balivillacareA villa on an old IMB: what the permit still covers
Key takeaways
- An IMB issued before February 2021 remains valid until it expires (PP No. 16 Tahun 2021, Pasal 346). There was no deadline to convert it.
- It records a function. A change of function, including a sub-function, needs a PBG perubahan (Pasal 11 ayat (2)).
- A house permit on a building run as a villa business is the case to check before licensing.
- A building standing with no permit at all goes SLF first: the PBG is issued together with the SLF (Pasal 262 ayat (4)).
- Renovation that changes floors, area or facade needs an amended approval; maintenance does not.
Most villas in Bali were built before 2021, on an IMB. The permit did not expire when the PBG arrived. What it records, though, is a function — and a villa that is now run as a business may not be the building the permit describes.
How to read the numbers on this page. A figure with no marker is quoted from a primary source and linked at the foot of the page. reported means we could not read the figure at its source — a company that publishes no rate card, or an official decision or announcement available only through news reporting — so it comes from that reporting, which is linked. modelled means it came out of the model set out on the methodology page, which you can disagree with line by line.
Eight words for an old permit
The transition from IMB to PBG changed the vocabulary. These are the terms that decide what an old permit still covers.
| Term | What it is | What it means for a villa |
|---|---|---|
| IMB, Izin Mendirikan Bangunan | The building permit before February 2021. | Remains valid until it expires. |
| PBG | The building approval that replaced it. | Needed for new work from 2021. |
| PBG perubahan | An amended approval. | What a change of use or a large renovation needs. |
| Fungsi, function | What the permit says the building is for. | A house permit is not a villa-business permit. |
| Sub-function | A narrower use within a function. | Changing it counts as a change of function. |
| SLF | The certificate of function. | The route to a PBG for a building that has none. |
| As-built drawings | Drawings of the building as it now stands. | Compared with the permit at inspection. |
| SBKBG | The building ownership certificate. | Tied to a valid SLF. |
What the transition actually said
PP No. 16 Tahun 2021 replaced the IMB with the PBG on 2 February 2021. Its transitional article, Pasal 346, is three sentences long.
| What it says | |
|---|---|
| Ayat (1) | Permits issued by the regency before the regulation remain valid |
| Ayat (2) | An IMB remains valid until it expires |
| Ayat (3) | A building standing without a PBG must go through the SLF process to obtain one |
So an IMB did not need converting on any deadline. It needs replacing when the building changes — and the regulation is specific about what counts as a change.
The function the IMB records
A permit is for a building with a function: residential, business, and so on. PP No. 16 Tahun 2021 writes the function onto the approval, the SLF and the ownership certificate (Pasal 11 ayat (1)), and sets it by the activity given priority in the building.
The house that became a villa business
Many villas were permitted as houses and are now let by the night. Pasal 11 ayat (2) requires an owner to apply for a PBG perubahan when the function changes, and the elucidation adds that this includes a change of sub-function. The list of business buildings in the elucidation names wisma, losmen, hostel, motel, rumah kos, hotel, kondotel; villas are not named, so whether a given let villa has changed function is the regency's classification.
Why it matters now
Pasal 12 lets the regency sanction a building that does not conform to its function, up to demolition. And the license a villa now needs rests on the building documents (PP No. 28 Tahun 2025, Pasal 12), which is where a mismatch surfaces. What the function changes, from levy to SLF.
Villa on an old IMB?
Tell us which part of Bali the villa is in. Five questions, and your details are the last step.
When the old permit is no longer enough
Two things end an IMB's usefulness short of its expiry: the building changes, or it never had a permit in the first place.
Renovating a villa on an IMB
An amended approval is needed for the changes Pasal 262 lists: function, number of floors, floor area, facade, components affecting safety or health, and strengthening after moderate or heavy damage. Maintenance and upkeep are expressly excluded. A new pool pavilion, an added floor or an enclosed terrace that adds floor area is on the list; repainting is not.
The levy for the amended approval is lower than for a new building in Denpasar: its built-building index is 0.225 or 0.325 for moderate or heavy renovation, against 1 for a new build. How the levy is calculated.
Changes the renewal inspection will find
If the villa already has an SLF, alterations surface at the next renewal. PP No. 16 Tahun 2021, Pasal 299, has the inspector recommend a new PBG where the building no longer matches its last certificate, with repairs as well where the changes affect safety or health. An unpermitted extension does not stay invisible for longer than one SLF cycle.
A villa with no permit at all
Pasal 346 ayat (3) gives the route: the SLF process, with the PBG issued alongside it (Pasal 262 ayat (4)). The inspection for a first SLF on a building without a PBG checks it against the technical standards and recommends adjustments where it falls short, which the owner then carries out (Pasal 212). The SLF, and what it costs to let it lapse.
What the new licensing rules do and do not touch
PP No. 28 Tahun 2025 exempts from its new implementation rules the licenses that were already issued, verified or approved and are still valid when it took effect (Pasal 549), and keeps earlier rules on basic requirements in force where they do not conflict with it (Pasal 550). A villa's existing license is not undone by the new regulation. A new application, or a change, is made under it — and that is when the building documents are looked at again.
Three checks before buying or taking on a villa
- The function on the IMB or PBG. A house, or a business building?
- The building against the drawings. Extra floors, rooms or a pavilion that are not on the approved drawings are an amended approval waiting to happen.
- The SLF. Whether there is one, what function it records, and when it renews.
A manager taking on a villa is in a good position to ask for all three, and a good reason to: the license they will list it under rests on them.
What this page does not cover
- How OSS treats an IMB in a license application. Not read.
- Regency practice on when letting changes function. Not read for any regency.
- Zoning. Whether the land's zone allows the use is a separate check (KKPR), covered by our sister site for buyers.
Common questions
Is an IMB still valid in Bali?
Yes. PP No. 16 Tahun 2021, Pasal 346, says permits issued before it remain valid, and an IMB remains valid until it expires. It did not need converting into a PBG on any deadline.
Do I need to convert my villa's IMB to a PBG?
Not for its own sake. A new approval is needed when something changes: the function, the floors, the floor area, the facade, or safety-related components (Pasal 262). Maintenance does not trigger it.
My villa was built with a house IMB. Can I let it as a villa?
The permit records a function. PP No. 16 Tahun 2021 says a change of function, including a change of sub-function, requires the owner to apply for an amended PBG (Pasal 11 ayat (2)), and a building that does not conform to its function can be sanctioned (Pasal 12). Whether letting a particular villa changes its function is the regency's classification; the question is worth settling before a license is applied for.
What if the villa has no IMB or PBG at all?
The regulation's route is the SLF: a building already standing without a PBG goes through the SLF process to obtain one (Pasal 346 ayat (3)), and the PBG is issued together with the SLF (Pasal 262 ayat (4)). The inspection checks the building against the technical standards and can require adjustments.
Does an IMB satisfy the PBG requirement for a business license?
PP No. 28 Tahun 2025 lists PBG and SLF among the basic requirements (Pasal 12), and its Pasal 550 keeps earlier rules in force where they do not conflict. How OSS treats an IMB for a given application was not read for this page.
What should I check on an IMB before buying or managing a villa?
The function it records, whether the building as it stands matches the approved drawings, and whether there is an SLF. A mismatch in any of the three is a PBG perubahan or an SLF process waiting to happen.
Sources cited on this page
- PP No. 16 Tahun 2021 — Bangunan Gedung, BPK copy
- PP No. 16 Tahun 2021 — BPK record
- PP No. 28 Tahun 2025 — risk-based business licensing, BPK copy
Every figure above was read from the source it is attributed to on 20 September 2026. How we check this.