What off-plan means at this level
An off-plan purchase is a commitment to a house that exists on paper, on land that may still be bare. The buyer pays in stages while it is built and takes the final deed once it is finished. For the buyer it brings a set of risks that ordinary resale stock does not carry, chief among them that the house is late, different from what was sold, or built without the approvals it needs.
Timelines are the first thing to read carefully. Smaller villa projects are commonly sold on a build of ten to twelve months once work begins. Bigger or more involved schemes are reported at nine to eighteen months, and some sources cite eighteen to twenty-four for the largest. These are figures from developers and agencies, not a regulatory timeline, and none of them binds anyone unless it appears in the contract.
Much new supply is small. The 2026 report by Horwath HTL and C9 Hotelworks found that about 84 per cent of new villa developments comprise fewer than 30 units, and that villas now make up about 18 per cent of Bali’s accommodation supply, up from 13 per cent a year earlier. A small project can be very well run, but it also means the builder’s balance sheet and track record matter more than the render.
Permits before progress
PBG, Persetujuan Bangunan Gedung, took the place of the IMB across Indonesia under the reforms that followed the Job Creation Law of 2020. It is the approval to build, and the SLF, Sertifikat Laik Fungsi, is the certificate issued once a completed building meets the standards for its intended use. Both run through the online SIMBG system. A PBG application needs, among other things, the identity of the owner or applicant, details of the licensed planning provider including an architect holding an STRA, and technical data covering architecture, structure and mechanical, electrical and plumbing design.
PP 28/2025 places KKPR, the spatial-use approval, alongside environmental approval and the PBG and SLF as basic requirements for business licensing. Where a regency has an integrated detailed spatial plan (RDTR), a Konfirmasi KKPR issues automatically through OSS. Outside that coverage a Persetujuan KKPR requires registration, examination and assessment. Badung and Denpasar were reported at full RDTR coverage as of July 2024, Gianyar at 65.40 per cent and Tabanan at 15.93 per cent, so a project on the Tabanan coast may sit on the slower route.
If the house will be let to guests, the permits must suit that use. The licensing chain reported for a foreign-owned rental business runs through a tourism-zone location, a PBG for commercial use, then an SLF, then a verified business identification number (NIB) carrying the right KBLI code. Note that a PBG for a private residence is not the same document.
Completion risk on the record
The enforcement record of 2025 and 2026 shows where projects fail. On 9 January 2026 Satpol PP Badung sealed a land-clearing site in Desa Adat Kampial, Kuta Selatan, which the operator said was for a planned resort. It had no PBG and no environmental document and had carried on after a third warning letter. On 1 and 2 October 2025, in Karangasem, a provincial DPRD special committee and Satpol PP halted work at a four-hectare real-estate project still in its permit process, and at a Padangbai resort whose groundwater permit, PBG and SLF were still in process and which stood about three metres from a riverbank where five metres is required. In mid-2026 a Badung DPRD special committee reported indications of spatial and permit violations at several tourism projects on the Pecatu cliffs and recommended temporary closure of the buildings concerned. High-end and branded projects have not been exempt.
Policy has tightened around land use as well. From 16 September 2025 the provincial government applied controls on converting productive farmland and water-catchment areas to commercial use, which the governor described as strict control rather than an outright moratorium. Six regencies, among them Tabanan, Karangasem and Klungkung, agreed to stop pushing new hotel and restaurant development from 2026, though the legal form of that agreement was not confirmed. Bali’s Perda 4/2026 exposes conversion of protected farmland (LP2B) into villas to criminal prosecution. A project that depends on converting such land carries a risk no contract clause can remove.
One property guide, writing in May 2026, put the consequence plainly. Every villa needs a PBG, and a buyer who does not verify it can inherit an illegal structure.
Stage payments and contracts
The documents follow the ordinary sequence, stretched over the build. A PPJB, the preliminary agreement of sale, is signed before a notary at the outset. Once the house is complete, the final deed, an AJB or a grant of HGB or Hak Pakai, is signed before the PPAT. For a leasehold villa, the notarised lease deed is the instrument, and BPN holds no record of it.
Payment is often milestone-based for off-plan stock. The research found no standard schedule of percentages, so the schedule is whatever the contract sets. Escrow is not required by Indonesian property law. It is a practice the lawyers can negotiate, and whether stage payments sit with the developer or in a controlled account is one of the most consequential points in the agreement.
Points worth putting to your lawyer include what triggers each payment and who certifies it, what happens if the PBG is refused or delayed, how late completion is treated, what specification is fixed in the contract, and, for a lease, when the lease term begins and what it says about the building at expiry. No statute decides what becomes of the building when a lease ends. The lease itself does.
Tax on a new build
A new villa bought from a VAT-registered developer carries PPN. Below Rp 30 billion, the effective rate is 11 per cent under PMK 131/2024 and PMK 11/2025, which took effect on 4 February 2025 for deliveries from 1 January 2025. At Rp 30 billion or more, about US$1.7 million at the September 2026 rate, the full 12 per cent applies together with PPnBM at 20 per cent, under PMK 15/2023 as amended by PMK 96/2023.
PPh 22 at 1 per cent, collected by designated corporate sellers, applies to houses with land above Rp 30 billion or with 400 square metres of building area, under PMK 92/PMK.03/2019. A large villa can fall within it on floor area alone. Whether that rule has since been consolidated into a later regulation was not checked.
PMK 90/2025 relieves PPN in full on the first Rp 2 billion of new homes priced at no more than Rp 5 billion and handed over in 2026. That cap sits at the very bottom of what a foreigner may buy under Hak Pakai, and whether the 2026 version keeps the earlier wording on foreign eligibility was not confirmed. BPHTB, the buyer’s acquisition duty, is due as on any acquisition of a registered right, at a regency rate of up to 5 per cent.
What to verify before the first payment
Build cost gives a rough test of a developer’s price. One dated source, updated 22 August 2026, put a premium build at between US$1,400 and US$2,000 a square metre for construction alone, and suggested allowing another 15 per cent or more, up to a quarter, for the architect, permits, pool, landscaping and furniture.
Before money moves, your notary and lawyer should have confirmed the land’s certificate and zoning, the KKPR, the PBG and its intended use, the environmental document, and the developer’s right to sell or lease the plot. Viewings of completed work by the same builder, which we can arrange and accompany, are a useful complement to the paperwork, never a substitute for it.