Information, not advice. Raja Ampat Investment Intelligence is an independent editorial guide. This page is general information, not financial, legal, tax, or investment advice, and we never promise returns. Indonesian regulations and customary (adat) land rights are complex and change — verify everything with licensed Indonesian counsel, a notaris, and customary-law experts before any decision. Where useful we can introduce you to vetted independent partners; we may receive a referral fee, at no cost to you.
A PT PMA (Perseroan Terbatas Penanaman Modal Asing) is Indonesia’s foreign-investment limited-liability company — the only legal vehicle through which a foreign national or foreign entity can directly own and operate a tourism or marine business in Raja Ampat. Every guide you find on PT PMA setup is written for Bali. This one is not. The regulatory skeleton is the same across Indonesia, but the KBLI codes you choose, the capital commitments involved, the West Papua customary-land overlay, and the very real risk that a permit can be revoked — as four nickel concessions were in June 2025 — make Raja Ampat a materially different operating environment. This page maps the rules as they stand; it is information, not legal or financial advice, and you should retain a licensed notaris and an OSS-registered investment consultant before acting.
What a PT PMA Can and Cannot Do in Raja Ampat
A PT PMA gives a foreign investor direct legal standing in Indonesia: the company can hold contracts, employ staff, open a tax ID (NPWP), accept Rupiah and foreign-currency revenues, and — crucially for the tourism sector — hold certain registered land rights. What it cannot do is own land outright. Foreigners and their companies cannot hold Hak Milik (freehold title) under the Basic Agrarian Law (UUPA, Law No. 5/1960). A PT PMA typically holds HGB (Hak Guna Bangunan, right to build) or Hak Pakai (right to use) over land that is leased from its registered owner — which in Raja Ampat is frequently a Papuan clan (marga or keret) rather than an individual titleholder.
That distinction matters more here than anywhere else in the archipelago. Much of Raja Ampat’s coastline and small islands exists as unregistered customary (adat, tanah ulayat) land. There is no Badan Pertanahan Nasional (BPN) certificate to inspect, no cadastral boundary that a title search will find. Papua Special Autonomy Law No. 21/2001, as amended by Law No. 2/2021, explicitly protects the land and resource rights of Orang Asli Papua and requires free, prior, and informed consent (FPIC) before any commercial use. A PT PMA can be established cleanly, with all its BKPM approvals in order, and still face an insurmountable social-licence problem if the clan agreement was signed by one leader whose authority is contested by the broader community.
Capital Requirements: The IDR 10 Billion Rule and the Disputed Paid-Up Floor
The most frequently mis-stated number in PT PMA guides is the minimum capital. Here is the honest picture, as it stood based on sources available through mid-2026:
| Threshold | Amount | Source / Status |
|---|---|---|
| Total investment plan | > IDR 10 billion per KBLI code per project location, excluding land and buildings | PP 7/2021 MSME classification thresholds — widely cited, confirmed consistent across advisors |
| Minimum paid-up capital (widely-cited pre-2025) | IDR 10 billion | Legacy BKPM guidance, still cited by some practitioners |
| Minimum paid-up capital (post-October 2025 claim) | IDR 2.5 billion (~USD 150,000 at current rates) | Cited by Cekindo/InCorp as effective since October 2025 under BKPM Reg 5/2025; not independently verified |
The inconsistency between IDR 2.5 billion and IDR 10 billion paid-up capital is real, and you will encounter both figures depending on which advisor or platform you consult. Verify the in-force BKPM/Ministry of Investment regulation with a licensed consultant before you commit capital. What is not disputed: the investment plan must exceed IDR 10 billion per KBLI line per location. That threshold defines a PT PMA as a large enterprise and is what separates it from the MSME scale reserved for local Indonesian operators.
The practical implication for Raja Ampat is direct. A small eco-lodge with five bungalows is unlikely to satisfy an IDR 10 billion investment-plan requirement on paper without incorporating equipment, boats, solar systems, and fit-out costs — all of which can legitimately be included, since the exclusion is specifically land and buildings. A dive centre, a liveaboard operation, and a resort can each sit under separate KBLI codes; each code, at each location, requires its own investment-plan commitment. Plan your capital structure early and document everything that can legally count toward the threshold.
