Part of the series: KBLI 2025
- KBLI 2025 Scale Restrictions in OSS and Why PT PMAs Feel the Impact First
- KBLI 2025: Real Estate and Accommodation
- Why Governments Set the Rules and Markets Make Them Work: Indonesian Government Objectives of KBLI 2025
- Foreign Ownership and Padel in Indonesia: the KBLI Codes a Foreign Company can Register
Padel is the fastest-growing sport in Indonesia. The clubs that drew its early players were built by foreign founders, who combined a flagship sports facility, a franchise offer, a coaching academy, and a retail line under a single brand. The rules on foreign ownership of padel in Indonesia now turn on one classification code and one provincial measure. The code that operates a padel court, KBLI 93119, offers the large-enterprise scale at which a foreign-owned company registers, and its low risk level brings it within the Bali closure on new foreign-owned registrations.
A foreign-owned company, in Indonesian law a Perseroan Terbatas Penanaman Modal Asing (PT PMA), can register three roles, each read on the live Online Single Submission (OSS) system, Indonesia’s risk-based business licensing platform. Outside Bali, it can register and run the padel facility itself. Anywhere in Indonesia, it can act as the brand and intellectual property licensor and run the coaching academy. In Bali, the playing facility of a new club remains with a company that Indonesian shareholders own and control, because of the provincial closure rather than any rule reserving the sport to Indonesian citizens.
01 · The position now
What a foreign company can register today
Dedicated padel clubs opened in Bali from 2022 and spread across the island and into Java over the seasons that followed. The clubs that drew the early players were built by foreign founders, who carried both the capital and the operating method from outside Indonesia.
A foreign-owned company can register three roles in the licensing system. The first is the padel facility, under KBLI 93119, Other Sports Facility Management, read on OSS on 12 November 2026: its scope names padel courts, and it shows the large-enterprise scale at a low risk level, with an NIB issued under the authority of the regent or mayor. The second is the brand and intellectual property licence, under the intellectual property lease code (KBLI 77400). The third is the coaching academy, under the sports and recreation education code (KBLI 85510). The last two were read on OSS in August 2026, each showing the large-enterprise scale and naming the foreign-owned company as an eligible party licensed at ministerial level.
The facility position changed between our August and November readings. In August 2026 the sports-facility codes showed no configured scale, so a foreign-owned company had no scale to register a facility against. By November 2026, OSS had configured KBLI 93113, 93114 and 93119 at all scales, including large enterprise. The sports-club codes (KBLI 9312 group) still showed no configured scope, so a membership club registers with a domestic company for now.
Location now decides the structure. Outside Bali, a foreign-owned company can hold the facility together with the brand and the academy. In Bali, a new club places the facility with a company that Indonesian shareholders own and control, and the foreign-owned company holds the brand and the coaching. An operator already trading through a foreign-owned company confirms which of its codes the system will accept, and a prospective investor sets the structure to the registrable codes from the start.
02 · The classification
How KBLI 2025 classifies padel
KBLI 2025 has no code titled for padel, and the OSS scope for KBLI 93119, Other Sports Facility Management, now names padel courts expressly, together with pickleball, squash, gateball and hyrox. The court and field codes, KBLI 93113 and 93114, cover arena sports and field sports such as tennis, badminton and basketball. The registrar assigns the operative code at registration, so the code for a specific club is confirmed against the activity it conducts in practice.
The hierarchy runs from the Arts, Sports and Recreation category, through Sports, Entertainment and Recreation Activities, into Sports Activities, and then into two branches. Sports Facility Management covers the venue, and carries the court and field codes. Sports Club Activities covers the membership club. The education branch, which covers coaching, belongs to a separate part of the classification under Education.
| KBLI 2025 | Activity | OSS configuration at the position date | Position for a foreign-owned company |
|---|---|---|---|
| 93114 | Field facilities (golf, badminton, volleyball, basketball, tennis) | Large-enterprise scale configured; court sports medium-low risk, golf high risk | Open; court sports closed to a new foreign-owned company in Bali |
| 93113 | Court and arena facilities | Large-enterprise scale configured; medium-high risk | Open, Bali included |
| 93119 | Other sports facility management, including padel, pickleball and squash | Large-enterprise scale configured; low risk; NIB | Open outside Bali; closed to a new foreign-owned company in Bali |
| 9312x | Sports club activities (membership club) | No scope configured | No large-enterprise scale to register against |
| 85510 | Sports and recreation education (coaching, instruction) | Large-enterprise scale configured; high risk; PMA parameter present | Open; the foreign-owned company registers, licensed by the Minister of Education |
| 77400 | Lease of intellectual property and similar products, not copyrighted works, including franchise-system operations | Large-enterprise scale configured; low risk; PMA parameter present | Open; the foreign-owned company registers, licensed at ministerial level |
NOTES:
Facility and club positions read on live OSS on 12 November 2026; the education and intellectual property codes read in August 2026. The OSS scope for KBLI 93119 names padel courts expressly.
