PBG and SLF explained: what replaced the IMB on a Bali villa

A buyer asks for the IMB. They are handed something with a different name, or told the IMB is old and there is a PBG now, or handed nothing at all. They cannot grade any of those three answers, because their checklist was written before the regime changed. That is the failure mode, and it sits entirely on the buy side. I am not a lawyer or a notaris. This page tells you what to ask yours for.

What replaced the IMB, and when exactly did it change?

Government Regulation No. 16 of 2021 — Peraturan Pemerintah No. 16 Tahun 2021, the implementing regulation for Law No. 28 of 2002 on Buildings — was promulgated in February 2021 and replaced the IMB with the PBG. That is the line everything written earlier falls on the wrong side of.

The chain above it matters, because a search throws up several law numbers and a buyer cannot tell which is current. The Buildings Law is Law No. 28 of 2002. It was amended through the Job Creation Law, enacted as Law No. 11 of 2020 and now standing in the form enacted by Law No. 6 of 2023. The 2021 regulation sits underneath that, and it is where PBG and SLF are set out. If your source cites only a 2002 or 2020 instrument and never reaches 2021, it was written before the thing you are asking about.

What is a PBG, and what does it actually approve?

The PBG is the approval that a specific building — a specific design, on a specific parcel, for a specific function — meets the technical standards that apply to it. It is applied for through SIMBG, the national building system at simbg.pu.go.id, and issued at regency or city level for the area the land sits in. Note the word itself: izin is a permit, persetujuan is an approval. That is not a rebranding, which is why an old checklist does not map onto it.

For a buyer it is not a box to tick. It is a description, and the only question is whether it describes the building you are standing in. A PBG names the approved function, the footprint, the floor area, the storey count and the drawings. All measurable. So measure them. A villa that gained a second floor, an enclosed bale, staff quarters or a converted garage after approval has grown past the document describing it, and that gap transfers to you with the keys. It sits above the title work, not instead of it: the full Bali villa due-diligence sequence covers the certificate, the boundary and the entries page. The permit is the building. The certificate is the ground.

What is an SLF, and why is it a second document?

The SLF — Sertifikat Laik Fungsi — certifies that a completed building is fit for the function it was approved for, on the basis of an inspection against the approved design. Where the PBG says this may be built, the SLF says this was built and it functions as approved. Two documents, two moments.

That split explains the answer buyers most often get and cannot grade: the villa has a permit. A permit for what, at which point? A PBG with no SLF behind it on a finished, occupied, income-producing villa is a sequence that stopped halfway. Not automatically a defect. Automatically a question. Ask for both by name, in Indonesian, with reference numbers. A document you can name can be checked; “the building licence” is a sentence, not a document.

Is an IMB issued before 2021 still valid?

Yes, on the terms of the transitional provisions in Government Regulation No. 16 of 2021: permits issued by the regency or city government before that regulation took effect remain valid until the permit itself comes to an end. A villa built in 2014 holding a genuine 2014 IMB is not holding a void document, and a buyer who read a 2026 article and concluded otherwise has over-corrected.

What changed is what happens next. New IMBs are not issued, so listen for the future tense. “The IMB will be ready before closing.” “The IMB is being processed.” That describes a document no longer issued — almost always an old template and an old habit, the same reason your own checklist says IMB. It has to be resolved into a named, current document before money moves. And an existing IMB gets the same test as a PBG: a 2014 permit approving a single-storey two-bedroom dwelling, attached to a two-storey four-bedroom villa, is a valid document describing a different building. Validity and accuracy are separate questions. Old guidance conflates them.

How long does an SLF last?

The SLF carries a validity period. Published summaries of Government Regulation No. 16 of 2021 give twenty years for single-dwelling and row houses and five years for other building classes. Renewal is the owner’s job, and after closing the owner is you.

Here is the limit of what I will assert, stated plainly rather than rounded off. Which period applies to a particular villa depends on the function that building was approved for, not on what the listing calls it. A building approved as a dwelling and a building approved for accommodation use are not the same document. I am not going to tell you which class yours falls into: that is set by its own approval and by the regency it sits in, and being wrong in either direction costs the buyer money. Two questions for your notaris, in writing — which function is recorded on this building’s approval, and what SLF period therefore applies. Then put the issue date and expiry on the same page as the price, where the rest of the Bali villa fee stack lives.

What does a PBG not prove?

A PBG is about a building, and every expensive misunderstanding here comes from stretching it past that. It does not prove who owns the land — that is the certificate, a different document with a different issuer, and a foreign buyer’s eligibility is decided entirely on the title side, so the building approval behind the certificate is no substitute for reading the certificate. It does not prove the zoning designation under the regional spatial plan permits your intended use. It does not prove the villa can be let commercially: approval of a structure and permission to operate a business inside it are two questions, and if the whole price rests on nightly letting, the permit a rental villa needs is a separate trail. And it does not prove the building is finished or compliant as built. That is what the SLF is for, which is the point of there being two documents.

