Three abbreviations determine whether your building is legal. One describes today's building permit, the second — its predecessor, the third — the right to the land beneath the building. If any of them is missing, the problem is not documentary — it is real.
PBG — today's building permit
PBG (Persetujuan Bangunan Gedung — building approval) is the permit regime introduced by Government Regulation No. 16 of 2021, which replaced the old regime under Government Regulation No. 36 of 2005. PBG confirms that the project complies with technical standards, zoning, and spatial planning requirements. Applications are submitted electronically through the SIMBG system of the Ministry of Public Works.
PBG is a prerequisite for the issuance of the SLF (Sertifikat Laik Fungsi) — the certificate that the building is fit for use. Construction may begin after the issuance of the PBG, but if within a certain period — usually six months — the technical service is not notified of the start, the permit may be revoked.
IMB — the old permit regime that remains valid
IMB (Izin Mendirikan Bangunan) is the predecessor, issued under Government Regulation No. 36 of 2005. It does not lose its force. A building constructed under a valid IMB remains legal and the IMB continues to be recognized. The difference lies in the transition:
- if an IMB was issued but construction has not yet begun — a PBG is submitted;
- if the building has already been constructed and has not been modified — the old IMB is used, including when renewing the SLF;
- new projects go through the PBG regime.
HGB — the right to the land beneath the building
Hak Guna Bangunan is the right to build on land, held by an Indonesian company — including a PT PMA. The term is 30 years, plus up to 20 years of extension and up to 30 years of renewal — up to 80 years, under Government Regulation No. 18 of 2021. The extension is not automatic: each action is submitted and approved, and the right requires the land to be used in accordance with its designation. If the HGB is not renewed on time, the right reverts to the state. That is why the extension is submitted months, not weeks, before expiry.
Why the check is no longer a formality
In recent years, the regulator in Bali has visibly tightened control. During July 2025, 48 illegal buildings were demolished on Bingin beach — mostly villas and establishments erected without permits on communal land in a green zone. At the end of 2025, 30 villas in Canggu were stopped because they stood on protected rice land.
By Governor's Instruction No. 5 of 2025 (December 2, 2025), the issuance of permits for the conversion of agricultural land is frozen until its final designation as protected. From 2026, Provincial Regulation (Perda) No. 4 of 2026, signed on February 24, 2026, prohibits the conversion of protected agricultural land and its nominal acquisition, with sanctions including demolition of the building to restore the function of the land.
For illegal conversion of protected agricultural land, National Law No. 41 of 2009 provides for sanctions of up to 5 years of imprisonment and a fine of up to 1 billion rupiah. For violations of spatial planning rules, Law No. 26 of 2007 provides for up to 3 years and up to 500 million rupiah. By the end of 2026, the implementing regulations under the ordinance are being drafted — the specific case is checked with a notary.
Checklist before purchase
- Land certificate — the type (SHM, HGB, or Hak Pakai) and authenticity, verified at BPN, not from a copy.
- Zoning — an official parcel reference (ITR/KKPR), not a color from a public map.
- Protected agricultural land — a check with the relevant agricultural service and with the municipality (whether the parcel is LP2B/LSD).
- PBG or a valid IMB for the building, in the name of the current owner.
- SLF — fitness for use, if the building will be inhabited or rented out.
- Encumbrances, mortgages, and unpaid annual taxes (PBB) on the title.
- If it will be rented out short-term — a lodging and registration license (NIB) in the OSS system.
This text describes the general framework as of the time of publication and is not legal advice. Ordinance numbers and rules change frequently. Before committing funds, each document is checked specifically with a licensed Indonesian notary (PPAT) or lawyer.
If you want us to check the documents for a specific property before signing — request a check.
