Anteya Research
PBG vs IMB in Bali: Building Permits for Foreign Buyers (2026)
May 22, 2026
Across roughly 5,300 buyer conversations Anteya logged with Bali buyers between 2023 and 2026, "is there a permit?" is one of the most common technical questions buyers send through after they see a render and a price. The answer has changed since the UU Cipta Kerja (Job Creation Law) reforms of 2020 replaced Izin Mendirikan Bangunan (IMB, the legacy building permit) with Persetujuan Bangunan Gedung (PBG, the current building approval). The replacement is not cosmetic. It changed the document a buyer should ask for, where to verify it, how regencies issue it, and what enforcement looks like when it is missing. This article walks through what PBG actually is, how it sits next to Sertifikat Laik Fungsi (SLF), what happened to old IMB certificates, and the concrete due-diligence steps a foreign buyer takes before sending a deposit on a Bali villa.
What PBG actually is, and what IMB used to be
IMB (Izin Mendirikan Bangunan) was the long-standing Indonesian building permit, granted by the regency or municipality before construction could begin. For decades it was the document that proved a building's right to exist on a given parcel; a Bali villa without IMB was, in practice, a building tolerated rather than authorized.
UU 11/2020 Cipta Kerja (the Job Creation Omnibus Law) and its implementing regulation PP 16/2021 on Building Regulations replaced IMB with Persetujuan Bangunan Gedung (PBG). The framing shift is important. IMB was a permit to build; PBG is a building approval tied to a technical-standards review (compliance with Standar Teknis Bangunan Gedung, the national building-technical standard, and with the local Tata Ruang / RTRW spatial plan).
In practical terms for a Bali buyer, PBG is the document that says: this structure was approved to be built on this parcel, at this size, for this declared use, in compliance with current regulation. It is issued by the regency through the Sistem Informasi Manajemen Bangunan Gedung (SIMBG, the national building-management information system), which runs as an online portal integrated with OSS-RBA (the Online Single Submission Risk-Based Approach platform).
SLF: the document that completes the loop
PBG alone is not enough. After construction finishes (or on substantial change of use), the building requires Sertifikat Laik Fungsi (SLF), a certificate that the completed structure is fit for the declared function. SLF is issued by the regency on confirmation that the built structure matches the PBG approval and meets the technical standard.
Two documents, two stages, both required:
- PBG before construction starts. Issued by the regency through SIMBG following technical-standards review by the Tim Profesi Ahli (TPA, the building expert review team).
- SLF after construction completes. Issued by the regency following inspection of the completed building against the PBG approval.
For an off-plan villa, PBG should exist at the time you are sold the unit. SLF will not exist yet (the building does not yet stand). For a ready-built villa, both should exist; if only PBG exists on a ready villa, ask why SLF is missing.
"The developer's brochure shows the PBG certificate. I asked about SLF and got told 'that's later, after handover'. Is that normal or a red flag?"
Buyer inquiry, Anteya CRM, 2025
For off-plan handovers, "SLF after handover" can be technically correct if the developer is mid-completion and SLF is genuinely pending the regency inspection cycle. It can also be cover for a building that the developer is delivering without intending to obtain SLF, which is a meaningful structural issue: a villa without SLF is legally not yet authorized for its declared use, regardless of how finished it looks. The contract should specify a deadline for SLF and a withhold-payment mechanism tied to it.
What happened to existing IMB certificates
IMB certificates issued before UU Cipta Kerja and PP 16/2021 generally remain valid for the structures they covered, but the certificate type is no longer issued for new buildings. Three practical implications for a Bali buyer:
- A villa built before 2021 with a valid IMB on file is, in principle, properly permitted under the regime in force at construction. The certificate stays on file at the regency and through the Dinas Pekerjaan Umum dan Penataan Ruang (Public Works and Spatial Planning Office).
- Any new construction, expansion, or change of use after 2021 requires PBG, not IMB. A pre-2021 villa that has since been expanded (extra floor, pool, ancillary structure) needs PBG for the new work even if the original structure was IMB-authorized.
