balivillacareForeign guests at a Bali villa: what has to be reported, and by whom
Key takeaways
- The owner or manager of a villa must give data on foreign guests if asked by an immigration or police officer on duty. The police were added in 2024.
- Refusing, or giving nothing after being asked, carries up to 3 months' detention or IDR 25,000,000.
- The minimum data is six items: name, place and date of birth, sex, phone, nationality, passport number.
- The immigration directorate says APOA is the platform it uses for that data. The villa photographs the passport page and enters the guest.
- If a manager runs the villa, the contract should say who keeps the guest data and who answers when asked.
Every villa in Bali that takes foreign guests is a place of lodging in the eyes of the immigration law. The duty it carries is narrow and specific — hand over guest data when asked — but the penalty is criminal, and the question of who answers is one most management contracts never settle.
Seven words in the immigration rule
The law is short. These are the words it turns on.
| Term | What it means | What it means for a villa |
|---|---|---|
| Orang Asing | A foreigner. | Every guest who is not an Indonesian citizen. |
| Tempat penginapan | A place of lodging. | A villa let to guests is one; the penalty clause also says “house”. |
| Pemilik atau pengurus | The owner or the manager. | Either can be the one asked. The contract should say which one answers. |
| Pejabat Imigrasi | An immigration officer. | Could always ask for guest data. |
| Pejabat Kepolisian | A police officer. | Can also ask since the 2024 amendment. |
| APOA | Aplikasi Pelaporan / Pengawasan Orang Asing. | The immigration directorate's app for guest data, as it describes it. |
| Pengawasan Keimigrasian | Immigration supervision. | The purpose the data is handed over for. |
What the law actually requires
The duty: give the data when asked
UU No. 6 Tahun 2011, the immigration law, as rewritten by UU No. 63 Tahun 2024 on 17 October 2024, says two things in Pasal 72:
- an immigration officer and/or a police officer on duty may ask anyone who gives a foreigner a place to stay for data on that foreigner; and
- the owner or manager of a place of lodging must give data on the foreigners staying there if asked by an immigration or police officer on duty.
The elucidation adds that the request may be made manually or electronically. Before the 2024 amendment only immigration officers were named; the police were added, and the two are told to coordinate (Pasal 72 ayat (3)).
The penalty
An owner or manager who gives no information, or no data on foreigners staying at the house or lodging, after being asked, faces detention of at most three months or a fine of at most IDR 25,000,000 (Pasal 117, as amended). The penalty attaches to not answering a request, not to failing to file on a schedule.
The data
The implementing regulation, PP No. 31 Tahun 2013, repeats the on-request duty (Pasal 187) and sets the minimum content (Pasal 188): full name, place and date of birth, sex, phone number, nationality and passport number. The data is handed to immigration for immigration supervision. PP 31/2013 has been amended four times since; none of the amending texts read for this page changes these two articles.
| Source | What it says | |
|---|---|---|
| Who may ask | UU 6/2011 Pasal 72(1), as amended | Immigration and/or police officers on duty |
| Who must answer | Pasal 72(2), as amended | The owner or manager of the lodging |
| When | Pasal 72(2) | If asked |
| What | PP 31/2013 Pasal 188 | Six items, at least |
| If not | Pasal 117, as amended | Up to 3 months or IDR 25,000,000 |
Not sure who answers for your villa's guests?
Tell us which part of Bali the villa is in. Five questions, and your details are the last step.
APOA: the channel immigration says it uses
APOA is the Directorate General of Immigration's application for foreigner data. In a news release on 26 March 2025 the directorate said that it has the authority to ask hotels and other lodging for data on foreigners, and that it uses APOA as the platform for that. Its description of the process:
- the owner or manager of the lodging logs in to APOA;
- asks the foreign guest for their passport and uploads a photo of the passport page, or takes one in the app;
- enters the guest's data, which is checked for accuracy; and
- immigration officers can then access the data for supervision.
The release was headlined as lodging managers being obliged to report guests through APOA. The legal duty it cites is the Pasal 72 duty above — to give the data when asked — and APOA is how that asking is done in practice. A villa that enters its guests there has the answer ready before the question arrives.
What this means for a villa run from abroad
The owner of a villa in Bali is often not there. The law names the owner or the manager, so whoever is on site is the one an officer will ask. That is a reason to settle it in writing rather than assume it.
Guest data in the management contract
Three clauses cover it:
- Who keeps the guest register — the six items, for every foreign guest, and for how long.
- Who holds the APOA account for the villa and enters guests on arrival.
- Who answers an immigration or police request, and who carries the consequence if it is not answered.
A manager already doing check-in is the natural party to do all three. The point is that the contract says so. The clauses that decide who does what, and the staff who will actually be at the door.
Guests booked through a platform
A booking made on a platform does not move the duty. The platform is an intermediary; the guest sleeps at the villa, and the villa is the lodging. What the 2026 platform rules add.
What this page does not cover
- Whether APOA entry is required without a request. The texts read here set a duty to answer a request; no regulation read sets a routine filing deadline.
- How long guest data must be kept. Not found in the texts read.
- Data-protection rules on guest passports. Not read.
- Guests' own immigration duties. A separate set of rules.
Common questions
Do Bali villas have to report foreign guests?
The owner or manager of a place of lodging must give data on the foreigners staying there if an immigration officer or a police officer on duty asks for it (UU No. 6 Tahun 2011, Pasal 72 ayat (2), as amended by UU No. 63 Tahun 2024). The immigration directorate says it uses its APOA application as the platform for that data.
What happens if a villa does not give the data?
An owner or manager who gives no information or data after being asked faces detention of at most three months or a fine of at most IDR 25,000,000 (Pasal 117, as amended).
What guest details have to be given?
At least full name, place and date of birth, sex, phone number, nationality and passport number (PP No. 31 Tahun 2013, Pasal 188).
What is APOA?
The immigration directorate's foreigner-reporting application. In its own words, the owner or manager logs in, photographs the guest's passport page, enters the data, and immigration officers can then access it.
Who reports when the owner lives abroad?
The law names the owner or the manager of the lodging. If a management company runs the villa, the management contract should say that it keeps the guest data and answers requests, and who is responsible if it does not.
Do the rules apply to a villa let for a month or more?
The duty attaches to a foreigner staying at the lodging or house, not to the length of the stay. The hotel tax treats stays over a month differently; the immigration rule read here does not.
Sources cited on this page
- UU No. 63 Tahun 2024 — third amendment to the immigration law, Pasal 72 and 117
- UU No. 6 Tahun 2011 — immigration law
- PP No. 31 Tahun 2013 — implementing regulation, Pasal 187-188
- Directorate General of Immigration — APOA news release, 26 March 2025
Every figure above was read from the source it is attributed to on 20 September 2026. How we check this.