Introduction
Now that you've met Indonesia's national standards with your company now established, your accounting and tax systems in place, and your hiring and hr practices are legal and compliant, you now need to ensure that you're also compliant and able to operate at the regional/local level.
In Part 6 – Local Registrations in Indonesia – NPWPD & Regional Compliance, we shift focus to the regional level. This information primarily applies to hospitality businesses including restaurants, hotels and short term accommodation providers.
You will learn about NPWPD's, municipal tax obligations, and how local regulations integrate with OSS-RBA to complete your compliance profile.
If you haven't read our first five parts of this series make sure you check out
Part 1 – How to Open a Foreign-Owned Company (PT PMA) in Indonesia
Part 2 – Indonesia KBLI Codes & Business Licences Explained
Part 3 – Accounting Setup for PT PMA Companies in Indonesia
Part 4 – Financial & Tax Reporting in Indonesia – PSAK Statements & Annual SPT Filing
Part 5 – Indonesia HR Compliance Guide – Employment Contracts, Payroll & BPJS
1. Why Local Compliance Matters
Indonesia’s governance system delegates significant power to regional governments (Pemda) under Law No. 23 of 2014 on Regional Autonomy.
That means even a fully licensed PT PMA (with NIB, NPWP, and OSS permits) must still meet local obligations at the province and district level to operate legally.
Local compliance includes:
- Registration for a regional tax number (NPWPD)
- Filing and payment of local taxes (PBJT, PHR, advertising, groundwater, etc.)
- Registration with the local Manpower Office (Disnaker)
- Approval of environmental and zoning documents (SPPL / UKL-UPL / AMDAL)
- Holding a valid building utilisation certificate (SLF)
Failing to meet these requirements can result in closure of the business premises, local fines, or even national licence suspension through OSS.
2. Indonesia’s Multi-Layered Licensing System
Level | Authority | Key Registrations / Permits | Example |
National | BKPM / OSS-RBA | NIB, Standard Certificates, NPWP, BPJS, RPTKA | Company establishment, national compliance |
Provincial | Provincial Government | Regional taxes (e.g., motor vehicle, fuel, groundwater), environmental coordination | Bali Provincial BPBD & Dinas Lingkungan Hidup |
Regency / City (District) | Bapenda (Tax), Disnaker, Satpol PP, Dinas Pariwisata | NPWPD, PBJT/PHR filings, TDUP, Disnaker registration | Denpasar City / Badung Regency for most Bali PMAs |
Local taxes and permits vary between provinces and even regencies, but the core logic is consistent:
no NPWPD = no legal operation at the site level.
3. What is NPWPD (Nomor Pokok Wajib Pajak Daerah)?
The NPWPD is the Local Taxpayer Identification Number, issued by the Regional Revenue Office (Bapenda).
It is the local equivalent of the national NPWP (tax ID), but specifically for taxes managed by the district.
Legal Basis:
- Law No. 1 of 2022 on Financial Relations between Central and Regional Governments
- Regional Tax Regulations (Peraturan Daerah / Perda) of each regency or city
Purpose:
- To register your business premises under the local tax database.
- To enable the payment of regional taxes (such as PBJT or PHR).
- To allow inspection and verification by the local government.
Without NPWPD, your company technically cannot collect or remit local taxes — which means it cannot legally invoice or operate within that district.
Example – NPWPD in Practice
Business Type | Example KBLI | Local Requirement | Tax Type | Responsible Office |
Villa / Hotel Operator | 55900 | Must register NPWPD under the Bapenda where property is located | PBJT (Hotel Tax) | Badung or Gianyar Bapenda |
Restaurant / Café | 56101 | Register NPWPD at premises location | PHR (Restaurant Tax) | Denpasar or Badung Bapenda |
Consulting Office | 70209 | NPWPD required for local property tax and signage | Advertising Tax | Denpasar Bapenda |
Real Estate Leasing / Co-working | 68200 | NPWPD required for PBJT or rental tax | PBJT | Bapenda where asset located |
In Bali, NPWPD is handled by:
- Bapenda Kota Denpasar – for most commercial areas,
- Bapenda Kabupaten Badung – for Seminyak, Canggu, Jimbaran, Uluwatu,
- Bapenda Kabupaten Gianyar – for Ubud and surrounding regions.
Each office issues a unique NPWPD number (format: 00.xx.xxxx.xx-xxx.xx) tied to your company’s address.