- A villa that claims a "valid IMB" but was actually built or expanded after 2021 has a paper problem. The IMB on file does not cover the post-2021 work; PBG should exist for that.
The buyer-side question is not just "is there a permit?" but "does the permit on file match what was built and what is being sold?"
How a foreign buyer verifies PBG and SLF status
The single most useful tool is SIMBG itself. The portal at simbg.pu.go.id is the national registry; a registered PBG produces a SIMBG reference number that can be verified against the regency record. Public self-service lookup on the portal is limited; in practice the verification runs through a konsultan perizinan (permit consultant) or a Bali-based building-permit lawyer pulling the record from the regency. The notaris (Indonesian notary) handling the land transfer verifies the sertifikat tanah (land certificate) with BPN and clears the tax position, but does not routinely run SIMBG queries on the building permit. A buyer who assumes the notaris is doing permit due diligence is the buyer who gets surprised at SLF time. Ask explicitly whether SIMBG verification is in scope and engage a separate permit consultant if not.
Three layers of verification worth running before signing:
Layer 1: SIMBG record. PBG reference number, registration date, declared use, declared building size, declared parcel, current status. A document that does not surface in SIMBG is a problem regardless of how authentic the printed certificate looks.
Layer 2: Regency cross-check. PBG records sit with the regency Dinas PUPR and are fronted at the DPMPTSP (Dinas Penanaman Modal dan Pelayanan Terpadu Satu Pintu, one-stop investment service). In Badung the DPMPTSP is in Mangupura; in Gianyar at the regency complex in Gianyar town; in Denpasar at the Walikota complex on Jl. Surapati. A konsultan perizinan or a Bali-based building-permit lawyer can request written confirmation that the PBG is on file and current. This is slower but adds a layer beyond the portal.
Layer 3: Zoning compatibility. A PBG was issued under the Tata Ruang (RTRW spatial plan) in force at the time. If the parcel has since been re-zoned, the PBG remains, but new construction or expansion needs to fit the current RTRW. For off-plan buyers, the PBG should explicitly match the current spatial plan.
"How do I check the PBG myself before I send any money? The agent keeps sending me certificates but I have no way to verify which is real."
Buyer inquiry, Anteya CRM, 2025
The SIMBG lookup is the first thing to do. Ask for the PBG reference number, search it on the SIMBG portal, compare the declared parcel, declared building size, and declared use against what the developer is selling you. If any of the three diverge, surface that gap to the notaris and resolve it in writing before any money moves.
What it costs and how long it takes
PBG fees are set by the regency through a retribusi (retribution fee) formula that scales with declared building size, structure class, and location. The retribusi itself on a single residential villa in Badung, Gianyar, or Tabanan typically sits in the IDR 30-80 million range (roughly low four-figure USD). The all-in PBG cost a buyer hears about, low five figures USD, includes the licensed architect of record, structural and MEP (mechanical, electrical, plumbing) drawings, Tim Profesi Ahli review fees, and the konsultan perizinan or biro jasa who packages the SIMBG submission. The bare retribusi is a small slice of that total.
Statutory time for PBG issuance under PP 16/2021 is 28 working days from a complete application; the Bali reality in 2025-2026 rarely matches the statute. Practitioners in Badung and Gianyar routinely report 4 to 9 months from a clean SIMBG submission to PBG in hand, with Badung the slowest after the 2024 moratorium on new accommodations in Canggu, Seminyak, and the Bukit. Tabanan currently processes fastest among the high-volume regencies; Buleleng sees lower volume but a thinner consultant bench. Off-plan developers who quote the 28-day statute are quoting regulation, not regency reality. The shared Tim Profesi Ahli pool on Bali (a small bench of credentialed architects and structural engineers sitting on multiple regency panels) is frequently the bottleneck, particularly during the post-Nyepi and July-August surges.
