Nominee Agreements in Bali: What Perda 4/2026 Changed

What Perda 4/2026 actually does

Perda 4/2026 — its full title covers the control of productive land conversion and the prohibition of nominee land ownership — was signed by Governor Wayan Koster on 24 February 2026. It is a Bali provincial regulation, so it sits below national law but applies specifically and only within Bali province.

The change is a provincial prohibition with administrative sanctions, not a new crime. Nominee land structures were already unenforceable under Article 26(2) of the Basic Agrarian Law (UUPA), which voids any arrangement that gives a foreigner effective control of land registered to an Indonesian citizen. That remains a civil matter: the arrangement has no legal force if it is challenged. The Perda adds a ban on brokering one (Article 14, as DNT Lawyers quotes it) and administrative sanctions for breaching its rules (Article 20). Criminal exposure, where it exists, comes from national law — for example the penal code's offences of fraud and forgery, including a false statement in a notarial deed — and depends on the facts.

Coverage since February 2026, including an earlier version of this guide, said the Perda carries up to five years' imprisonment and an IDR 1 billion fine. Those figures are Article 72(1) of Law 41/2009 on the Protection of Sustainable Food Agricultural Land, which punishes converting protected farmland. A Perda's own criminal penalties were capped by Article 15 of Law 12/2011 at six months' detention or an IDR 50 million fine, and Law 1/2026, in force since 2 January 2026, leaves regional regulations with fines only.

Who is exposed now

The Perda's practical significance is less about the foreigner and the nominee, who were already exposed under national law, and more about who else it names. Intermediaries and facilitators who help arrange, document or execute a nominee structure fall within its prohibition — a wider net than most existing guidance on nominee risk describes, and one that reaches agents and consultants who have historically treated the arrangement as a routine service.

How big is the problem this targets

Estimating how much Bali property sits under nominee structures is difficult, because the arrangements are private and undocumented by design. A figure circulating in 2026 coverage — roughly 10,500 land plots, worth an estimated USD 10.4 billion, held via nominee structures — is attributed to an advocacy group known as the Indonesian Nominee Crisis Working Group (K3NI). That figure is repeated across several property-industry sources, but its underlying methodology was not published anywhere independently verifiable in this research. Treat it as evidence the practice is widespread, not as an audited statistic.

If you already hold land through a nominee

The Perda, as reported in the sources available for this article, does not clearly spell out how it treats structures set up before 24 February 2026. Whether its sanctions reach existing arrangements, as opposed to only new ones, was not confirmed in any source found. That question needs an Indonesian lawyer's answer for your specific situation before you do anything, including restructuring — unwinding a nominee arrangement badly can create new exposure of its own.

• Get advice from an Indonesian lawyer, not the agent who sold you the structure — their incentive is to keep you calm, not to tell you the exposure.
• Do not sign anything that purports to 'convert' the arrangement without independent legal review; a badly drafted conversion can itself look like a fresh nominee structure.
• The lawful alternatives are a leasehold, Hak Pakai if you hold a qualifying residence permit, or Hak Guna Bangunan through a PT PMA if the property earns rental income.

What is still unverified

The Perda's article numbers and sanctions above come from DNT Lawyers' reading of its text and from Bali press coverage of 25–27 February 2026, not from the regulation itself: we could not find its text on the provincial legal database (jdih.baliprov.go.id) or the national BPK database on 13 October 2026. Before acting on this regulation — restructuring, walking away from a deal, or anything else — verify the current text and its transitional provisions with an Indonesian notary or lawyer.

Common questions

Sources and further reading

• Law 5/1960, the Basic Agrarian Law, art 26(2) (JDIH BPK)
• Law 41/2009 on protecting sustainable food farmland, arts 72–74 (JDIH Kemenkeu)
• Law 1/2026 on the adjustment of criminal penalties (JDIH BPK)
• Kilas Bali, 25 February 2026: Governor Koster enacts Perda 4/2026
• DNT Lawyers: reading Perda 4/2026's nominee ban (Indonesian)

Related guides

• Leasehold vs Freehold in Bali and Indonesia (2026): Who Can Own
• Due Diligence Before Buying Property in Bali: 2026 Checklist
• Bali property scams: how deals actually go wrong
• Hak Pakai: the right-to-use title foreigners can hold

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