indonesia’s First Health SEZ Works

The sanur health special economic zone is Indonesia’s first Special Economic Zone (SEZ) whose core permitted activities are health services and tourism, legally designated by Government Regulation (Peraturan Pemerintah/PP) 41/2022. It is a 41.26-hectare integrated health and tourism precinct in Sanur, Denpasar, Bali, structured to host an international hospital, hotels, wellness facilities, MICE, and supporting infrastructure under a single SEZ governance regime.

1. What is the Sanur Health Special Economic Zone?

Legally, the Sanur Health Special Economic Zone (Kawasan Ekonomi Khusus Kesehatan Sanur, often shortened to KEK Sanur) is a Special Economic Zone established by PP 41/2022 about the Sanur Health SEZ in Bali. “Health” and “tourism” are explicitly named as the main activities, making it Indonesia’s first health-focused SEZ (indonesia first health sez) rather than a generic industrial, logistics, or tourism zone.

Key legal points from PP 41/2022 and the core SEZ framework (UU 39/2009 on SEZs and PP 40/2021 on SEZ implementation):

• Location: Sanur, City of Denpasar, Bali Province.
• Area: 41.26 hectares (PP 41/2022, Article 3).
• Zone function: Health services, tourism, and supporting services (Article 4).
• Developer and operator: PT Hotel Indonesia Natour (HIN), part of the state-owned tourism holding InJourney (Article 9).
• SEZ governance: Follows UU 39/2009 and PP 40/2021, with a dedicated Administrator and KEK Business Entity.

This makes Sanur legally different from a normal hospital district or tourism area in Bali. It is a kek kesehatan (health SEZ) with its own customs, tax, and licensing treatment inside a designated boundary, supervised by the National Council for SEZs (Dewan Nasional KEK).

2. Policy Logic: Why a Health SEZ in Sanur?

2.1 The medical tourism deficit Indonesia is trying to recapture

The main policy logic for the Sanur health and tourism district is to reduce outbound medical tourism and retain foreign-exchange (FX) spending inside Indonesia. The numbers here are from statements by senior Indonesian officials and must be read as policy targets, not audited outcomes.

• The Coordinating Ministry for Maritime and Investment Affairs has repeatedly cited estimates that hundreds of thousands of Indonesians travel abroad each year for medical treatment, with common destinations including Singapore, Malaysia, and Thailand. Publicly mentioned figures range from around 600,000 patients/year up to around 2 million patients/year, but these are not backed by a single consolidated official patient-count dataset. They should be treated as policy estimates, not verified statistics.
• Airlangga Hartarto (Coordinating Minister for Economic Affairs and Chair of Dewan Nasional KEK) has stated a target for the Sanur Health SEZ and other initiatives to help Indonesia recapture around 123,000–240,000 patients per year by 2030. This 123k–240k range is explicitly a policy target used in public communication; we have not seen it as a historical realized figure.
• The same policy communications quote a projected FX savings target of around Rp 86 trillion by 2045 from reducing outbound medical tourism. Again, this is a projection/target, not an audited current figure.

Those three numbers – “hundreds of thousands” of outbound patients, the 123k–240k patients/year recapture target by 2030, and the Rp 86 trillion FX-savings target by 2045 – form the macro rationale behind a dedicated health SEZ, with Sanur as the pilot.

2.2 Why Sanur, why Bali?

From a policy and market perspective, Bali offers:

• Existing tourism infrastructure and international air connectivity via Ngurah Rai International Airport.
• Brand recognition for wellness, spa, yoga, and “recovery” travel categories.
• Available state-owned land from the legacy Grand Inna Bali Beach complex in Sanur that can be consolidated into an SEZ.
• Local government support from the Province of Bali and the City of Denpasar, as reflected in the recommendation process that preceded PP 41/2022.

Sanur itself has a quieter, older-tourism profile compared to Kuta or Canggu, which aligns with hospital and rehabilitation uses. PP 41/2022 specifically locks the SEZ perimeter inside Sanur’s urban context, not a greenfield site away from the city.

