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 of Padel Clubs in Indonesia: KBLI Codes Favour Locally-Owned Enterprises
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 fact. The code that operates a padel court carries no large-enterprise scale, and a foreign-owned company can exist only at large-enterprise scale.
A foreign-owned company, in Indonesian law a Perseroan Terbatas Penanaman Modal Asing (PT PMA), therefore sits outside the code that runs the facility itself, across the whole of Indonesia rather than in Bali alone. The provincial block in Bali adds a second closure on top of the national one. The structure that survives separates the facility from the brand, the system, and the coaching, and routes the foreign company into the codes that stay open to it.
01 · The position now
The code that runs a padel court sits beyond foreign ownership
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. The common pattern placed a flagship venue, a franchise network, a coaching academy, and a pro shop under one brand.
The classification that governs the playing facility decides whether that ownership pattern survives the 2025 framework. The activity of running padel courts maps to the sports facility management codes in the Indonesian Standard Industrial Classification (Klasifikasi Baku Lapangan Usaha Indonesia, or KBLI). Those codes carry no large-enterprise scale. A foreign-owned company exists only at large-enterprise scale. The facility code therefore sits beyond foreign ownership.
This is a national position, not a Bali position. The provincial block that closed foreign registrations in lower-risk codes adds a second layer in the island where most padel courts stand. The national scale rule operates first, and it operates everywhere.
Two readers face the same fact from different sides. An operator already running courts through a foreign-owned company sits outside the lawful lane and needs a restructuring path. A prospective investor, whether building a greenfield club or taking a franchise, needs the structure set correctly before any capital is committed.
02 · The classification
Where padel sits in KBLI 2025
KBLI 2025 carries no dedicated code for padel. The sport is classified by analogy to the codes for court and field facilities, the same codes that carry tennis, badminton, futsal, and basketball. Any registered code for a specific club should therefore be read against the activity the club actually conducts.
The hierarchy runs from the Arts, Entertainment and Recreation category, through sports activities, into two branches that concern an operator. Sports Facility Management covers the venue and its courts. Sports Club Activities covers the membership club that sits above a venue. The facility branch carries the codes that govern a padel court.
Within the facility branch, the field facility code (KBLI 93114) covers open-field and court facilities, including tennis, badminton, futsal, basketball, and padel by analogy, and sits at low to medium-low risk, licensed by the Regent or Mayor. The court and arena facility code (KBLI 93113) sits at medium-high risk. The other sports facility management code (KBLI 93119) covers a multi-sport complex at medium-high risk. The club branch (KBLI 9312) covers membership clubs, such as a field tennis club.
| KBLI 2025 | Activity | Risk position | Business scale | Position for a foreign-owned company |
|---|---|---|---|---|
| 93114 | Field and court facilities (tennis, badminton, futsal, basketball, padel by analogy) | Low to medium-low | Micro, small, and medium; no large-enterprise scale | Closed to a foreign-owned company; the scale it requires is absent |
| 93113 | Court and arena facilities | Medium-high | Micro, small, and medium; no large-enterprise scale | Closed to a foreign-owned company on the same scale point |
| 93119 | Other sports facility management (multi-sport complex) | Medium-high | Micro, small, and medium; no large-enterprise scale | Closed to a foreign-owned company on the same scale point |
| 9312x | Sports club activities (membership club; excludes the facility) | Not yet set in OSS | No enterprise size data recorded | Not currently registrable for a foreign-owned company; re-read once OSS sets the scale |
| 85510 | Sports and recreation education (coaching, instruction) | High | Large-enterprise scale available | Open to a foreign-owned company; full licence; see Section 05 |
| 77400 | Lease of intellectual property and similar products, not copyrighted works | Confirm on live OSS | Large-enterprise scale available | Open to a foreign-owned company; carries the franchise and brand licence |
Padel carries no dedicated KBLI 2025 code and maps to the court and field facility codes by analogy, so the registered code for a specific club should be confirmed on live OSS against the activity actually conducted. The scale position for codes 93113, 93114, and 93119 was confirmed on the OSS classification pages: each code lists micro, small, and medium business scale and omits the large-enterprise (Usaha Besar) scale. The club codes (KBLI 9312 group) were read on OSS and carry no enterprise size data at this stage, so the platform records no large-enterprise scale to register a foreign-owned company against; that position should be read again once OSS sets the scale for these codes.
03 · The mechanism
The scale rule that closes the court code to foreign ownership
A foreign-owned company can exist in Indonesia only as a large enterprise. Two instruments set that position. Government Regulation No. 28 of 2025 on Risk-Based Business Licensing governs how an activity is licensed according to its risk. Minister of Investment and Downstreaming Regulation No. 5 of 2025 sets the capital that a foreign-owned company carries.
The capital rule carries two figures. The total investment plan for each five-digit KBLI code, at each project location, must exceed IDR 10,000,000,000 (ten billion Indonesian Rupiah), excluding the value of land and buildings. The minimum issued and paid-up capital is IDR 2,500,000,000 (two billion five hundred million Indonesian Rupiah), reduced from ten billion in October 2025, and locked in the company account for twelve months save for verified operational use. A company carrying two separate KBLI codes plans the investment figure against each code independently.