SLF retribution is separate and substantially lower than PBG retribution. For a single residential villa, the SLF retribusi itself is typically IDR 5-15 million (under USD 1,000); the four-figure-USD bracket buyers often hear about is the consultant-of-record fee, as-built documentation package, structural certification, and MEP sign-off, not the regency fee.
Enforcement reality on Bali in 2023-2026
Bali enforcement of building-permit regulation has tightened materially since the 2023 cycle of regency-level moratoria and public-attention enforcement actions. Two patterns worth understanding:
Demolition orders on illegal construction. The most publicly visible enforcement action of the past two years was the July 2025 Bingin Beach (Pecatu, Badung) demolition wave, where dozens of cliff-side and beachfront warungs, small accommodations, and family-run guesthouses were torn down by the Badung task force. The primary driver was encroachment onto state-owned coastal land inside the sempadan pantai (beach setback), not solely missing PBG; many of the structures could not have been legalized with any permit because the underlying parcel was never alienable. The lesson for buyers is broader than PBG alone: enforcement now follows the weakest link in the title-zoning-PBG-SLF chain, and scale offers no protection. Family-scale operators were as exposed as commercial builds. Enforcement geography in 2024-2026 has clustered around Pecatu / Bingin / Uluwatu for coastal-setback and state-land violations, around Canggu / Berawa / Pererenan for unpermitted commercial accommodations breaching the 2024 Badung moratorium, and around Ubud / Tegallalang for villa-on-sawah cases where the parcel was never cleared from green-zone classification.
Administrative sanctions under PP 16/2021 and UU 28/2002. The sanction framework sits in PP 16/2021 (Article 346) and the underlying UU 28/2002 on Bangunan Gedung (Article 45). The headline figure in the Indonesian press is "up to 10% of construction value", but the practical structure is a tiered cascade: written warning, restriction of activity, temporary halt, revocation of PBG or SLF, retribution recalculation, and in serious cases ordered demolition. In Bali practice the 10% headline is rarely the actual outcome; far more common is denda (fine) plus retribution recalculation plus an ordered remediation cycle to bring the building into PBG compliance and obtain SLF. Outright demolition has been reserved for setback violations, coastal-land encroachment, and heritage-zone breaches. For a foreign buyer, the relevant question is not the maximum sanction but the legal status of a structure that cannot produce SLF on resale.
Anteya observation: in our deal flow, buyer due diligence on PBG and SLF has moved from a year-three concern to a pre-deposit concern over the 2024-2026 period. Buyers who waited for handover to verify permit status now routinely pull SIMBG records before the down payment, and the legal-review portion of buyer-side spend has expanded accordingly.
Off-plan: how PBG and SLF should appear in the contract
For an off-plan Bali villa, the contract should answer three permit-related questions explicitly:
PBG status at signing. Is the PBG already issued and on file in SIMBG, or pending submission? If pending, what is the developer's commitment on timeline and consequences if delayed?
SLF deadline post-handover. When does the developer commit to obtaining SLF after handover? What payment is withheld until SLF is in hand? In a clean contract, a meaningful slice of the final payment (commonly the last 5 to 10%) is held until SLF is delivered.
Permit-conformance warranty. A developer-side warranty that the as-built structure matches the PBG approval (size, use, location). If the developer over-builds (extra floor, larger footprint than approved), the SLF will not be granted on a non-conforming structure, and the buyer is left with a villa that cannot legally be authorized for use without retroactive remediation.
"We're buying off-plan. The developer says PBG is in process. How long until that becomes a problem if it doesn't come through?"
Buyer inquiry, Anteya CRM, 2025
The contract should set the answer. A PBG that does not arrive within a defined window after the developer's commitment date should trigger either an extension on agreed terms or a buyer-side termination right with deposit return. Without a contractual deadline, "in process" can stretch from months into years, and the buyer carries the regulatory uncertainty unilaterally.