The facility codes (KBLI 9311 group) were configured between August and November 2026. The club codes (KBLI 9312 group) showed no configured scope in November 2026 and should be re-read before any filing.
The education code (KBLI 85510) and the intellectual property lease code (KBLI 77400) were fully configured and named the foreign-owned company as an eligible party.
03 · The open codes
The two codes a foreign company registers
The intellectual property lease code (KBLI 77400), lease of intellectual property and similar products not copyrighted works, is open to a foreign-owned company. Its OSS page shows the large-enterprise scale, a low risk level, and the foreign-owned company as a party licensed by the relevant Minister or Head of Agency. This code covers the brand, the name, the operating system, and the intellectual property licensed to an operator in exchange for a fee. The code description itself references business operations under the franchise system.
The franchise regime applies on top of the code
The intellectual property lease code (KBLI 77400) is the classification for the licence. Where the arrangement meets the definition of a franchise, the Indonesian franchising regime applies separately and on top of the code. It requires the franchisor to lodge a franchise registration certificate (Surat Tanda Pendaftaran Waralaba, or STPW), to provide a franchise prospectus, and to meet disclosure and local-content obligations, under the current franchising instrument, which should be confirmed before the relationship is documented. KBLI 77400 is the licensing code; the franchising regime governs the franchise relationship built on it.
The sports and recreation education code (KBLI 85510) covers the coaching academy. Its OSS page shows the large-enterprise scale, a high risk level, and the foreign-owned company as a party licensed by the Minister of Education. A high risk level means a full business licence with verification rather than a self-declared certificate. No foreign-ownership percentage is recorded against the code on the classification platform, and the education field is not placed on the investment-list schedules that cap or reserve foreign ownership under Presidential Regulation 10 of 2021 as amended.
KBLI 85510 draws one boundary. It routes training delivered by a sports club to the club codes, and training delivered inside a fitness centre to the facility codes. KBLI 85510 fits a standalone coaching academy that operates as an education provider. Coaching delivered inside the club itself belongs to the club, which the local party runs.
Each pillar carries its own capital plan
A foreign-owned company registers at the large-enterprise scale, and each five-digit code carries its own investment plan under Minister of Investment and Downstreaming Regulation No. 5 of 2025. The plan for each code exceeds IDR 10,000,000,000 (ten billion Indonesian Rupiah), excluding land and buildings, with minimum paid-up capital of IDR 2,500,000,000 (two billion five hundred million Indonesian Rupiah). A vehicle carrying both KBLI 77400 and KBLI 85510 therefore plans an investment against each code, rather than a single figure for the pair.
Equipment supply divides along the line in Indonesian trade rules. Wholesale and import of equipment, covering rackets, balls, court systems, and surfacing, is open to a foreign-owned company at the large-enterprise scale, subject to the capital rule and an importer identification number for cross-border supply. Retail falls on the other side of that line. The pro shop that sells to players over a counter is a retail activity, and retail is among the fields restricted for foreign investors, so the pro shop registers with the local operator.
04 · The national position
Where a foreign company can register a facility
Nationally, a foreign-owned company can now register a padel facility under KBLI 93119 at large-enterprise scale. The Bali measure then closes the same code to a new foreign-owned company in Bali. Neither position reserves the sport to Indonesian citizens.
The national position follows the OSS configuration. In August 2026 the sports-facility management codes (KBLI 9311 group) and the sports-club codes (KBLI 9312 group) showed no configured large-enterprise scale. By 12 November 2026, OSS showed KBLI 93113, 93114 and 93119 at all business scales, with no reservation to domestic investors or to micro, small and medium enterprises, while the club codes still showed no configured scope. The investment list under Presidential Regulation No. 10 of 2021, as amended by Presidential Regulation No. 49 of 2021, does not place these codes on a closed, conditional, reserved or partnership schedule. A foreign-owned company registering KBLI 93119 plans an investment exceeding IDR 10 billion for the code at each location, under the capital rule set out above.
