{"id":43558,"date":"2026-01-29T23:33:47","date_gmt":"2026-01-29T15:33:47","guid":{"rendered":"https:\/\/visa-indonesia.com\/?p=43558"},"modified":"2026-01-29T23:33:53","modified_gmt":"2026-01-29T15:33:53","slug":"nominee-arrangements-bali-law","status":"publish","type":"post","link":"https:\/\/visa-indonesia.com\/ms\/bali-tips\/nominee-arrangements-bali-law\/","title":{"rendered":"Nominee Arrangements in Bali: Risks, the Law, and Safer Alternatives"},"content":{"rendered":"

If you\u2019ve spent even five minutes around Bali property talk, you\u2019ve probably heard someone say: \u201cJust use a nominee.\u201d It sounds like a quick solution<\/em>. You pay the money, a local name goes on the paper, and you\u2019re the actual owner behind the scenes.<\/p>\n\n\n\n

This is a comprehensive guide to nominee arrangements in Bali: what they are, why people do them, what Indonesian law says, the legal risks, and the legal alternatives that are much safer.<\/p>\n\n\n\n

What are \u201cnominee arrangements\u201d in Bali?<\/strong><\/h2>\n\n\n\n

A nominee is a person who holds something in their name<\/em>, even though someone else paid for it and thinks they are the real owner.<\/p>\n\n\n\n

In Bali, you\u2019ll hear two common types of nominee arrangements<\/strong>:<\/p>\n\n\n\n

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  1. Land\/property nominee<\/strong>: A foreigner pays for land or a villa, but an Indonesian citizen is listed as the legal owner on the certificate. This is often used for freehold land (Hak Milik), because only Indonesian citizens can hold that right.<\/li>\n\n\n\n
  2. Company nominee<\/strong>: Shares in a company are put under a local person\u2019s name (a local nominee) even though the investor behind it is a foreigner. People do this to get around foreign ownership restrictions.<\/li>\n<\/ol>\n\n\n\n

    These are also called nominee structures, nominee setups, or nominee practices. They usually rely on extra side contracts, private agreements, to \u201cprove\u201d who the beneficial ownership holder (the one who really paid and controls it).<\/p>\n\n\n\n

    Here\u2019s the key idea you must lock in: Indonesian agencies like the land office care most about what\u2019s on official records. That means the person on the certificate is generally treated as the legal owner.<\/p>\n\n\n\n

    Why do foreigners use a nominee in Bali?<\/strong><\/h2>\n\n\n\n

    Because the rules feel inconvenient.<\/p>\n\n\n\n

    Indonesia has an Indonesian legal framework<\/strong> that limits certain forms of pemilikan asing<\/strong>, especially for land. The goal is to keep core land rights tied to citizens. Under Indonesian land law<\/strong> (Law No. 5 of 1960, the Basic Agrarian Law), Hak Milik<\/strong> (freehold\/ownership right) is tied to Indonesian citizenship, so foreign nationals can\u2019t just buy it directly.<\/p>\n\n\n\n

    For businesses, foreign investment is regulated as well. People talk about the negative investment list<\/strong> because for years, Indonesia used a \u201cNegative List\u201d approach to restrict which business fields were closed or limited to foreigners. But that system changed: Indonesia introduced the \u201cPositive Investment List\u201d under Presidential Regulation No. 10\/2021 (as amended), replacing the older Negative List framework.<\/p>\n\n\n\n

    So a nominee can look like a shortcut for:<\/p>\n\n\n\n