Common red flags in Bali permits
The list, distilled from a few hundred client conversations and the patterns our team sees:
PBG reference number not searchable in SIMBG. Either the document is not what it appears to be, or the data has not been registered in the portal. Either case requires resolution before signing.
PBG declared use does not match what is being sold. Residential PBG sold as a daily-rental investment villa is a use mismatch; SLF will be issued for residential use, not commercial.
Pre-2021 IMB on a post-2021 building or expansion. The paper does not cover the work. New PBG is required.
No defined deadline for SLF in the contract. For an off-plan purchase, this is a deal-shaping omission.
Developer cannot produce the architect drawings reviewed by the Tim Profesi Ahli. PBG approval is grounded in approved drawings; if those drawings are not available to the buyer's lawyer, the structure of the approval is opaque.
"PBG in process" with no documented submission. A PBG that has actually been submitted has a SIMBG reference number from the day of submission. "In process" without a reference number means "not submitted".
Inflated retribusi quoted to buyer. The retribution fee is regency-set and traceable on the receipt. A developer who quotes a much higher figure to the buyer than the actual regency invoice is creating a margin layer.
Daily-rental villa with PBG only, no operating license. PBG approves the building; daily-rental operation also requires the Pondok Wisata license (held by an Indonesian citizen) or a PT PMA with KBLI 55193 Villa license on top. PBG alone does not authorise commercial short-stay use.
How this fits with zoning, ownership title, and operating license
Building permit (PBG + SLF) is one of four overlapping regulatory layers a Bali villa sits inside; getting one right without the others does not produce a legal short-stay rental:
- Title. Registered BPN land rights: Hak Milik (citizen freehold), Hak Guna Bangunan (HGB, commonly held by PT PMA), Hak Pakai (right of use, available to foreigners individually). Plus the contractual long-lease (Hak Sewa / leasehold, formalised as a notarial akta perjanjian sewa), which is not a registered BPN right but is the most common foreign-buyer structure on Bali. Governs ownership.
- Zoning. Tata Ruang / RTRW classification, set by the provincial Perda 3/2023 and the regency RDTR: kuning (permukiman, residential), merah muda (commercial / trade-services), hijau (sawah, agricultural and green-belt), KSPN tourism strategic zone, plus setback overlays such as sempadan pantai (coastal setback) and sempadan sungai (river setback). Governs permitted activity on the parcel.
- Building permit. PBG + SLF. Governs whether the structure itself is approved.
- Operating license. Pondok Wisata (citizen-held) or PT PMA with KBLI 55193 (Villa) on top. Governs whether the operating business is approved. Note: the KBLI 2025/2026 update (BPS Regulation 7/2025) introduces a refreshed villa-activity code; verify the code currently registered on the operating NIB. Pondok Wisata applications also require a rekomendasi (recommendation) from the local banjar (customary village unit) and often the desa adat, which is the practical gate that no online checklist captures.
A buyer who verifies title and zoning but skips PBG/SLF can find themselves owning a parcel they are authorized to use, but a building on it that is not authorized to stand.
"If the title is clean and the zoning is pink, does the PBG really matter that much, or is it more of a formality?"
Buyer inquiry, Anteya CRM, 2025
It matters. The structural risk of a missing PBG is not abstract: the regency has the authority to order corrective action up to demolition, and a building without SLF cannot resell cleanly because the next buyer's notaris will surface the issue at due diligence. Even if no demolition order ever comes, the discount required to sell a non-SLF villa onto the secondary market can be material. Treat PBG and SLF as part of the title chain, not as a formality.
Due-diligence checklist before sending a deposit
A short practical list, drawn from the deals our team has walked through:
Ask for the PBG reference number and verify it on SIMBG before signing. Refusal to provide the reference, or a reference that does not surface in the portal, is a deal-shaping signal.
Compare the PBG declared use, declared building size, and declared parcel against what you are being sold. Surface any divergence to the notaris.
For off-plan, require a contractual SLF deadline and a withhold-payment mechanism (often 5 to 10% of the final payment) that releases on SLF delivery.
