Consilio Consulting Asia

Agrarian Reform Law 2026: what it means for land and leases in Bali

The DPR approved the Agrarian Reform Law (Undang-Undang Pengaturan Reforma Agraria) in plenary session on 22 September 2026. A working committee had spent five days on it the week before and brought it down to 14 chapters and 53 articles. At the date of writing the law has no number and the signed text has not been published. The Constitution makes a bill law 30 days after joint approval even if the President does not sign it, which puts the latest date at around 22 October. On 1 October the President swore in the head of the agency the law creates.

Most of the reporting so far has been about plantations, because the largest obligations fall on companies holding big HGU concessions. HGU (Hak Guna Usaha) is the right to cultivate state land for agriculture, plantations or fisheries, granted to companies for decades at a time, and it is the title most oil palm and rubber estates sit on. HGB (Hak Guna Bangunan) is the right to put up and own buildings on land that belongs to someone else or to the State, and it is the right a PT PMA uses to hold land. For anyone who holds a lease, an HGB or a PT PMA in Bali, a shorter list of provisions is relevant, and almost all of them wait on implementing regulations that have not been drafted yet. Below is what has been reported about the passed version, and what we would check on land you hold or are about to sign for.

Where the law stands on 2 October 2026

Item Status
Approval by the DPR 22 September 2026, in plenary
Length 14 chapters and 53 articles. The DPR’s own draft of 8 September had 70 articles, so its numbering does not carry over
Law number and signature Not yet published
Law without signature Around 22 October 2026, 30 days after joint approval under Article 20(5) of the Constitution
The agency Called Lembaga Penyelenggara Reforma Agraria in the final text. Its head, Komjen Pol Dedi Prasetyo, was sworn in on 1 October under the earlier name, Badan Reforma Agraria Nasional, by Presidential Decree 105/P/2026. He has said the body cannot yet operate fully while its structure is set up
Implementing rules Thirteen instruments in preparation, eight government regulations and five presidential regulations, with no published timetable

Since the final text is not public, what follows comes from the DPR’s official release, statements by members of the working committee, and press reports on the passed version. Where those sources disagree, we say so.

The provisions that reach Bali

Provision As reported What still decides its effect
Land that can become reform land Abandoned land, absentee farmland, accretion land on the coast (tanah timbul), land held above the maximum, land surrendered voluntarily, state land occupied in good faith for 20 years or more, and land in conflict A parcel has to be designated as reform land before anything happens to it
Maximum holdings Counted across a company and its affiliates together, with a stated aim of bringing the land Gini ratio to 0.30 The limits themselves will be set by government regulation, and will differ by region
Small islands and the shoreline A single right held by one person or company may not cover a whole small island, and committee members describe a similar restriction for parcels directly bordering the coastline Left to a government regulation
What was taken out Land for National Strategic Projects, HPL held by the Land Bank or by state enterprises, and military land. Free trade zones and free ports are excluded from priority locations unless the land is in conflict (reported as Article 16(5)) Already in the passed text

Absentee land is the item most likely to come up in Bali. The rule behind it is old. Since Government Regulation 224 of 1961, an owner of agricultural land who lives outside the subdistrict (kecamatan) where the land lies has had to move there or transfer the land within six months. The new law gives that land a route into reform, and a good deal of the farmland around Bali’s tourism areas is owned by people who live elsewhere, some of it let on long leases to foreigners or to PT PMAs.

A lease over Hak Milik land is a contract with the owner, and it sits on the owner’s certificate. The reported provisions say nothing about tenants of land that is designated for reform, so the place to look is the owner’s title, the owner’s domicile and the history of the plot. Our checklist before signing a lease covers the rest of that review.

What is not yet known

The 8 September draft gave the agency power to suspend registration and transfers of land in conflict (its Article 14), and said that the agency’s decisions would apply in full if ministries and regions did not carry out corrective measures within 30 days (its Article 40). No report on the passed version says whether either survived.

Reports on the criminal provisions do not agree. One describes the maximum sentence as cut from five years to four. Another lists three offences: taking control of reform land by threats, up to six years and eight in aggravated cases; transferring reform land to hide who controls it, four years or IDR 200 million (about USD 12,100); and transferring rights to stay under the maximum holding, two years or IDR 200 million. Neither gives article numbers, and we will update this when the text is published.

The regional maximums, the shoreline rule and the structure of the agency all depend on regulations that are still being prepared.

For HGU holders

Holders of HGU and plantation permits must provide at least 20 percent of their land for reform, inside the concession, or an equivalent share of profit. The September draft gave existing holders one year to comply. Few of our clients hold HGU, so we mention it only for completeness.

What we would check now

Check Why it matters under the new law
Where the owner of agricultural land lives Absentee farmland is among the reported categories of reform land
Any past or current dispute over the plot Land in conflict is a category, and the draft allowed land administration to be suspended on it
Whether the plot is on the shoreline or was formed by accretion Both are named in the reported provisions
Total land held across your group of companies The maximum is counted across affiliates
Overlap with forest estate or with another right Overlapping land is in scope
What your lease says if the owner’s title is restricted The tenant’s position follows the owner’s title, and most Bali leases are silent on this

Questions we are being asked

Is the Agrarian Reform Law in force?
It was approved on 22 September 2026 and becomes law when the President signs it, or around 22 October if he does not. Most of its provisions also need implementing regulations before they can be applied, and none has been issued.

Can the land under my villa lease be taken for reform?
Only land designated as reform land through the process the law sets up. The reported categories are abandoned, absentee, accretion, conflicted and excess land, plus state land occupied in good faith. Land that falls into none of them is not on the list.

Does the law treat foreigners or PT PMAs differently?
No provision on foreigners or PT PMAs has been reported. The law applies to land, whoever holds it.

My company holds HGB in Bali. Do the maximum limits apply to it?
The limits will be set region by region in a government regulation that has not been issued. They are reported to count a company and its affiliates together.

When will the new agency start work?
Its head was sworn in on 1 October 2026. The presidential regulation setting up its structure has not been issued, and he has said the body is not yet fully operational.

What this means for you today

For most foreigners and PT PMAs in Bali, nothing changes yet. The law cannot be applied until its implementing regulations are issued and the agency is staffed, and a lease over properly titled Hak Milik land, owned by someone who lives in the same subdistrict, with no history of dispute and away from the shoreline, does not fall into any of the reported categories of reform land. The one category whose reach is still open is land held above the maximum, because the maximums have not been set.

The law matters more on agricultural land whose owner lives elsewhere, on plots that have been or are in dispute, and on land along the coast. If you are about to sign or renew a lease on land like that, check the owner’s domicile and the plot’s history first and make sure the lease says what happens if the owner’s title is restricted. If you already hold such land, it is worth doing the same checks now, while no land in Bali has been designated.

Checking land you hold

Send us the certificate number and, if there is one, the lease. We check the owner’s domicile, the history of the plot and its status at the land office, and tell you which of the reported provisions could apply to it. Once the signed text is published we will update this article with the article numbers.


Correct at the date of publication, 2 October 2026. The signed text of the law had not been published, so provisions are cited from the DPR’s official release, statements by members of the working committee and press reports on the passed version. USD figures are approximate, at IDR 16,500 to the dollar. Ask us to check a plot, or know more about property.

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Corporate structuring, licensing and company compliance at Consilio Consulting Asia.

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