Choosing the Right KBLI Codes: Tourism and Marine Activities
KBLI 2020 (Klasifikasi Baku Lapangan Usaha Indonesia) is the business-activity classification system that feeds directly into the OSS (Online Single Submission) licensing platform. The KBLI codes you register at incorporation quietly determine which downstream permits you can ever obtain. Choosing a code that is too narrow, or that does not map to the primary revenue activity, creates a licensing ceiling you will hit later — often expensively.
The following are the codes most commonly relevant to Raja Ampat tourism and marine ventures. Confirm each code against the official KBLI 2020 list and current OSS before registering — classifications are periodically revised:
- 55111 — Penyediaan Akomodasi Bintang (Star-rated hotel/resort accommodation)
- For resorts seeking formal star classification. Relevant to larger dive resorts that want a formal tourism rating.
- 55112 — Penyediaan Akomodasi Non-Bintang
- Non-star hotel and accommodation. Many boutique dive lodges and eco-resorts register here.
- 55199 — Penyediaan Akomodasi Lainnya (Other accommodation, including villas)
- Covers smaller villa or pondok wisata-style accommodation. Note: micro/small-scale accommodation is reserved for MSMEs and not open to foreign PT PMA ownership — the line between MSME-scale and large-enterprise is the IDR 10 billion investment-plan threshold.
- 93119 / 93299 — Aktivitas Olahraga Air / Aktivitas Rekreasi Lainnya
- Covers diving operations, snorkelling tours, and water-sport activities. These codes are typically the primary code for a dedicated dive centre or water-activity operator. Verify which of the 93xxx sub-codes best matches your activity type.
- 50119 — Angkutan Laut Penumpang Dalam Negeri Lainnya
- Domestic sea passenger transport. Relevant for liveaboard operators and inter-island charter services. Maritime transport carries additional requirements under cabotage rules — vessels must generally fly the Indonesian flag and meet Ministry of Transportation safety standards.
- 79121 — Agen Perjalanan Wisata (Travel Agency)
- For operators selling packaged trips, handling bookings, and representing third-party suppliers.
- 79122 — Penyelenggara Perjalanan Wisata (Tour Operator)
- For operators designing and running itineraries directly — relevant to liveaboard and land-tour operators.
- 56101 — Restoran
- Full-service restaurant. Any resort with a restaurant open to non-guests, or charging separately for food, typically needs this alongside the accommodation code.
Foreign ownership at 100% is generally permitted for large-scale tourism operations under the Positive Investment List (Perpres 10/2021 as amended by Perpres 49/2021). The critical word is large-scale. Micro and small-scale accommodation — homestays, pondok wisata, small guesthouses — are explicitly reserved for Indonesian MSMEs and cooperatives. A foreign PT PMA operating at those scales is not a licensing technicality you can work around; it is a structural prohibition. Verify each KBLI line you intend to register against the Perpres annexes, as conditions and ownership caps vary by code and may have been updated since publication of this page.
OSS Risk-Based Licensing and the NIB
Since the Omnibus Law (Job Creation Law / UU Cipta Kerja, 2020) and its implementing regulations — principally PP 5/2021 on risk-based business licensing and PP 7/2021 on MSME classification — Indonesia’s licensing architecture shifted from sector-specific permits to a risk-tiered system administered through the OSS (Online Single Submission) platform managed by the Ministry of Investment / BKPM.
Every business, including a PT PMA, must obtain an NIB (Nomor Induk Berusaha) — a single business identification number that serves as the gateway to all subsequent licenses. The process, simplified:
- Establish the PT PMA legal entity — articles of association notarised before a licensed Indonesian notaris, submitted to the Ministry of Law and Human Rights (MOLHR) for company deed approval.
- Register on OSS — input company data, KBLI codes, investment plan values, and shareholder/director information. The system issues the NIB automatically for most standard activities.
- Obtain the Business License (Izin Usaha) — the OSS system classifies your activity by risk level (low, medium, high). High-risk tourism activities typically require additional environmental assessments and sector-specific approvals before the license activates.
