The four checks are related—but not interchangeable
For a rental villa, do not accept a single screenshot, tax receipt or broker statement as “the licence.” The file normally needs four questions answered:
| Question | Document or system to examine | What it does not prove by itself |
|---|---|---|
| May this activity use this location? | Applicable spatial plan and the property's spatial-utilisation approval or confirmation, where required | That the structure was approved or is fit to use |
| Was this building approved as designed? | PBG, or a valid legacy IMB for an older building, plus approved technical drawings | That the completed building matches the approved drawings |
| Is the completed building fit for its approved function? | SLF and the supporting inspection record | That the operating company holds every business licence |
| May this operator run the relevant accommodation activity? | OSS business licensing for the correct entity, location and activity | Ownership of the land or compliance of unapproved extensions |
Indonesia's building framework is administered through SIMBG. The Ministry of Public Works describes it as the system for PBG, SLF and related building administration. Business licensing is handled through OSS under the risk-based licensing framework.
PBG, legacy IMB and SLF in plain English
PBG: approval for the building work
Persetujuan Bangunan Gedung (PBG) is the building approval used for constructing, changing, extending, reducing or maintaining a building in accordance with technical standards. Government Regulation No. 16 of 2021 is the central implementing regulation for the building regime.
An older villa may instead present an IMB issued under the previous regime. Do not reject or accept it based only on its age. Ask counsel and the local building office to confirm whether it remains valid for the existing structure and approved function—and whether later work required a new approval.
SLF: evidence of functional worthiness
Sertifikat Laik Fungsi (SLF) is the local-government certificate stating that a completed building is fit for use. Current Government Regulation No. 28 of 2025 says a business actor must obtain SLF before a building is used and provides an assessment route for existing buildings. This matters for acquisitions: “no PBG” is not a question a buyer should answer with a generic slogan. The correct pathway depends on the building's history and must be checked with the competent authority.
PBG asks whether the building work was approved. SLF asks whether the completed building is fit for its approved function. A due-diligence file should test both.
The document-to-building reconciliation
The decisive work is not collecting PDF filenames. It is reconciling the paperwork with the asset you can see. Ask the seller to authorise direct verification and give the reviewer a complete property schedule.
- Record the exact land parcel, address, owner/lessor, operating entity and intended use.
- Obtain the complete PBG or legacy IMB file—not only its cover page—and the approved architectural, structural and building-services drawings.
- Obtain the SLF, its identifier, issue/validity information and the technical assessment supporting it.
- Compare approved drawings with the current footprint, floors, bedrooms, pool, walls, access, parking, wastewater system and any rooftop or ancillary structures.
- List every alteration and ask which approval covers it. Treat “built later” as a verification item, not a harmless footnote.
- Verify the records through the competent regency/city office or its official system. Do not rely only on a forwarded portal screenshot.
A mismatch does not automatically tell you the remedy or its cost. It tells you not to price, sign or launch operations until a qualified professional has documented the path, authority, timing and closing condition.
Check the land use before the building file
Bali's Provincial Regulation No. 2 of 2023 establishes the provincial spatial plan for 2023–2043, while detailed controls also exist at regency/city level. Because a district name or map colour used in a sales deck is not a legal conclusion, verify the exact parcel against the currently applicable plans and approvals.
For property in Badung, the regency's official BATARA service offers parcel, RDTR/RTRW and spatial-document checks. Use the relevant local service for the actual property; a Badung lookup does not verify a villa in Gianyar, Denpasar or another jurisdiction.
The practical question is not simply “is it in a tourism area?” Ask whether the intended accommodation activity, building intensity, access and other site conditions are allowed for this parcel and reflected consistently in the building and business files.
Keep the operating licence in a separate column
OSS lists KBLI 55193 “Vila” for private houses specifically rented to tourists with facilities and managed by their owners. That definition is useful, but it does not mean every property marketed as a villa automatically belongs under that code. The correct KBLI, business scale, risk classification, supporting licence and responsible entity depend on the real operating model.
Ask the operator or seller to map each guest-facing activity to the entity named in OSS and to the property address. Verify who contracts with guests, receives revenue, employs staff and is responsible for compliance. A building approval in one party's name and an OSS account belonging to another may be explainable, but the chain must be documented.
Questions to put into the offer or lease
- Which documents must be delivered before the deposit becomes non-refundable?
- May your lawyer and technical reviewer verify records directly with authorities?
- Which party must cure a mismatch, and by what date?
- Is closing conditional on written confirmation of zoning, building status, SLF and the intended operating path?
- What happens to the deposit if the intended use cannot be verified?
- Which representations survive closing, and what evidence supports them?
Keep deposits, completion payments and fit-out commitments tied to evidence and professional advice. “The neighbour rents nightly” is not verification of your parcel, structure or entity.
A clean handoff to operations
Once due diligence closes, the owner should give the operator a controlled compliance pack: verified approvals, approved drawings, SLF evidence, spatial documents, OSS records, a plan of the actual asset and a register of renewal or monitoring dates. Store originals safely, restrict editing and log every later renovation against the approval question before work begins.
This file also improves monthly owner oversight. If the operating model, guest contract or building changes, the owner has a baseline against which to ask whether the permitted function and business licensing still match reality.
Official sources
- Government Regulation No. 16 of 2021 — implementation of Indonesia's building law.
- Government Regulation No. 28 of 2025 — current risk-based business licensing framework, including SLF provisions for business buildings.
- SIMBG, Ministry of Public Works — official building administration system.
- OSS KBLI 55193 “Vila” — official business-classification entry.
- Bali Provincial Regulation No. 2 of 2023 — Bali spatial plan 2023–2043.
- BATARA Badung — official parcel and spatial-plan information service for Badung.
Review a Bali villa investment → Build the owner-oversight file →