A large enterprise is defined by that capital position. The court codes carry no large-enterprise scale, so a foreign-owned company cannot register against them. A foreigner cannot lawfully run a micro, small, or medium enterprise (Usaha Mikro, Kecil, dan Menengah, or UMKM) in a direct capacity. The two facts close the same door from both sides.
This is the point where the analysis often goes wrong. The OSS classification page for a court code displays a support permit, a business licence to support business activities (Perizinan Berusaha Untuk Menunjang Kegiatan Usaha, or PB UMKU), described as a certificate of fitness in the region. A PB UMKU is a supplementary permit obtained after the base registration. It does not decide ownership eligibility. Ownership eligibility is decided by the scale and capital rule set out above. The presence of a PB UMKU on the page does not open the code to a foreign-owned company.
The closure operates nationally. It applies in Jakarta, in Surabaya, and in Bali alike. A move between provinces does not reach a large-enterprise scale that the code does not carry.
04 · The second layer
The Bali block as reinforcement
Bali adds a provincial closure on top of the national one. The Governor of Bali letter numbered B.27.000/642/PM/DPMPTSP, dated 28 January 2026, asked the Ministry of Investment to stop new foreign-company registrations in every low-risk and medium-low-risk classification across the province, and to stop accepting virtual office addresses for foreign companies. The Ministry applied the request inside the Online Single Submission (OSS) system, Indonesia’s risk-based business licensing platform, and the block took effect in May 2026.
The field facility code (KBLI 93114) sits at low to medium-low risk. The Bali block closes that level to foreign-owned companies on the risk tier alone, independent of the national scale rule. In the island where most padel courts stand, the court code is therefore closed twice over, once by the absent large-enterprise scale and once by the provincial block.
A new foreign-company application in Bali also needs a verifiable commercial address that follows the zoning for the activity. A virtual office or residence does not serve as a registered business seat. The requirement removes a common registration route used by smaller foreign operators.
Existing foreign-owned clubs in Bali sit at the centre of this. The provincial enforcement through 2025 and early 2026 produced administrative sanctions against foreign companies for licensing violations, and the Ministry of Investment opened a dedicated Investment Desk in Bali to coordinate monitoring across the island.
05 · The open codes
The classifications a foreign company keeps
The foreign company is not shut out of the sport. It is shut out of the playing facility. Two codes carry the functions that a foreign group can own, and both were confirmed open at large-enterprise scale.
The intellectual property lease code (KBLI 77400), lease of intellectual property and similar products not copyrighted works, is open to a foreign-owned company. This code carries the franchise and brand licence: the name, the system, the operating manual, the design standards, and the method, licensed to an operator in exchange for a fee.
The sports and recreation education code (KBLI 85510) carries the coaching academy. The OSS classification page lists the large-enterprise (Usaha Besar) scale for this code, at high risk, which means a full business license with verification rather than a self-declared certificate. The licensing route names a separate path for foreign-owned companies. A domestic operator obtains the license from the Regent or Mayor through the regional one-stop investment service. A foreign-owned company obtains it from the Minister of Education, Culture, Research and Technology. No foreign-ownership percentage is recorded against the code on the classification platform. A regulator does not write a foreign-company licensing route for a code that foreign companies cannot enter.
The 85510 licensing authority
For sports and recreation education, the licensing authority differs by ownership. A domestic operator is licensed by the Regent or Mayor through the regional one-stop investment service. A foreign-owned company is licensed by the Minister of Education, Culture, Research and Technology. The route for foreign-owned companies is written into the standard itself, which confirms that the code admits a PT PMA.
One boundary sits inside KBLI 85510. The code 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 in its own right. Coaching delivered inside the club itself belongs to the club, on the local side. The foreign academy and the local club are separate entities under separate codes.
The management function does not have a sports-specific home open to a foreign company. The sport-related management codes carry no large-enterprise scale, which closes them to a foreign-owned company on the same point as the facility codes. Management therefore runs as a contracted output of the franchise and the academy, rather than as a standalone sports KBLI. A standalone management vehicle would need a non-sport code, and the obvious one is not available everywhere. Other management consultancy activities (KBLI 70209) is open to a foreign-owned company nationally, and Government Regulation No. 28 of 2025 recategorised it to low risk. In Bali, that low-risk position places it inside the provincial block, and the provincial authority named KBLI 70209 among the codes already closed to new foreign registration. A foreign company therefore cannot register a fresh management vehicle under KBLI 70209 in Bali. Even so, it would be a stretch to govern the management of a sporting facility with a management consulting license.
Equipment supply divides along the line that runs through Indonesian trade rules. Wholesale and import of equipment, covering rackets, balls, court systems, and surfacing, is open to a foreign-owned company at large enterprise scale, subject to the capital rule and an importer identification number for cross-border supply. Retail sits 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 rather than the foreign company.