4. NPWPD vs NPWP – How They Work Together
Identifier | Managed By | Scope | Purpose |
NPWP | Directorate General of Taxes (DJP) | National income, VAT, corporate tax | National-level taxation |
NPWPD | Local Government (Bapenda) | Local taxes: hotel, restaurant, advertising, groundwater, parking | District-level taxation |
A PT PMA needs both:
- NPWP – to file monthly and annual corporate income tax.
- NPWPD – to file local taxes based on physical operations.
These systems are not integrated automatically; you must apply separately to the relevant Bapenda.
5. PBJT & PHR – The Core Local Taxes
Two regional taxes apply to most foreign-owned businesses operating physical premises:
A. PBJT (Pajak Barang dan Jasa Tertentu) – Hotel Tax
- Applies to temporary accommodation, including hotels, villas, and guesthouses.
- Calculated as a percentage of the gross rental revenue (usually 10 %).
- Collected from guests and remitted monthly by the operator.
- Payable even if booking platforms (Airbnb, Booking.com) collect payment abroad; the operator must still report the gross amount.
Example: A villa operator earns IDR 200 million gross in April.
→ PBJT = 10 % × 200 million = IDR 20 million, payable by the 15 th of May.
B. PHR (Pajak Hotel dan Restoran) – Restaurant Tax
- Applies to food & beverage sales consumed on-site.
- Standard rate 10 % of gross sales, excluding VAT.
- The restaurant charges this to the customer and remits monthly.
Example : A café bills IDR 5 million in daily sales (before VAT).
→ PHR = 10 % × 5 m = IDR 500 000/day, aggregated and paid monthly.
Local Example (Bali) : Badung Regency (Perda No. 15/2011) and Denpasar
(Perda No. 3/2023) both fix PBJT/PHR at 10 %.
Other Local Taxes (Depending on Operations)
Tax Type | Description | Typical Sector | Rate Range |
Advertising Tax (Pajak Reklame) | For outdoor signage, billboards, and LED boards | All sectors | 5–25 % of advertisement value |
Groundwater Tax (Pajak Air Tanah) | For wells or bore water usage | Hospitality, manufacturing | 20 % of extraction value |
Parking Tax | For paid parking facilities | Hotels, malls | 20 % of parking fees |
Entertainment Tax | For bars, clubs, or ticketed events | Tourism | 10–50 % depending on activity |
Each of these requires prior NPWPD registration and is enforced by Bapenda inspectors (Petugas Pajak Daerah), who may perform spot audits.
6. Disnaker Registration (Manpower Office)
Once you begin employing staff, your business must also be recorded at the local Department of Manpower (Disnaker)—separate from national BPJS and tax registrations.
Purpose | Requirement | Responsible Office | Notes for Bali PT PMAs |
Company Manpower Registration | File a company manpower profile including KBLI, address, and workforce list | Disnaker Kota Denpasar or Disnaker Kabupaten Badung | Issued a unique Company Manpower Registration Number (NPPK) valid 2 years |
Workplace Report (Laporan Ketenagakerjaan Perusahaan) | Annual workforce data report | Same Disnaker office | Lists total employees (local & expat), wage ranges, BPJS numbers |
Work Accident Reporting | Report any occupational incident within 2 × 24 hours | Same office / BPJS branch | Linked to JKK program verification |
Why it matters:
Disnaker registration completes your manpower profile within the province. If you operate without it, the local government can issue a cease-operation letter even if your national licences are valid.
7. Environmental and Zoning Compliance (SPPL, UKL-UPL, AMDAL, SLF)
A. Why Environmental Approval Is Mandatory
Before any PT PMA may operate physically, it must obtain the appropriate environmental instrument under the OSS-RBA risk-based system.
These permits prove that your operations comply with local environmental impact standards and zoning rules.
Instrument | Full Name | Risk Level (OSS-RBA) | Typical Use Cases | Issued By |
SPPL | Surat Pernyataan Pengelolaan Lingkungan (Environmental Statement Letter) | Low risk | Offices, consulting firms, co-working spaces | Dinas Lingkungan Hidup (DLH) City/Regency |
UKL-UPL | Upaya Pengelolaan Lingkungan / Upaya Pemantauan Lingkungan | Medium risk | Restaurants, small hotels, villa complexes (< 50 rooms) | DLH + OSS |
AMDAL | Analisis Mengenai Dampak Lingkungan | High risk | Large resorts, factories, construction > 5 ha | Provincial DLH + Ministry of Environment |
SLF | Sertifikat Laik Fungsi (Building Feasibility Certificate) | All physical buildings | Required before operation or rental | Dinas PUPR (Building and Housing Office) |
Example – Villa Operator in Badung:
A 10-villa complex under KBLI 55900 (sub-20 rooms) is classified medium risk.
