Yes. A foreign investor can own 100% of a company operating inside KEK Sanur, Bali’s health and tourism Special Economic Zone, for the large majority of activities the zone was built to attract: hospitals, specialist clinics, hotels, restaurants, MICE services, and most professional and support services. The vehicle is a PT PMA (Perseroan Terbatas Penanaman Modal Asing), Indonesia’s foreign-owned limited liability company, wholly foreign-held inside the zone with no mandatory local shareholder for any open sector.
The conditions are short: a national closed list of six sectors applies everywhere, a handful of small-scale activities stay reserved for Indonesian MSMEs, professional practice (a doctor treating patients) is licensed separately from company ownership, and a PT PMA needs a minimum investment above IDR 10 billion per business classification. None of this blocks full foreign ownership; it shapes how you structure it.
Where the 100% rule comes from
Foreign ownership in Indonesia stopped being a maze of sector caps in 2021. The Job Creation Law and the Positive Investment List (Presidential Regulation 10/2021, amended by 49/2021) opened every sector to 100% foreign investment by default unless closed, MSME-reserved, or conditional; hospitals, once capped at 67% foreign equity, are now open to 100%. Two regulations shape the zone itself: Government Regulation 40/2021 sets how SEZs operate, including fiscal facilities and one-stop licensing through the Administrator, and Government Regulation 41/2022 established KEK Sanur, 41 hectares on Sanur’s beachfront developed by PT Hotel Indonesia Natour under the state-owned InJourney group. Its anchor, Bali International Hospital, built by state holding IHC with an announced Mayo Clinic collaboration, began operations in 2025, adding fiscal incentives, one-stop licensing, and foreign property rights on top of the nationwide 100% rule.
What’s open to 100% foreign ownership inside the zone
Health services are the zone’s reason for existing: general and specialist hospitals, specialist clinics (dental, fertility, orthopaedics, oncology support), diagnostic imaging and laboratories, rehabilitation centres, and wellness facilities can all sit under wholly foreign-owned companies. Ownership of the company is open; the clinical licences it must then hold, facility and practitioner licences, are a separate track, covered below.
Hospitality and MICE follow the same rule: hotels, restaurants, cafés, spas, and convention and exhibition services are fully open, and the zone’s masterplan leans on them, with a redeveloped Bali Beach Hotel, a convention centre, and retail precincts around the hospital core. Supporting services, consulting, patient coordination, tour operation, health-tech development, training, and property management, are broadly open too. Qualifying tech startups inside an SEZ may also be exempted from the IDR 10 billion minimum investment threshold.
What stays restricted, inside and outside the zone
- The national closed list. Six sectors are closed to all private investment everywhere: narcotics cultivation, gambling and casinos, fishing of endangered species, coral harvesting, chemical weapons production, and certain ozone-depleting chemical industries. SEZ status does not reopen any of them.
- MSME-reserved lines. Small-scale retail and micro-scale services remain reserved for Indonesian cooperatives and MSMEs, or need a formal partnership. Check the specific KBLI classification before assuming a retail component is open.
- Professional practice licensing. Owning 100% of a clinic does not license anyone to practise medicine. Clinicians need Indonesian registration; foreign doctors can now practise under the 2023 Health Law, which eased the specialist pathway, but licensing sits with the individual, not the shareholders.
- Land title. No foreigner or PT PMA can hold freehold (Hak Milik) land anywhere in Indonesia. Zone companies operate on Right-to-Build or Right-to-Use titles instead. Our guide to legal ownership structures for KEK Sanur investments covers how these titles layer with the corporate entity.
The vehicle: setting up the PT PMA
A PT PMA needs at least two shareholders (either can be foreign), a director, and a commissioner, plus an investment plan exceeding IDR 10 billion (roughly USD 600,000-650,000) per KBLI classification, excluding land and buildings. Paid-up capital rules are set separately and change periodically, so confirm the current OSS figure before incorporating. Licensing runs through the OSS risk-based system, with the KEK Sanur Administrator coordinating zone entry, faster than assembling regional permits piecemeal. The KBLI code you select determines your investment exposure and licensing risk, so get it right before you incorporate. Our walkthrough of the PT PMA setup process for KEK Sanur covers name reservation, the deed of establishment, and OSS licensing.
A realistic sequence: confirm the KBLI status, structure the shareholding, incorporate through OSS, engage the Administrator for zone entry and incentives, apply for fiscal facilities before operating, then secure sectoral licences and work permits. Budget three to six months for a services entity; clinical facilities take longer.
Getting the structure right the first time
KEK Sanur Investment is a curation and advisory desk under Juara Holding Group, operating in Bali since 2015. We do not sell incorporation packages ourselves: we scope your plan, flag the restrictions for your activity, and arrange the setup through the group’s licensed legal and business-investment desk, which handles the notarial, OSS, and licensing work end to end. Send us the activity you have in mind and we will map it to the current rules before you commit to a structure.
Reach the desk on WhatsApp at +62 811-3941-4563 or by email at bd@juaraholding.com.
This guide is general information, not financial or legal advice. Verify current regulations with licensed advisors.