Is an existing villa on former rice land at risk?

It depends on the regularity of the original conversion: a permitted, documented conversion holds; an irregular one is now exposed to the sanction apparatus, demolition included. The document chain (permits, zoning, titles) makes the difference.

Does the Perda change anything for PT PMA holding?

No — it strengthens that route: a PT PMA holds in its own name (HGB), whereas the nominee, void since 1960, now falls under a reinforced enforcement regime that also targets intermediaries.

Bali's Perda 4/2026: rice-field conversion moratorium, nominee schemes under criminal sanction

Perda 4/2026: Bali locks down productive land — and criminalises the nominee

Having closed the nominee route, Bali closes the converted-rice-field route: Perda 4/2026 turns two grey zones into forbidden ones — demolition and prison attached.

1 September 20264 min readLa rédaction — Wealth Management · Global Real AssetsIndonésie (Bali)Facts checked on 1 September 2026Subject to regulatory updates

Key points

Provincial Regulation (Perda) No. 4 of 2026, signed on 24 February 2026 by Bali's governor, controls the conversion of productive land (rice fields, horticulture, plantations) and expressly prohibits nominee land holding.
The text organises a moratorium on rice-field conversion permits until the mapping of protected agricultural land (LP2B) and protected rice fields (LSD) is finalised.
Administrative sanctions are graduated and far-reaching: written warning, activity suspension, site closure, permit revocation, demolition, land restoration, incentive withdrawal, fines.
Criminal sanctions attach in accordance with national legislation — the nominee prohibition, already void under the 1960 agrarian law, gains a provincial enforcement regime that also targets intermediaries.
For an investor the practical consequence fits in one sentence: the "convertible" farm plot no longer exists as a bet — zoning due diligence (RDTR) becomes the only road.

What truly changes: enforcement

Nominee holding had been void since 1960; wildcat conversion was already irregular. Perda 4/2026's novelty is not the prohibition, it is the apparatus: control powers, community participation, funding, sanctions graduated up to demolition — and a criminal limb aimed at the ecosystem, intermediaries included. Bali moves from written law to applied law; the gap between the two fed many a structure.

The moratorium: rice fields are no longer a land bank

Until the LP2B/LSD mapping is finalised, rice-field conversion permits are frozen. Buying a paddy "for later" means parking capital in an asset whose buildable use depends on a future administrative decision — the opposite of an investment thesis. Our RDTR zoning text details the method: designation first, charm second.

Our reading

The house has never structured through nominees — our 2026 PT PMA text already explained why that bet was lost in advance. Perda 4/2026 delivers the provincial confirmation, with the enforcement toolkit that was missing. The Bali market that emerges is narrower and healthier: fewer "possible" plots, more safe ones. Good news for those who structure properly — very bad news for the rest. Our presence in Bali was built on that second market — the safe plots.

General information, verified at publication date. Rules change: every transaction calls for licensed local advice.

Journal articles are published for general, educational purposes. They constitute neither legal, tax or financial advice, nor an offer. Every situation calls for the analysis of licensed advisers.