Can Chinese citizens buy property in Bali? Not freehold. That is a citizenship rule, not a Chinese one.

Can Chinese citizens buy freehold property in Bali?

No. Article 21(1) of the Basic Agrarian Law (Law No. 5 of 1960) provides that only Indonesian citizens may hold Hak Milik, the right of ownership recorded on an SHM certificate. It is a citizenship test, not a visa test or a residence test, and it applies to all foreign nationals.

This is the single fact that decides how a Bali listing should be read. When an English language listing says freehold, the Indonesian document behind it is an SHM, and an SHM cannot be issued to a foreign national. The reforms that changed a great deal else in Indonesian land law, including the Job Creation Law and its implementing regulation, did not move the citizenship gate.

The full explanation of the certificate and the gate: Sertifikat Hak Milik, explained.

What can a mainland Chinese buyer actually register in Bali?

Hak Pakai, the right of use, is the only registered land title a foreign individual can hold in their own passport name, and it requires a valid Indonesian immigration document. A foreign owned Indonesian company, a PT PMA, can hold Hak Guna Bangunan, the right to build. Hak Sewa is a contractual lease.

Under Government Regulation No. 18 of 2021, Hak Guna Bangunan and Hak Pakai both run on a 30 year initial grant, extendable by 20 years and renewable for a further 30. Those extensions are applications, not automatic rollovers: you re-apply, you pay, the land office reissues.

Hak Pakai also carries provincial minimum price thresholds and residential zoning requirements, and in practice the land office works to a KITAS, a KITAP or a Second Home Visa. So the immigration document is not an afterthought for a mainland buyer, it is a precondition of the title.

The two routes in detail: Hak Pakai explained and the PT PMA route.

What do China's foreign exchange rules say about buying property abroad?

SAFE, the State Administration of Foreign Exchange, publishes an individual facility with an annual total equivalent to USD 50,000 per person. Overseas property purchase is not among the uses the individual foreign exchange purchase application form permits. A mainland buyer should take professional advice on lawful routes before committing.

The annual total is set out in Article 2 of the Detailed Rules for the Measures for the Administration of Individual Foreign Exchange, which give the figure as the equivalent of 50,000 dollars for each person every year. SAFE's own explanation of those rules separates current account items, which run under that annual amount, from capital account items, which carry their own approval and registration steps.

Since 2017, an individual buying foreign exchange completes an application form stating the purpose. As SAFE's own form states, it does not permit the foreign exchange to be used for property, securities or dividend paying insurance products abroad.

Read that together with the Bali timeline and the order becomes obvious. Settle the funding question with a qualified professional first, then the immigration document, then the title. A deposit paid before the first two are answered is the expensive way to discover them.

This page states the rules as published and does not set out ways around them. A villa agent in Bali is not a source of advice on Chinese foreign exchange law.

Does a 2025 Indonesian regulation open freehold to foreign buyers?

No. Government Regulation No. 28 of 2025 is a risk based business licensing regulation. It changes how permits are processed. It does not change who may hold which land right, and the citizenship gate on Hak Milik in Article 21(1) of the Basic Agrarian Law is untouched.

This matters because the claim circulates in listings aimed at foreign buyers, and a buyer reading in a second language is the one most likely to be handed it. If a page tells you a 2025 regulation opened freehold to foreigners, it is describing licensing reform and calling it something else.

The permits that regulation does touch are real and worth checking on any villa: the building approval, the function certificate and the spatial planning conformity. That is a due diligence list, not an ownership route.

What should a Chinese buyer check before paying anything in Bali?

Four documents, in this order: the seller's underlying certificate and what right it actually records, the buyer's own immigration document, the building and spatial planning permits, and the written terms of any extension. Nothing about that list is nationality specific, and all of it is checkable before a deposit.

• The right on the certificate. An SHM in a seller's name is not a right that can pass to you. Read what is being converted, by whom, and on what timetable.
• The immigration document. Hak Pakai in a personal name works to a KITAS, a KITAP or a Second Home Visa in practice.
• The permits. The building approval and function certificate under Government Regulation No. 16 of 2021, and spatial planning conformity under Government Regulation No. 21 of 2021.
• The extension terms. A 30 year grant with an extension application is not the same asset as a perpetual one, and it should not be priced as if it were.

The full checklist: Bali villa due diligence, and the lease question in full: freehold versus leasehold in Bali.

Header photo: Unknown, CC0, via Wikimedia Commons. All credits: image credits.