- Fulfil post-NIB commitments — environmental compliance (AMDAL or UKL-UPL depending on project scale), building permit (PBG, which replaced IMB), spatial-use confirmation (KKPR), and sector permits from the Ministry of Tourism and the local Dinas Pariwisata.
PP 28/2025 introduced further digitisation of the licensing process. Verify the current OSS workflow at oss.go.id at the time of your application; the interface and required documents have changed multiple times since the system launched.
A practical note on Sorong incorporation: most Raja Ampat-focused PT PMA companies are incorporated in Sorong (the gateway city, in Southwest Papua province), since the regency itself has limited notarial and legal infrastructure. Sorong has licensed notaries, a regional BPN office, and access to the regional BKPM desk. Factor this into your setup timeline and budget for in-person visits.
Ready to map your legal structure to a Raja Ampat investment? Plan your approach with our concierge — we can connect you with vetted notaries and OSS consultants who have worked in the West Papua system.
Environmental Permits: AMDAL, UKL-UPL, and the Marine Park Layer
Raja Ampat’s ~13,550 km² Marine Conservation Area network — 7 MPAs, managed by the Raja Ampat Marine Park Authority (UPTD BLUD) in coordination with the provincial Maritime and Fisheries Service, the Navy, and the Indonesian Police — adds an environmental compliance layer that has no equivalent in Bali.
Any project involving construction near the coast, over water, or within an MPA utilisation zone will require an environmental impact assessment. The scale of the assessment depends on project size:
- AMDAL (Analisis Mengenai Dampak Lingkungan) — full environmental impact assessment, required for larger projects and those in sensitive ecosystems. This is a public document, involves community consultation, and can take six to twelve months.
- UKL-UPL (Upaya Pengelolaan Lingkungan Hidup / Upaya Pemantauan Lingkungan Hidup) — simplified environmental management and monitoring plan, for smaller-scale projects. Faster, but still requires formal submission and approval from the relevant environmental authority.
Inside the MPA zones, additional Marine Park Authority permits are required for commercial tourism operations, liveaboard anchoring, research, and filming. Core no-take zones (zona inti) prohibit construction, habitat disturbance, and fishing entirely. Tourism activity is concentrated in designated utilisation zones (zona pemanfaatan), and even there, anchoring on live coral is prohibited — moorings on sand or designated buoys only. Any dredging, land reclamation, mangrove clearance, or over-water structure in a living reef environment requires rare high-level approval and in practice is extremely unlikely to receive it.
The UNESCO Global Geopark designation (2023) and the Gold Blue Park Award (2022) mean Raja Ampat’s conservation performance is externally monitored. Enforcement has become more visible. The June 2025 revocation of four nickel mining permits — announced by the Minister of Energy and Mineral Resources at the Presidential Palace, citing environmental damage within geopark boundaries — demonstrated that the political will to protect the designation is real. Tourism operators who ignore environmental compliance are not operating in a low-enforcement environment.
Foreign Ownership Limits: Where the Positive Investment List Draws the Line
The 2021 Positive Investment List, established under Perpres 10/2021 and amended by Perpres 49/2021, replaced the older Negative Investment List (Daftar Negatif Investasi) with a framework that is in theory more open to foreign capital. For large-scale tourism and marine recreation, 100% foreign ownership is generally available through a qualifying PT PMA.
The hard limits fall at the MSME boundary. Small-scale accommodation — homestays, the community-based pondok wisata model that supports hundreds of Papuan families across Waigeo, Kri, Gam, Mansuar, Arborek, and Misool — is reserved for Indonesian nationals and cooperatives. This is not merely policy intent. The MSME-scale investment threshold under PP 7/2021 creates a structural barrier: activities with an investment plan below IDR 10 billion are classified as micro or small enterprises, and those classifications are reserved for local players. A foreign investor cannot circumvent this by holding a small resort through a nominee arrangement with a local partner.
Nominee Structures: Why They Are a Trap
Nominee arrangements — where an Indonesian national holds shares in a PT as a front for a foreign investor, often documented in a side letter or trust deed — are illegal under Article 10(1) of Law No. 25/2007 on Investment. Penalties include company dissolution, asset forfeiture, and criminal liability. Indonesian courts have consistently refused to enforce nominee agreements, treating them as attempts to circumvent the positive investment list. The side letter does not protect you.