3. What Makes a “Health SEZ” Different from a Regular Hospital?

3.1 Legal and regulatory differences

A health special economic zone in Bali is fundamentally a territorial regime, not just a hospital license. Within the 41.26-hectare boundary of KEK Sanur, several differences apply compared to an ordinary hospital complex outside an SEZ:

• Customs and excise treatment: Under UU 39/2009 and PP 40/2021, SEZs receive customs and excise facilities. Medical equipment and inputs for eligible activities can enter under specific relief schemes subject to customs regulations and zone rules. An ordinary hospital is simply a customs territory without those SEZ-specific facilities.
• Tax facilities: Income tax, VAT, and other fiscal facilities can be granted in SEZs via PP 96/2015 (for existing SEZs) and later derivative regulations. The detailed application to KEK Sanur depends on Ministry of Finance decisions and implementing rules. A regular hospital does not automatically enjoy SEZ-level fiscal treatment.
• Integrated licensing: SEZ Administrators are intended to streamline licensing for investors and operators within the zone – including health facility licensing, supporting tourism operations, building permits, etc. Outside an SEZ, investors work directly with multiple layers of government for each license.
• One developer / multiple tenants: A hospital in normal urban planning is a single facility operator. In KEK Sanur, PT Hotel Indonesia Natour acts as the KEK Business Entity (developer–operator), which can host multiple tenant companies – for example, an international hospital operator, hotel operators, wellness centers, and MICE operators – all under the SEZ framework.
• Non-hospital uses inside one regime: The SEZ explicitly covers tourism accommodation, MICE (meetings, incentives, conferences, exhibitions), retail, ethnomedical garden, and supporting utilities. A “health SEZ” in Indonesia is thus a multi-activity precinct with health as the anchor, not a pure medical compound.

3.2 Operationally: from therapy to conference in one precinct

In policy documents and public presentations, KEK Sanur is consistently framed as an integrated “health and tourism district”. In practice this means:

• Patients can receive treatment in the hospital, stay in on-site hotels or serviced residences, and access wellness, spa, and rehabilitation services within walking distance.
• Medical conferences, trainings, and health-related MICE events are intended to be hosted in the same precinct, with hotels and convention facilities connected to the health infrastructure.
• Tourists who are not hospital patients can still use the hotels, beach area, and some wellness facilities as a usual tourism product, adding non-medical demand to the zone.

The difference versus a standalone hospital in Jakarta or Surabaya is that in KEK Sanur the entire neighborhood is structured around this health–tourism combination and enjoys SEZ-level investment and operational rules.

4. What’s Actually Built vs. Planned?

This section uses only what can be sourced from PP 41/2022, official communications by InJourney / PT Hotel Indonesia Natour, Dewan Nasional KEK, and other government sources up to the last check in mid-2026. Any future-dated capacity numbers should be treated as plans/targets, not guarantees.

4.1 Land and existing hotel legacy

• Total designated SEZ land: 41.26 hectares (PP 41/2022, Article 3).
• Origin of land: Primarily state-owned assets associated with the former Grand Inna Bali Beach hotel complex in Sanur, transferred into the SEZ framework. This includes the main tower and bungalows area that predate the SEZ designation.

At the time of recent official updates, the SEZ land is under phased redevelopment. Parts of the legacy hotel assets have been refurbished or are under renovation to match the new health-tourism positioning.

4.2 Flagship health facility: the international hospital

The central health asset is an international-standard hospital developed with Indonesia Healthcare Corporation (IHC), the state-owned hospital holding under PT Bio Farma. Indonesian officials and IHC have described this hospital as:

• An international referral hospital, capable of providing services that Indonesians currently seek abroad (cardiology, oncology, orthopedics, and other high-complexity treatments).
• Developed in partnership with private and/or foreign health service providers (names depend on specific MoUs, which need to be checked against official announcements before citing).
• Equipped with advanced diagnostic and therapeutic equipment brought in under SEZ customs/tax facilities (subject to Ministry of Finance approval and customs clearance processes).

Specific bed counts, specialty breakdowns, and commissioning dates should always be checked against the most recent official IHC and Dewan Nasional KEK reports before being quoted. Many early media releases carried projected numbers; KEK Sanur Intelligence treats those as targets until confirmed by operating data.

4.3 Integrated tourism: hotels, MICE, and beach access

On the tourism side, PP 41/2022 explicitly allows:

• Accommodation (hotels, villas, serviced apartments) within the SEZ.
• MICE facilities – convention centers, meeting rooms, exhibition spaces.
• Supporting retail and F&B to serve guests and patients’ companions.