Outside Bali, a foreign-owned company can therefore own and run a padel facility under its own registration, and a membership club remains with a domestic company until the club codes are configured.
05 · Bali
The provincial block and where foreign capital concentrates
Bali warrants separate treatment, for two reasons of its own. First, it draws the largest concentration of foreign padel investment, and most foreign-founded clubs operate there, so most of the affected operators and prospective franchise investors are in Bali. Second, it adds a provincial closure on top of the national configuration.
The Governor of Bali letter numbered B.27.000/642/PM/DPMPTSP, dated 28 January 2026, closed new foreign-company registration in low-risk and medium-low-risk classifications across the province. The Ministry of Investment applied the request inside OSS, and the block took effect in May 2026. KBLI 93119 is low risk and the court sports scope of KBLI 93114 is medium-low risk, so the Bali measure closes both to a new foreign-owned company in Bali, independently of the national position. A PT PMA that registered and licensed its padel facility in Bali before the closure took effect holds a registration granted under the earlier rules, and should confirm its current OSS record before adding a location or a code.
One code remains open in Bali. The court and arena code (KBLI 93113) shows a medium-high risk level, which the Bali measure does not close. Its scope covers arena facilities such as swimming, bowling and ice hockey venues, and a padel club falls under KBLI 93119, which names padel expressly. A padel club registered under KBLI 93113 to avoid the Bali measure would describe an activity it does not conduct, and the registration would be exposed to correction.
Bali enforces this actively. The provincial enforcement through 2025 and early 2026 produced administrative sanctions against over 400 foreign companies, and a substance-based enforcement programme runs from June 2026. Bali also regulates the land directly, through Provincial Regulation No. 4 of 2026, which the structure section below addresses.
A foreign brand that licenses to a network of new clubs across Bali follows the split structure. Each Bali club operates as a company owned and controlled by Indonesian shareholders that registers the facility code, the foreign brand licenses under KBLI 77400 and coaches under KBLI 85510, and the local company owns the facility. Outside Bali, the same brand can own and run its clubs through its own foreign-owned company. The provincial block reinforces that split for the lower-risk codes, and a prospective franchise investor in Bali confirms the operating entity’s code and its configuration before committing capital.
06 · The franchise relationship
Which party registers which function
Outside Bali, the foreign-owned company can register the facility under KBLI 93119 alongside the brand under KBLI 77400 and the academy under KBLI 85510. In Bali, for a new club, the foreign-owned company owns the brand and the operating system, with the franchising regime governing the franchise relationship, and provides the coaching method, while a company that Indonesian shareholders own and control runs the facility. Where a membership club is used, a domestic company runs it under the sports-club codes. The registrable positions decide the role of each party.
A PT PMA that registered and licensed a padel facility in Bali before the closure took effect in May 2026 is in a different position from a new entrant. The closure applies to new registrations, and the existing registration was granted under the rules in force at the time. The operator should confirm its current record on OSS, including the conversion of its code to KBLI 2025, and should check the position before adding a location or a code, because either step requires a new registration.
For a prospective franchise investor, the structure depends on which party the investor is. A foreign investor taking a franchise acts as the franchisor and brand party, or invests through the brand and academy vehicles, with a locally controlled operating partner operating the facility. A local investor taking a franchise registers the operating entity under the facility codes as a domestic company, and operates the club under licence from the foreign brand.
| Function | KBLI 2025 code | Party responsible | Note |
|---|---|---|---|
| Brand, name, operating system | 77400 intellectual property lease | Foreign-owned company | Franchising regime and STPW registration apply on top where a franchise |
| Coaching method and academy | 85510 sports and recreation education | Foreign-owned company | Full licence; licensed by the Minister of Education |
| Court and facility operation | 93119 (padel) | Foreign-owned company outside Bali, and existing pre-May 2026 Bali registrations; local operating company for a new Bali club | Large-enterprise scale configured, low risk (OSS, 12 November 2026); Bali closure applies to new registrations |
| Membership club | 9312 sports club codes | Local entity | No scope configured in November 2026; re-read on live OSS |
| Fee-based management | Contracted output of the franchise and academy | Documented agreement between the parties | Priced at arm’s length |
A prospective franchise investor verifies four points before committing capital:
- The first is the OSS configuration and eligibility of the operating entity’s codes at the date of filing.