Beyond the legal risk, nominee structures in Raja Ampat carry a social risk specific to the region. If a dispute arises with the local community, an investor whose ownership is informal and undocumented has no legal standing to defend. The argument that the community knew the real foreign owner does not translate into enforceable property rights. Papua’s strengthened indigenous rights framework under Law No. 2/2021 amplifies this exposure.
KITAS for Foreign Directors and Key Personnel
A PT PMA requires a minimum of two shareholders, one director, and one commissioner. There is no nationality requirement for the director, but a foreign national serving as director will need a KITAS (Kartu Izin Tinggal Terbatas, temporary stay permit) and a RPTKA (Rencana Penggunaan Tenaga Kerja Asing, foreign worker utilisation plan) approval before they can legally work and reside in Indonesia in that capacity.
The KITAS process is administered through the Directorate General of Immigration and typically takes four to eight weeks from submission of a complete dossier. The permit is issued initially for one or two years and is renewable. For Raja Ampat projects, plan for the director to be based in Sorong during the incorporation and licensing phases; remote management from outside Indonesia does not substitute for in-country presence when dealing with regional government offices in West Papua.
LKPM and Ongoing Compliance
A PT PMA’s compliance obligations do not end at incorporation. The most frequently neglected is the LKPM (Laporan Kegiatan Penanaman Modal), the investment activity report filed quarterly through the OSS system to the Ministry of Investment / BKPM. LKPM reports document capital realisation progress against the committed investment plan. Gaps between committed and realised capital attract scrutiny; persistent non-filing risks administrative sanctions and, in theory, suspension of the business license.
The principal taxes a Raja Ampat PT PMA will encounter:
- Corporate Income Tax (PPh Badan)
- 22% standard rate (Law 7/2021 HPP). Turnover below IDR 4.8 billion in a year qualifies for a reduced rate; confirm current thresholds with a tax consultant.
- VAT (PPN)
- 11% statutory rate (with a legislated step toward 12%). Applies to most goods and services sales; tourism services are generally taxable.
- Local Hotel and Restaurant Tax
- Typically around 10%, levied by the regency or city government. Confirm the Raja Ampat Regency rate with the local tax office (BAPENDA).
- Dividend Withholding Tax (PPh Pasal 26)
- 20% on dividends paid to foreign shareholders; reducible under applicable tax treaties. Verify Indonesia’s treaty with your country of residence.
- PBB (Land and Building Tax)
- Annual tax on land and building values. Rate is modest but compliance is required for title maintenance.
- Import Duties
- Dive equipment, solar panels, generators, and construction materials imported directly can carry significant duties. Factor this into your investment-plan capital budgeting — imported inputs count toward the IDR 10 billion investment threshold, which is one advantage.
Annual financial statements must be prepared in accordance with Indonesian accounting standards (SAK) and, above a certain revenue threshold, audited by a registered public accountant (KAP). Keep LKPM filings, tax returns, and audit reports current — permit renewals and any future expansion to new KBLI codes will require a clean compliance record.
The Sorong Incorporation Reality
Practitioners who handle only Bali incorporations sometimes underestimate the administrative geography of a Raja Ampat project. The regency capital is Waisai on Waigeo Island, accessible from Sorong by fast ferry in roughly two to three hours (economy fare in the IDR 100,000–150,000+ range for Indonesians; private speedboat charters run into several million IDR). Sorong itself is a working port city in Southwest Papua province — a different province from West Papua, which complicates inter-agency coordination when your project spans both administrative units.
Most PT PMA incorporations for Raja Ampat tourism projects are formally registered in Sorong because the notarial, BPN, and investment promotion infrastructure there is more developed than in Waisai. Plan for multiple in-person visits during the incorporation and licensing phases. Remote-only management of Indonesian bureaucratic processes rarely works; it almost never works in eastern Indonesia.