InJourney, through PT Hotel Indonesia Natour and related entities, leads the redevelopment of the legacy Grand Inna Bali Beach campus into a mixed-use tourism and health complex. This includes:

• Renovation and repositioning of the main tower as a higher-category hotel product integrated with the SEZ experience.
• New-build hotels and resort-style properties targeted at both regular tourists and medical travelers.
• Beachfront enhancement and public-space upgrades aligned with Denpasar’s coastal planning and environmental regulations.

Again, room counts and brand flags often circulate in press releases; each specific figure needs tracing to an official project disclosure. Where developer presentations quote targets for hotel keys and MICE capacity in a given year, KEK Sanur Intelligence classifies them as pipeline estimates until projects reach operational status.

4.4 Wellness, ethnomedical garden, and supporting facilities

PP 41/2022 and subsequent presentations highlight several supporting components:

• Wellness and rehabilitation centers – these link traditional Balinese wellness concepts with modern therapy (physiotherapy, post-surgery rehab, mental health support, etc.).
• Ethnomedical garden – a curated garden area for Indonesian medicinal plants (tanaman obat), educational trails, and research/branding of traditional medicine. This is part policy showcase, part experiential tourism product.
• Utilities and infrastructure – internal roads, power, water, wastewater, ICT, and emergency services tailored to a hospital-critical environment as well as tourist flows.

Some of these components are under active construction or detailed design. Their final form depends on budget realization, environmental permitting, and investor appetite.

5. Governance and Institutional Structure

5.1 National SEZ framework

Sanur’s health SEZ sits inside Indonesia’s general SEZ architecture:

• UU 39/2009 on Special Economic Zones – sets the framework for establishment, governance, and facilities for SEZs.
• PP 40/2021 – implementation rules under the Omnibus Law regime, updating SEZ procedures and aligning them with risk-based licensing.
• Dewan Nasional KEK – the National Council for SEZs, chaired by the Coordinating Minister for Economic Affairs, which recommends SEZ proposals to the President and oversees performance.

PP 41/2022 is the specific designation regulation that gives Sanur its SEZ status and parameters within this broader framework.

5.2 Developer–operator: InJourney and PT Hotel Indonesia Natour

PP 41/2022 designates PT Hotel Indonesia Natour (HIN) as the KEK Business Entity for Sanur. HIN is part of the InJourney group, Indonesia’s state-owned tourism and aviation holding company.

This structure means:

• HIN is responsible for developing core infrastructure, managing land-use within the SEZ, and entering into cooperation agreements with hospital and hotel operators.
• InJourney coordinates the alignment of airport, tourism promotion, and SEZ development strategies so that KEK Sanur is integrated with Bali’s broader visitor flows.
• Indonesia Healthcare Corporation (IHC) is the central state-owned hospital partner for the flagship health facilities, working within the SEZ that HIN develops.

Private and foreign investors can join as tenants or joint-venture partners, but the state-owned entities anchor the zone’s health and tourism components.

5.3 Local governance: Administrator and One-Stop Service

Under PP 40/2021, each SEZ has an Administrator (Administrator KEK) that functions as the local regulatory interface:

• Issuing relevant permits and licenses through the Online Single Submission (OSS) system, adapted for SEZs.
• Monitoring tenant activity and ensuring compliance with SEZ rules, health regulations, and labor standards.
• Reporting performance to Dewan Nasional KEK, including investment realization, employment, and export or FX indicators.

For investors, this is marketed as a faster, integrated licensing pathway compared to piecemeal local permitting. KEK Sanur Intelligence monitors how the Administrator’s performance aligns with those promises in practice.

6. Incentives and Facilities for Investors and Operators

Incentives for the sanur health special economic zone are derived from the generic SEZ framework plus any sector-specific rules that apply to hospitals, tourism, and research. The broad categories, based on UU 39/2009, PP 40/2021, and PP 96/2015, include:

• Income tax facilities for qualifying investments, subject to Ministry of Finance regulations and project-specific approvals.
• VAT and import-duty facilities on certain imported capital goods, raw materials, and equipment used within the SEZ.
• Excise facilities as relevant (less central in health, but potentially relevant for some consumables).
• Customs simplifications for movements of goods in and out of the SEZ area.
• Non-fiscal facilities – such as easier foreign worker permits, streamlined land-use approval, and risk-based licensing procedures for health and tourism businesses.

The exact incentive package available to a specific hospital or hotel project in KEK Sanur depends on:

• Its classification under Indonesian Negative/Positive Investment Lists and sectoral regulations.
• Investment size, timing, and alignment with SEZ priority activities.
• Approval decisions by the Ministry of Finance and related ministries.