→ Needs a UKL-UPL filed through OSS, approved by DLH Badung, plus an SLF after construction.
Example – Consulting Office in Denpasar:
Classified low risk → only an SPPL required.
Issued within 7–10 working days by DLH Denpasar.
B. Relationship with Other Licences
Environmental approvals are cross-checked when you apply for TDUP (tourism licence), NPWPD, or building registration. Incomplete SPPL/UKL-UPL often delays NPWPD issuance for F&B and villa operators.
8. Step-by-Step: How to Register NPWPD in Bali
Each regency has its own procedure, but the workflow is similar across Bapenda offices.
Documents Required
- Deed of Establishment + MoLHR Approval
- NIB from OSS-RBA
- NPWP (Tax ID)
- Business Domicile Letter (Surat Keterangan Domisili Usaha)
- Lease Agreement or Land Certificate
- KTP and Tax ID of Director / Commissioner
- Photo of premises and building permit (IMB / SLF)
- Environmental approval (SPPL / UKL-UPL / AMDAL)
- TDUP (if hospitality or F&B sector)
Registration Process
Step | Action | Responsible Office | Duration |
1 | Submit application with documents | Bapenda front office or online portal | 2–5 days |
2 | Site inspection (optional for F&B / villas) | Local Bapenda officer | 3–7 days |
3 | NPWPD number issued and QR certificate emailed | Bapenda | Within 10 working days |
4 | Company added to local tax database for monthly PBJT/PHR filing | — | — |
Local Note (Badung vs Denpasar):
- Badung Bapenda requires on-site photo verification before issuing NPWPD for hospitality premises.
- Denpasar Bapenda allows remote application via the e-Pajak Denpasar portal if supporting documents are digitally signed.
9. Monthly Reporting & Payment Deadlines
Tax Type | Return Due Date | Payment Deadline | Submission Method |
PBJT (Hotel Tax) | 15 th of following month | Same day | Manual form or e-PBJT portal |
PHR (Restaurant Tax) | 15 th of following month | Same day | e-PHR portal |
Advertising Tax | Before display period | Before installation | e-Reklame or manual form |
Groundwater Tax | Monthly usage report | 15 th monthly | e-Air Tanah portal |
Parking Tax | Monthly | 15 th monthly | Manual form (Badung) |
Payment Channels : Local banks (BPD Bali), Virtual Account Bapenda, or E-Billing system.
Penalties for Late Payment : 2 % per month on unpaid tax + administrative fine of IDR 50 000 – 500 000 per return depending on Perda.
10. Local Audit & Enforcement
A. Routine Inspections
Local revenue officers (Petugas Pajak Daerah) conduct spot audits to compare declared sales with actual transactions (e.g., POS data, booking records, or Odoo reports).
They can request:
- Sales summaries and guest folios
- Bank statements linked to business income
- Copies of leases and licences
B. Cross-Check with National Tax Data
Under Law 1/2022, local and national tax offices share data through the Joint Tax Portal.
If your PHR/PBJT filings are too low relative to NPWP VAT reports, expect a clarification letter (Surat Teguran).
C. Sanctions and Closure
- Repeated non-filing = temporary closure by Satpol PP.
- Fraudulent under-reporting = back-tax + interest + penalty up to 2 × tax owed.
- Unregistered business = OSS licence suspension via BKPM notification.
Bali Context: Since late 2024, Badung Regency has stepped up data-matching between booking platforms and PHR filings for villas. Non-registered operators now face immediate NPWPD back-registration and retrospective tax assessment of up to five years.
11. Common Local Compliance Mistakes and How to Avoid Them
# | Mistake | Why It Happens | Risk / Consequence | Corrective Action |
1 | Operating without NPWPD | Business assumes OSS + NPWP is enough | Treated as unregistered taxpayer; subject to back tax and closure by Satpol PP | Register NPWPD with Bapenda before opening premises |
2 | Using a virtual office for physical activity | Address does not match zoning | Bapenda rejects NPWPD or issues temporary permit only | Secure zoning-compliant lease and SPPL/UKL-UPL |
3 | Late payment of PBJT/PHR | Poor coordination between finance and operations | 2 % monthly interest + fine up to 500 000 IDR per return | Automate monthly filing calendar and reminders in Odoo |
4 | Under-reporting sales figures | Cash transactions not recorded in POS | Audit adjustment + double tax penalty | Integrate POS with Odoo Accounting and Bapenda e-filing |
5 | No environmental permit (SPPL/UKL-UPL) | OSS file incomplete during licensing | NPWPD and TDUP delayed or denied | File SPPL with DLH before local licence application |
6 | Ignoring Disnaker registration | HR focus limited to BPJS | Labour inspection fine and notice of violation | Submit NPPK to local Disnaker and update every 2 years |
7 | Missing SLF (Building Feasibility Certificate)** | IMB/SLF not renewed after renovation | Building use deemed illegal; utilities permits revoked | Obtain new SLF through Dinas PUPR post-renovation |
8 | Treating Bali regencies as one jurisdiction | Multi-location business operates under single NPWPD | Each regency can audit and tax separately | Register one NPWPD per business location |
9 | Neglecting cross-link with national tax data | Local and national sales reports don’t match | Data-sharing audit between Bapenda and DJP | Align Odoo chart of accounts for NPWP and NPWPD reporting |
12. Local Compliance Checklist for PT PMA Employers and Operators
Before Opening
- Verify zoning (“Perda RTRW”) for chosen address.