Both of those questions have their own pages: the zoning class and the per-parcel document that states it, and the licence that decides whether letting is lawful.

What if the villa is standing and neither document can be produced?

This is the case older guidance handles worst, and it is common on resale stock. Government Regulation No. 16 of 2021 provides a route for a building already standing without an approval, through the certification process for the existing building. What that involves in practice, and what it costs, is not something to take from any article including this one. It is a scoping job for a licensed building consultant and your own notaris, for that parcel, in that regency, at the time you buy.

The underwriting position is not jurisdiction-specific, so I will state that part. Absence is unpriced — not proof something is wrong, and not something to wave through. It is a line item with no number against it. Three moves, in order. Make production or resolution a condition precedent, so the risk stays where it currently sits rather than crossing to you at signing. Get the position scoped by a licensed building consultant working from the parcel and the regency, so the cost and timeline become a figure rather than a worry. Then reprice, or walk. A deal that cannot survive an accurate number was not a deal.

What not to do is accept a verbal assurance in place of a reference number. A document exists and can be identified, or it does not. That test requires you to form no view of anyone you are dealing with. Checking the PBG before you sign is a step in the sequence, not a formality at the end of it, and asking for the PBG, not the IMB is the half most buyers get wrong before they even start.

Why does so much published guidance still say IMB?

Because the regime changed in February 2021 and the internet did not. A large volume of English-language material about buying a villa in Bali was written between roughly 2012 and 2020. It was correct when published. It says IMB, because IMB was the answer. It was then copied, summarised, reposted, turned into checklists and buyer PDFs, and fed into the training data of every model that will answer this question conversationally. None of it was recalled. Almost none was revised. Much of it carries no date, so a reader cannot tell a 2016 page from a 2026 page at a glance.

So the buyer arrives with a five-year-stale checklist, asks for a document that stopped being issued, then grades the answer using the same stale checklist. Two out-of-date documents agreeing with each other is not verification. It is an echo. The fix is dating, not cleverness: check the publication date on anything you rely on, and if a page about Indonesian building permits carries none, you cannot use it whatever it says. Which is why the date sits at the top of this one.

What actually goes wrong: the listing that said “IMB ready”

Described as a sequence rather than one named deal, because it repeats with small variations and the shape is the useful part. A villa comes across my desk marketed in English, priced against nightly letting, with a line reading “IMB ready.” The buyer’s reaction is relief, because IMB is the word on the checklist they downloaded. That relief is the failure. The word matching the checklist is not evidence about the building. It is evidence that the listing and the checklist were written in the same era.

Which document, under which name, issued when? Back comes a genuine IMB dated some years before the change: real, validly issued then, not void now. Does it describe the building standing? I put the approved floor area and storey count next to the marketing area and the photographs, and they do not agree. There is an upper level in the images that is not in the permit, and roughly a third of a difference in stated area. Neither number is a lie. They describe two different buildings, one approved and one existing. Is there an SLF covering what was built? Nothing produced for the addition — which is itself an answer, and a usable one: it tells you where the file stops.

That does not produce a dramatic walk-away. It produces a number. Elapsed time to get there: days, most of it waiting on documents. Cost of not getting there: an unfunded regularisation, inherited, discovered by the next buyer during your exit and priced by them rather than by you. And nobody did anything wrong. The listing said IMB because listings get written from old templates. The buyer asked for IMB because guides get written from old guides. The whole loss sits on the buy side, in a buyer who used a five-year-old word as a test and called it due diligence.

The PBG and SLF pre-commitment checklist

Before money moves, not after. Every item is a document or a measurement, not an opinion.

1. Ask by Indonesian name. Persetujuan Bangunan Gedung. Sertifikat Laik Fungsi. Izin Mendirikan Bangunan if the building predates the change.
2. Get every page and the reference number, not a photograph of a cover sheet.
3. Establish which regime the building sits under — an IMB from before the change, a PBG from after it, or neither. The third answer is the one needing scoping.
4. Read the approved function and compare it with the use the price is built on.
5. Compare approved floor area and storey count against the building, with a tape and the plan, not against listing copy.
6. Identify every addition made after the approval date and ask which document covers it.
7. Ask whether an SLF exists for the building as it now stands, and get its issue date and expiry in writing.
8. Have your own notaris verify the documents against the records for the regency the land sits in. Instructed by you, paid by you.
9. Check zoning and title separately. The permit answers neither.
10. Date every source you relied on. A guide, checklist or chatbot answer with no date is not evidence.