- The second is the franchise registration and prospectus, where the arrangement is a franchise.
- The third is the genuine local ownership and capitalisation of the operating entity, tested against the beneficial ownership register.
- The fourth is the tax treatment of the fee flows, set out below.
07 · The structure that works
The owner-principal structure and its controls
In Bali, and wherever an investor chooses a local operating partner, the structure follows the owner-principal model, one of our standing methods for accommodation and now for sports facilities. The locally controlled entity owns and operates the facility. The foreign-owned company owns the brand and intellectual property licence under KBLI 77400 and runs the coaching academy under KBLI 85510. The brand, the system, the coaching method, and a fee-based management role flow to the local operator under separately documented agreements. Each function carries its own contract, its own fee, and its own code.
A locally controlled entity is defined by its corporate mechanics rather than by intent. Control means the Indonesian party owns the shares, appoints the board and directors, controls the signing authority, and retains the veto over reserved corporate actions. The local operator must be genuinely capitalised to own and build the facility. Where the foreign-owned company provides funding, the funding takes the form of an arm’s-length loan or a service and supply arrangement on commercial terms, documented as such, rather than a route through which control returns to the foreign party.
TraceWorthy tests a structure across four gates. The actor gate asks whether the real economic party is the registered party. The asset gate asks whether the land and lease platform fits the model. The building gate asks whether the building record matches the actual use. The business-activity gate asks whether the real activity matches the correct code under a lawful actor.
The nominee shortcut, and the Bali land regulation
The shortcut to avoid is the nominee. A structure that registers the operating entity or the facility land to Indonesian names while a foreign sponsor directs it and takes the economics meets several controls. Article 33 of the Investment Law (Law No. 25 of 2007) voids any agreement that shares or assets are owned for another person. The beneficial ownership register under Presidential Regulation No. 13 of 2018 requires the real controlling party to be disclosed. The Basic Agrarian Law (Law No. 5 of 1960) reserves freehold (Hak Milik) to Indonesian citizens. In Bali, Provincial Regulation No. 4 of 2026, on the control of productive land conversion and the prohibition of nominee land ownership, operationalises that reservation at provincial level. It defines a nominee arrangement as an agreement appointing a person to own or manage land rights in the name of a foreign national, and it prohibits any person from acting as an intermediary or a facilitator that causes a foreign national to control land through a nominee. Its own sanctions are administrative, and extend to written warnings, suspension of activity, closure of the location, revocation of permits, demolition, restoration of the land, and administrative fines, and it preserves criminal sanctions under higher national legislation. A nominee facility therefore carries no enforceable foreign claim, and in Bali exposes the parties, their advisers, and any facilitator to administrative closure and permit revocation, and to criminal liability under national law.
The fee flows carry tax consequences
The structure is a set of cross-border and related-party fee flows, and it is not tax-neutral. A royalty paid to the foreign licensor under KBLI 77400 attracts withholding at the domestic rate or the applicable treaty rate. Coaching and management fees carry their own withholding and value-added tax treatment. Each charge is a related-party transaction, so Indonesian transfer-pricing rules require the fees to be set at arm’s length and documented. The fee income is taxed at source, and the structure should be modelled net of that treatment.
The framework now divides the sector by location. Outside Bali, a chain can hold its venues in its own foreign-owned company under KBLI 93119. In Bali, a chain that wants a single brand across new venues places them with companies that Indonesian shareholders own and control, and concentrates the foreign-owned company on the brand and the coaching. Existing foreign-owned clubs should have their registered codes reviewed against the current OSS position.
08 · The next step
A worked outline and a structure review
For a new club in Bali, an anonymised worked outline sets out the lawful structure, naming each party, the code it registers, and the agreements that connect them. A locally controlled operating company owns the land or a lawful lease and the courts, registers under the facility code, and obtains the building and operating permits. A foreign-owned company carries KBLI 77400 for the brand and KBLI 85510 for the academy. Three documents connect them: a franchise and brand-licence agreement setting the royalty, a coaching and academy-services agreement setting the academy fee, and, where the foreign group funds construction, a loan agreement on commercial terms. Before committing capital, an investor confirms the operating company’s codes on live OSS, the franchise registration where a franchise, the genuine local ownership and capitalisation on the beneficial ownership register, and the withholding and transfer-pricing treatment of each fee. Outside Bali, the same outline applies, and the foreign-owned company can also register KBLI 93119 and own the facility itself.