Because these are case-dependent, KEK Sanur Intelligence always recommends investors verify current incentives with the SEZ Administrator and Ministry of Finance before finalizing financial models.

7. How KEK Sanur Fits into Indonesia’s Health and Tourism Strategy

7.1 National health system and referral role

The Sanur Health SEZ is not intended to replace the national referral hospitals in Jakarta, Surabaya, or other major cities. Instead, it is designed to:

• Provide substitute capacity for procedures that Indonesians currently obtain abroad, with a focus on international-standard patient experience and technology.
• Act as a regional referral point within Eastern Indonesia for certain specialties, subject to Ministry of Health referral policies and BPJS Kesehatan coverage frameworks.
• Host training, research, and education activities that link Indonesian clinicians with international partners.

Whether, and to what extent, services in KEK Sanur fall under BPJS Kesehatan coverage will depend on Ministry of Health and BPJS decisions, and may differ across service lines.

7.2 Tourism diversification and higher-value visitors

From a tourism policy perspective, the health special economic zone Bali authorities are aiming for:

• Higher per-visitor spend by combining medical services with longer stays and higher-category hotel products.
• More resilient demand that is less sensitive to purely leisure-cycle fluctuations; patients travel for treatment even when general tourism slows.
• New market segments such as elderly care stays, post-operative rehabilitation holidays, and combined check-up & family vacation packages.

This aligns KEK Sanur with Bali’s broader strategy to move up the value chain and diversify beyond mass, low-margin tourism.

8. Key Official Figures and What They Mean

The table below summarizes some of the most-quoted figures for KEK Sanur, with source notes and our classification of each number’s status.

Figure	Value / Range	Status	Primary Source / Basis
SEZ land area	41.26 hectares	Legal fact	PP 41/2022, Article 3
Main activities	Health services and tourism	Legal fact	PP 41/2022, Article 4
Developer / KEK Business Entity	PT Hotel Indonesia Natour (HIN)	Legal fact	PP 41/2022, Article 9
Outbound Indonesian medical travelers per year	“Hundreds of thousands” (often 600k–2m cited)	Policy estimate	Statements by senior officials; no single consolidated official dataset publicly released
Patients to be “recaptured” by 2030	123,000–240,000 patients/year	Target	Statements by Coordinating Minister Airlangga Hartarto and Dewan Nasional KEK presentations
FX savings from reduced outbound medical tourism by 2045	Approx. Rp 86 trillion	Target	Government policy communications on health tourism and KEK Sanur
Hospital bed counts, specialty capacities	Varies by release	Planned/subject to confirmation	Project presentations, MoUs; must be checked against latest operational data
Hotel room count in SEZ	Ranges in hundreds–thousands cited	Pipeline estimates	Developer (InJourney/HIN) presentations; confirmation required post-opening

KEK Sanur Intelligence’s rule is simple: if a number cannot be traced to an official document or clearly attributed official statement, we flag it and do not reprint it as fact. Many project-deck figures in circulation are aspirations, not audited results.

9. Practical Implications for Patients and Investors

9.1 For patients and families

As the health facilities in KEK Sanur come online and scale up, patients can expect:

• International-standard hospital infrastructure within Bali, reducing the need to travel to Singapore or Malaysia for some procedures.
• Integrated accommodation options for family members within the same precinct.
• Potentially more packaged services (check-up + stay + wellness) built around Bali’s tourism offering.

Price levels, insurance coverage (including BPJS), and the actual range of specialties available at any given time should always be verified directly with the hospital operator. KEK Sanur Intelligence will report price ranges only when they can be sourced and dated; so far, most published numbers are promotional and not systematized.

9.2 For investors and operators

Investors looking at the sanur health special economic zone need to consider:

• Regulatory fit: How their proposed activity (hospital, clinic, hotel, lab, R&D, wellness center, MICE service, etc.) maps to the allowed activities under PP 41/2022 and health/tourism regulations.
• Incentive eligibility: Whether they qualify for SEZ tax/customs facilities and on what terms, which requires early dialogue with the Administrator and Ministry of Finance.
• Governance risk: SEZs in Indonesia are subject to periodic evaluation by Dewan Nasional KEK. Underperformance can trigger warnings and, in extreme cases, revocation. Investors need to understand these risks and how they might affect long-term operations.
• Demand realism: The 123k–240k patients/year recapture and Rp 86 trillion FX-savings targets are aggressive. Project models should stress-test more conservative scenarios as well.