Two functions carry the same status on OSS at present. The membership club, under the sports club codes (KBLI 9312x group), and event and tournament promotion, under the implementation of sports activities code (KBLI 93191), both show no enterprise size data on the platform at this stage. Event promotion under KBLI 93191 covers championships, multi-event organisation, and promoter services including electronic sports. A foreign-owned company registers at large enterprise scale, and where the platform records no scale, there is no large-enterprise tier to register against, so neither code is currently registrable as a foreign-owned vehicle. The absence of any scale, rather than the presence of the smaller scales alone, indicates that these codes are not yet fully set for KBLI 2025 risk-based licensing, so the position should be read again once OSS completes the data.
The club code settles one structural point regardless of scale. KBLI 9312x excludes the operation of sports facilities, which stays under the facility codes (KBLI 9311x group). A membership club therefore sits as a layer above a separate facility entity, rather than carrying the courts itself.
06 · The franchise relationship
What the franchisor carries and what the franchisee carries
The franchise relationship is where the lawful structure and the commercial model meet. The franchisor sits on the foreign side, carrying the brand and the system under KBLI 77400 and the coaching method under KBLI 85510. The franchisee sits on the local side, carrying the facility under the court code and operating the club.
For a prospective franchise investor, the side of the line decides the structure. A foreign investor taking a franchise belongs on the franchisor and brand side, or invests through the brand and academy vehicles, with a genuinely Indonesian-controlled operating partner carrying the facility. The foreign investor cannot take the franchise into a foreign-owned company that operates the courts directly, because the court code does not admit one. A local investor taking a franchise carries the court code, registers the operating entity at the scale available to a domestic enterprise, and operates the club under licence from the foreign brand.
| Function | Code | Structure |
|---|---|---|
| Brand, name, system, operating manual | KBLI 77400 intellectual property lease | Foreign franchisor (PT PMA) |
| Coaching method and academy | KBLI 85510 sports and recreation education | Foreign academy (PT PMA, full licence) |
| Court and facility operation | KBLI 93114 or 93113 court and field codes | Local operating partner or local franchisee |
| Membership club | KBLI 9312 sports club codes (excludes the facility) | Local entity; no large-enterprise scale set on OSS at present |
| Fee-based management | Contracted output of franchise and academy | Documented agreement between the parties |
A prospective franchise investor verifies four points before committing capital.
- The first is the scale and ownership eligibility of the operating entity against the court code.
- The second is the genuineness of local control over that entity, tested against the beneficial ownership rules rather than the paperwork alone.
- The third is the separation of the franchise, the coaching, and the management functions into distinct documented agreements.
- The fourth is the registered code of each entity against the activity it actually conducts on live OSS.
07 · The structure that works
The lawful end-state for an own-and-license brand
The structure that survives the framework mirrors the logic that governs accommodation, where the Indonesian principal owns the operating asset and the foreign group supplies the brand and the services around it.
The facility ownership and operation sits with a genuinely Indonesian-controlled entity carrying the court code. The foreign group registers a foreign-owned company carrying the franchise and intellectual property licence under KBLI 77400 and the coaching academy under KBLI 85510. The brand, the system, the coaching method, and a fee-based management role flow from the foreign company to the local operator under separately documented agreements. Each function carries its own contract, its own fee, and its own code.
For an own-and-license brand, the contemplation is direct. The brand cannot own the courts through a foreign-owned company and license the same brand to franchisees at the same time, because the first half of that model is closed. The lawful version keeps the foreign company on the brand, the system, and the coaching, and places every operating facility, including any flagship, with a locally controlled entity. The franchise model becomes the core structure rather than an addition to a foreign-owned chain.
The shortcut to avoid is the nominee. A structure that registers the operating entity to Indonesian names while a foreign sponsor directs it and takes the economics meets a specific control. 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. A nominee operating entity therefore carries no enforceable foreign claim and stands exposed on disclosure.
The nominee is not a route
An operating entity registered to Indonesian names while a foreign party directs it meets Article 33 of the Investment Law (Law No. 25 of 2007), which voids any agreement that shares or assets are owned for another person, and the beneficial ownership register under Presidential Regulation No. 13 of 2018. The arrangement carries no enforceable foreign claim.
The framework points the sector toward consolidation. A foreign-owned chain that operates its own courts cannot continue in that form. The brands that adapt early convert their owned venues into locally controlled franchisees and concentrate the foreign company on the brand, the system, and the coaching. Existing foreign-owned clubs face a review and, in most cases, a restructuring.
08 · The next step
A KBLI and structure review
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 the scale and ownership eligibility of the operating entity against the small-enterprise reservation on the court code.
- Test each code the foreign company carries against the current investment and licensing position on live OSS.
A structure and licensing review produces the answer. Some structures need alignment of codes and agreements. A foreign-owned chain that operates its own courts needs a material restructuring, converting owned venues into locally controlled franchisees and concentrating the foreign company on the brand and the coaching. A structure built on a nominee operating entity needs a full unwind and re-entry on lawful footing.
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 out the position a foreign-owned company needs before its next registration or inspection.
This article provides general information on the regulatory position at the date of publication, 20 June 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. KBLI codes for padel are applied by analogy in the absence of a dedicated code, 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.