An operator or an investor can test the structure against the current framework before an inspection or a registration does. The test runs in four steps, adapted to a sports facility.
- Identify the real economic actor behind the facility, and compare it to the actor on the register.
- Identify which function each entity performs, whether facility operation, brand and intellectual property licensing, coaching, or management.
- Test each operating entities’ codes against the current investment and licensing position on live OSS.
- Test the tax and franchise-registration position of the fee flows.
TraceWorthy conducts that review for existing foreign operators in the sport, for prospective investors building a greenfield club, and for investors contemplating a sports franchise, and sets the structure to what a foreign-owned company can register at its next filing.
This article provides general information on the regulatory position at the date of publication, 20 June 2026, as updated on 12 November 2026. It does not provide legal, tax, or investment advice, and it does not create an adviser relationship. The regulatory position changes, and the public OSS environment continues to reflect transition treatment for earlier projects, so any structure should be tested against the current instruments and live OSS treatment before a decision is taken. The OSS scope for KBLI 93119 names padel courts, and the classification, scale, and licensing position for a specific entity should be confirmed on live OSS. PT TraceWorthy Consulting accepts no liability for reliance on this article without specific advice.
Frequently Asked Questions
Yes, outside Bali. The OSS scope for KBLI 93119, read on 12 November 2026, names padel courts expressly and shows the large-enterprise scale at which a PT PMA registers, at a low risk level that needs an NIB. In Bali, low-risk classifications have been closed to new PT PMA registrations since May 2026, so a new foreign-owned padel facility cannot be registered there. The sports-club codes still showed no configured scope, so a membership club registers with a domestic company.
Outside Bali, the facility under KBLI 93119, the brand licence under KBLI 77400, and a standalone coaching academy under KBLI 85510. In Bali, the facility code is closed to a new PT PMA, so the PT PMA registers the brand licence and the academy. KBLI 77400, the lease of intellectual property other than copyrighted works, covers licensing the brand, the name and the operating system, and is low risk. KBLI 85510, sports and recreation education, covers a standalone coaching academy, is high risk and is licensed by the Minister of Education. Both codes show large-enterprise scale and name the PT PMA as an eligible party.
Where the arrangement meets the definition of a franchise, the Indonesian franchising regime applies on top of KBLI 77400. The franchisor must register and obtain a franchise registration certificate (STPW), provide a franchise prospectus, and meet the disclosure and local-content obligations of the current franchising rules.
Each five-digit KBLI code has its own investment plan under BKPM Regulation 5 of 2025, exceeding IDR 10 billion per code per location, excluding land and buildings, with minimum paid-up capital of IDR 2.5 billion. A company registering both KBLI 77400 and KBLI 85510 plans an investment against each code, and KBLI 93119 where it registers the facility.
Under the owner-principal model. A locally controlled company owns the land or a lawful lease and the courts, registers the facility code, and obtains the building and operating permits. Local control means the Indonesian party owns the shares, appoints the board, controls signing authority and has the veto over reserved corporate actions, and the company is capitalised to build the facility. The foreign-owned company licenses the brand and runs the academy under separate agreements, and any funding it provides is an arm’s-length loan or supply arrangement documented on commercial terms.
A royalty paid to an Indonesian licensor, such as the PT PMA, is subject to 15 per cent withholding under Article 23 of the Income Tax Law. A royalty paid to a licensor outside Indonesia is subject to 20 per cent under Article 26, or a lower treaty rate where the treaty conditions are met. Coaching and management fees have their own withholding and value-added tax treatment, and each fee between related parties must be set at arm’s length and documented under the transfer-pricing rules.
Yes. KBLI 93119, the code that names padel, is low risk, so the Bali closure on new PT PMA registrations in low and medium-low risk classifications applies to a new foreign-owned padel facility. A PT PMA that registered and licensed its padel facility in Bali before the closure took effect holds a registration granted under the earlier rules, and should confirm its current OSS record before adding a location or a code. Bali’s 2026 provincial regulation on productive land conversion also prohibits nominee control of land, so a facility registered to Indonesian names on behalf of a foreign sponsor is exposed in the province as well as void under national law.