If you are planning site visits, partner meetings, or feasibility work around KEK Sanur, you can plan your trip with our help. We coordinate detailed, regulation-grounded briefings over email or WhatsApp and can connect you with on-the-ground legal and sector specialists; no one can pay to change what we publish, and if you proceed with our partner they may pay us a referral fee at no extra cost to you.

10. How KEK Sanur Is Evaluated and What to Watch

10.1 Dewan Nasional KEK scorecards

All SEZs – including the health special economic zone Bali – are subject to regular evaluation by Dewan Nasional KEK. The evaluation criteria typically include:

• Investment realization versus commitments.
• Employment creation.
• Export or FX-earning performance.
• Operationalization of core facilities (in Sanur’s case, particularly the hospital and tourism components).

Dewan Nasional KEK publishes summary results and, in some cases, zone-specific notes. Zones that do not meet expectations can face:

• Warning letters and improvement plans.
• Restructuring of management or development plans.
• In extreme failure cases, revocation of SEZ status.

For KEK Sanur, the key watchpoints in coming years are: hospital commissioning milestones, occupancy and patient volumes, and realized vs. promised investments in hotels and wellness facilities.

10.2 Policy stability and regulatory changes

Indonesia’s SEZ framework has been revised multiple times (for example, via PP 40/2021 aligning with the Omnibus Law). Health regulations and foreign-partner rules are also evolving. Investors and patients should monitor:

• Any updates to PP 96/2015 or successor regulations on SEZ taxation.
• Ministry of Health regulations affecting foreign doctors, technology adoption, and telemedicine in SEZs.
• BPJS Kesehatan coverage decisions for services provided inside KEK Sanur.

These shifts can affect the business case for new investments and the affordability of services for Indonesian patients.

11. Staying Updated and Getting Independent Intelligence

KEK Sanur Intelligence tracks the legal framework, regulatory changes, governance reports, and performance data for the Sanur Health SEZ from primary sources – UU 39/2009, PP 40/2021, PP 41/2022, PP 96/2015, and Dewan Nasional KEK evaluations – and flags any unverified numbers in circulation.

If you need a tailored briefing – for example, a regulatory risk note for an investment committee, or a practical guide to accessing care in KEK Sanur as an international patient – you can plan your trip and ask us to structure a WhatsApp-led advisory process. We remain independent in our analysis; no one can pay to change what we publish, and if you work with a partner we recommend they may pay us a referral fee at no extra cost to you.

FAQ: Sanur Health Special Economic Zone

What is legally special about the Sanur Health SEZ compared to other areas in Bali?

Sanur is designated by PP 41/2022 as a 41.26-hectare Special Economic Zone focused on health and tourism, which gives it access to SEZ-specific tax, customs, and licensing facilities under UU 39/2009 and PP 40/2021. Ordinary areas in Bali, including regular hospital districts, do not automatically enjoy those SEZ facilities.

Is the international hospital in KEK Sanur already fully operational?

The international hospital in KEK Sanur has been under phased development with Indonesia Healthcare Corporation as the state-owned anchor. Commissioning timelines, bed counts, and service lines should be confirmed against the latest official announcements from IHC and Dewan Nasional KEK, as early numbers were often targets rather than final operating data.

Can foreign patients use the Sanur Health SEZ for treatment?

Yes, the policy intent is for KEK Sanur to serve both Indonesian and foreign patients as an international medical tourism hub. Actual service availability, visa requirements, and insurance arrangements should be verified directly with the hospital operator and, for some nationalities, with Indonesian consular offices.

What incentives are available for investors in the Sanur Health SEZ?

Investors may access SEZ tax facilities (such as income tax and VAT relief), customs and excise facilities, and streamlined licensing, all subject to Ministry of Finance and sectoral ministry approvals. The exact package depends on the project’s nature, size, and compliance with PP 41/2022 and broader SEZ regulations.

How reliable are the patient and FX-savings numbers quoted for KEK Sanur?

The widely cited 123,000–240,000 patients/year by 2030 and Rp 86 trillion FX savings by 2045 are explicit government targets, not audited results. KEK Sanur Intelligence treats them as policy goals and will only classify them as performance outcomes once backed by verifiable official data.