- Obtain SPPL / UKL-UPL / AMDAL as required.
- Complete building permit (IMB or SLF).
- Register NPWPD with relevant Bapenda (regency of operation).
- Register company and employees with local Disnaker.
Monthly Operations
- File and pay PBJT and/or PHR tax by the 15 th each month.
- Keep sales and guest records for 5 years for audit.
- Reconcile POS data with NPWP and NPWPD reports.
- Maintain BPJS and payroll filings on schedule.
Annual Requirements
- Renew SPPL / UKL-UPL if activity changes.
- Renew Disnaker registration every 2 years.
- Conduct internal compliance audit (Q1 each year).
- Cross-check national tax vs local sales before annual SPT.
Expansion or Relocation
- Secure new SPPL and NPWPD for each new site.
- Confirm zoning and environmental classification before signing leases.
- Update OSS profile to include new location data.
13. Regulatory References
Domain | Regulation | Key Points |
Regional Autonomy | Law No. 23 of 2014 | Defines division of authority between central and regional governments |
Fiscal Decentralisation | Law No. 1 of 2022 | Establishes framework for regional taxes and revenue sharing |
Hotel and Restaurant Tax | Perda No. 3 of 2023 (Denpasar) / Perda No. 15 of 2011 (Badung) | Sets 10 % rate for PBJT and PHR |
Environmental Permits | GR No. 22 of 2021 + MoE Reg. No. 5 of 2021 | Governs SPPL, UKL-UPL, AMDAL procedures |
Building Use Certificates | Minister of PUPR Reg. No. 16 of 2021 | Details IMB → SLF transition |
Manpower Registration | Law 13 of 2003 & MoM Reg. No. 7 of 2021 | Requires NPPK and annual workforce report |
Tax Coordination | MoF Reg. No. 147/PMK.07/2023 | Enables data-sharing between DJP and Bapenda |
14.
How SatuSolusi Can Help (Regional & National Integration)
Launching a PT PMA in Indonesia requires navigating two systems that rarely speak to each other — national licensing (OSS, NPWP, BPJS) and regional administration (NPWPD, Bapenda, Disnaker, DLH).
SatuSolusi Consultancy bridges that gap for foreign businesses so operations remain seamless and fully compliant.
Our Local Compliance Services
- NPWPD application and registration across Bali and other provinces
- PBJT / PHR monthly tax filing and automation through Odoo
- Environmental licence ( SPPL / UKL-UPL ) preparation and DLH submission
- Zoning and building (SLF) audit for property and hospitality projects
- Disnaker registration and annual workforce reporting
- Multi-branch licence coordination for operators across regencies
Why Bali-based investors choose SatuSolusi:
- We maintain active liaison with Bapenda Denpasar, Badung, and Gianyar, and DLH Bali Province.
- We integrate your regional filings with national accounting and tax systems (Odoo ERP implementation).
- We train your local finance and HR teams on monthly compliance rhythm so obligations never fall through gaps.
Conclusion
NPWPD registration and regional tax compliance close the final gap in your PT PMA’s regulatory obligations. Together with OSS-RBA, BKPM, DJP, and BPJS requirements, these local registrations ensure your business operates lawfully across both national and regional levels — with no blind spots in your compliance profile.
If you’re following this series, Part 1 to Part 5 outlined the full national framework: incorporation, licensing, accounting setup, PSAK reporting, SPT filings, and HR compliance.
This concludes the core compliance roadmap for PT PMA companies. The next cycle of guides will explore operational optimisation, tax planning, and scaling strategies to help foreign businesses grow efficiently in Indonesia.
Questions about regional licensing
or tax? Let’s talk, book a 30-minute consultation at info@satusolusiconsultancy.com