A Practical Setup Timeline
Timeline estimates from advisors range from four to eight weeks for the core company establishment and NIB issuance, assuming a clean KBLI scope and no complications with the shareholder structure. Environmental permits add time that varies with project scale: UKL-UPL might resolve in two to three months; a full AMDAL for a larger resort can run six to twelve months and requires community consultation. Marine Park Authority permits have their own separate timeline. The realistic path from first notarial consultation to a legally operable tourism PT PMA with all permits in hand is six to eighteen months, depending on the project’s complexity and environmental footprint.
Before you reach that point, the due-diligence phase — verifying that the land you intend to use has a resolvable path to a registered BPN title, confirming adat clan consensus (not just a headman’s signature), cross-checking that the site sits within an MPA utilisation zone rather than a core zone, and reviewing the spatial plan (RTRW/RZWP3K) for any zoning restrictions — deserves at minimum as much time and money as the incorporation itself. These are the issues that have stopped Raja Ampat tourism projects cold after investors had already committed capital.
Want to connect with consultants who have navigated PT PMA setup in West Papua? Reach out via our contact page or message us on WhatsApp — we maintain a list of vetted local legal and business-setup professionals and can point you toward the right specialists for your project type. We do not take commissions from referrals; this is editorial matching, not paid placement.
Frequently Asked Questions
Can a 100% foreign-owned PT PMA own a dive resort in Raja Ampat?
Yes, a 100% foreign-owned PT PMA can own and operate a large-scale dive resort under the Positive Investment List (Perpres 10/2021 as amended). The qualifier is large-scale — the investment plan must exceed IDR 10 billion per KBLI code per location, excluding land and buildings. Micro and small accommodation is reserved for Indonesian MSMEs. The company can hold HGB or Hak Pakai land rights; it cannot hold freehold (Hak Milik). Ownership of the company is distinct from ownership of the land, which in Raja Ampat is often customary adat land requiring separate clan-consent agreements registered through BPN.
What KBLI codes should a Raja Ampat dive resort register?
A typical dive resort registers multiple codes: 55111 or 55112 (accommodation), 93119 or 93299 (dive and water-recreation activities), and 56101 (restaurant) at a minimum. A liveaboard operator adds 50119 (domestic sea passenger transport) and potentially 79122 (tour operator). The exact codes depend on primary revenue activities and must be verified against the current OSS system before registration. KBLI codes determine which downstream permits are available, so choosing correctly at incorporation matters — adding codes later requires an amendment process.
Is the minimum paid-up capital IDR 2.5 billion or IDR 10 billion?
This is genuinely disputed in the practitioner literature. The investment plan requirement of more than IDR 10 billion per KBLI per location is consistent across sources. The paid-up capital floor has been cited as both IDR 10 billion (older guidance) and IDR 2.5 billion (claimed effective October 2025 under BKPM Reg 5/2025). This inconsistency should be verified against the in-force Ministry of Investment regulation with a licensed consultant at the time of your application — do not rely on any single advisory source, including this page.
Do I need a separate permit to run a dive operation inside the Raja Ampat Marine Park?
Yes. Commercial tourism activities inside the Raja Ampat MPA network require permits from the Marine Park Authority (UPTD BLUD), in addition to the national OSS business license (NIB) and any sector-specific Dinas Pariwisata permits. Liveaboard operations need mooring and route permits; dive centres near sensitive reef sites may be subject to site-use agreements. There are also separate visitor conservation tag requirements (IDR 700,000 per foreign visitor, 12-month validity) that operators must account for in their pricing and guest-processing workflows. Confirm current permit requirements directly with the UPTD at the Waisai office.
Can I use a nominee shareholder to hold my Raja Ampat resort through a local PT instead of a PT PMA?
No. Nominee arrangements — where an Indonesian national holds shares on behalf of a foreign investor under a side letter or trust deed — are explicitly illegal under Article 10(1) of Law No. 25/2007 on Investment. Penalties include company dissolution, asset forfeiture, and criminal liability for both parties. Indonesian courts do not enforce nominee agreements. In Raja Ampat specifically, the combination of strengthened Papuan indigenous rights (Law No. 2/2021) and the social complexity of adat land arrangements means that an investor with no formal legal ownership has no standing in any dispute with the community or with regulators. The PT PMA structure exists precisely to allow legitimate foreign ownership — use it.