For ready-built, require SLF to exist and be on file at the regency, not a verbal promise that it will follow.
If the parcel was re-zoned after PBG issuance, confirm with the notaris that any subsequent or planned work fits the current RTRW.
If daily rental is part of the use case, verify that the Pondok Wisata (citizen-held) or KBLI 55193 (PT PMA-held) operating license is in place and current. PBG is necessary but not sufficient for short-stay operation.
Engage a Bali permit consultant or building-permit lawyer (these are different roles from the transactional notaris and the contract-review lawyer) for any villa above the entry-level ticket. Buyer-side permit due diligence on a single villa typically runs IDR 15-50 million (roughly USD 1,000-3,000) and surfaces the structural issues before money moves.
This article is general information, not legal advice. Indonesian building-permit regulation changes, regency practice varies, and individual cases differ. Consult a licensed Indonesian notaris and a Bali-experienced building-permit lawyer for your specific purchase.
FAQ
Is IMB still valid in Bali in 2026?
IMB certificates issued before UU Cipta Kerja and PP 16/2021 generally remain valid for the structures they originally covered; the certificate type is no longer issued for new buildings. Any post-2021 construction, expansion, or change of use requires PBG, not IMB. A villa claiming "valid IMB" but built or expanded after 2021 has a paper problem that needs PBG to resolve.
What is the difference between PBG and SLF?
PBG (Persetujuan Bangunan Gedung) is the building approval issued before construction starts, confirming the proposed structure meets technical standards and zoning. SLF (Sertifikat Laik Fungsi) is issued after construction completes, certifying the finished building matches the PBG approval and is fit for declared use. PBG plus SLF together authorise a building to exist and operate legally.
How do I verify a Bali villa's PBG status?
Ask for the PBG reference number and look it up on the SIMBG portal (simbg.pu.go.id), which is the national building-management system. Compare declared parcel, declared building size, and declared use against what is being sold. The notaris handling the purchase routinely pulls SIMBG records as part of pre-contract due diligence; you can verify independently before sending money.
What happens if I buy a villa without PBG in Bali?
A villa without PBG is legally an unauthorized structure. Regency enforcement can range from administrative sanction (warning, ordered correction, retribution recalculation) to ordered demolition in serious cases, under PP 16/2021 (Article 346) and the underlying UU 28/2002. Beyond enforcement risk, the absence of PBG and subsequent SLF affects resale value because the next buyer's permit consultant will surface the gap, materially discounting the secondary-market price.
How long does PBG take to issue in Bali?
The statutory timeline under PP 16/2021 is 28 working days from a complete application; Bali practice rarely matches the statute. Practitioners in Badung and Gianyar routinely report 4 to 9 months from a clean SIMBG submission to PBG in hand, with Badung the slowest after the 2024 moratorium. Off-plan developers who quote 28 days are quoting the statute, not regency reality; "PBG in process" without a submitted SIMBG reference number means the application has not actually been filed.
Do I need PBG if I am buying a finished villa from a previous owner?
Verify the PBG (or pre-2021 IMB) and SLF on the existing structure as part of title-chain due diligence. The transfer itself does not require new PBG, but if the previous owner expanded or modified the building after 2021 without PBG, the buyer inherits the paper problem. The notaris verifies the land certificate; engage a separate permit consultant for the SIMBG side.
Can a PT PMA-held villa skip PBG?
No. PBG is a building approval that attaches to the structure, not to the title-holding entity. A villa owned by a PT PMA under Hak Guna Bangunan requires PBG before construction and SLF after completion just like a citizen-owned or leasehold villa. The PT PMA structure determines who can hold the land and operate the business; it does not change the building-permit requirement.
Anteya Research is the editorial function of Anteya Real Estate, a Bali-based investment property advisory. This article reflects patterns across roughly 5,300 buyer conversations logged in the Anteya CRM between 2023 and 2026, supplemented by first-hand observations from our Bali-based team.
