An operating hotel may already have an NIB, an OSS account and years of commercial activity. That does not automatically establish that every activity performed at the property is correctly classified or that every applicable business license and supporting permission remains aligned with the current operation.
For investors, Hotel Business Licensing Due Diligence in Lombok should therefore examine the complete licensing profile of the business, not simply whether one registration document exists.
Indonesia’s current risk-based business licensing framework is governed by Government Regulation No. 28 of 2025. Tourism businesses must also consider the current sector standards under Minister of Tourism Regulation No. 6 of 2025.
Hotel Business Licensing Due Diligence in Lombok: NIB, KBLI and OSS Checklist
The purpose of licensing due diligence is to compare the hotel that actually operates with the business activities and permissions recorded in government systems.
A useful review asks three separate questions:
- Which legal entity operates the hotel
- Which activities are registered under that entity
- Which licenses and supporting permissions apply to those activities
A positive answer to only one of these questions is not enough to establish the complete regulatory position.
Start With the Legal Entity and NIB
First identify the company or other legal business actor responsible for the hotel operation.
Obtain the current NIB and OSS project information and compare them with corporate documents and the commercial agreements relating to the property.
This is particularly important where the land or hotel building is owned by one party while another company operates the accommodation business.
Confirm Which Entity Receives the Hotel Revenue
The investor should understand which entity contracts with guests and receives revenue from accommodation and supporting activities.
Where different companies operate different parts of the property, licensing should be reviewed at the level of each actual operator rather than assuming one hotel’s NIB covers every business performed at the site.
Map What the Hotel Actually Does
A modern hotel can operate more than accommodation.
Its commercial activities may include:
- Guest accommodation
- Restaurants and cafés
- Bars
- Meetings and events
- Laundry services
- Wellness or spa activities
- Retail activities
- Other tourism or supporting services
The due-diligence process should create an activity map before reviewing KBLI and OSS records.
The key question is whether the registered business activities accurately represent the hotel’s current sources of revenue and operational model.
Check the Hotel Against KBLI 2025
Indonesia now uses KBLI 2025 as the official classification of economic activities under BPS Regulation No. 7 of 2025.
The current OSS KBLI 2025 hotel classification places hotel and hotel-resort activities within sub-group 5510.
Its current subclasses are:
- 55101 for five-star hotel activities
- 55102 for four-star hotel activities
- 55103 for three-star hotel activities
- 55104 for two-star hotel activities
- 55105 for one-star hotel activities
- 55106 for non-star hotel activities
Do Not Choose KBLI From the Property’s Marketing Name
The commercial name used to advertise accommodation does not necessarily determine its legal classification.
For example, OSS distinguishes hotel and hotel-resort activities in sub-group 5510 from other categories of short-term accommodation. The current KBLI 55209 description, for example, includes forms of accommodation such as certain bungalows, cottages, hostels, bed-and-breakfast units, cabins and glamping.
An investor should therefore classify the actual operating model rather than selecting a code solely because the property is marketed as a boutique hotel, resort or villa.
Review Legacy KBLI 2020 Records
Existing hotels may have OSS records originating from the previous KBLI 2020 system.
Because KBLI 2025 is now implemented in OSS, investors reviewing an existing operation should determine whether older business data has been converted correctly. OSS provides an official KBLI 2020-to-2025 conversion process.
This is especially relevant in an acquisition because the buyer should know whether the current OSS profile reflects the hotel’s present activities rather than relying solely on historic licenses.
Audit the OSS Licensing Position
After identifying the correct activity, review the relevant project and licensing records inside OSS.
The checklist should include:
- NIB and legal business actor
- Current KBLI 2025 activities
- Project location
- Scope of the registered hotel activity
- Business licensing status
- Standard certification or verification where applicable
- PB UMKU relevant to supporting activities
- Outstanding OSS commitments or updates identified during the review
Do not assume that two hotels require identical licensing packages simply because both provide accommodation.
Building Size and Business Scope Can Matter
Current OSS pages for hotel activities display separate scopes based on building characteristics. For example, the OSS entry for five-star hotels distinguishes scopes for buildings up to 6,000 square metres and those above 6,000 square metres.
The exact risk classification and required licensing should therefore be checked from the selected KBLI, scope and project data in OSS rather than copied from another hotel.
Check Current Tourism Business Standards
Hotel licensing due diligence should also consider sector-specific tourism standards.
The current Minister of Tourism Regulation No. 6 of 2025 governs tourism business activity standards, supervision and administrative sanctions under Indonesia’s risk-based licensing framework.
It replaced the earlier Minister of Tourism and Creative Economy regulations that previously governed tourism business standards.
For an investor, this means a hotel operating under older documentation should be checked against the current regulatory framework rather than reviewed only from the rules that existed when the business first opened.
Review Supporting Activities Inside the Hotel
A hotel can create additional licensing questions through services offered alongside accommodation.
The current OSS hotel pages list PB UMKU categories that can include a health suitability certificate and direct-sale permissions relating to alcoholic beverages where relevant to the activity.
This does not mean every hotel automatically requires every PB UMKU displayed in OSS.
Instead, investors should compare the hotel’s real supporting activities with the permissions actually held.
Food, Beverage and Alcohol Operations Need Particular Attention
During due diligence, determine:
- Whether a restaurant or bar is operated by the hotel company or another entity
- Whether the relevant business activity appears in OSS
- Whether alcohol is sold
- Which supporting permissions apply to the actual operation
- Whether existing permissions correspond to the current operator and project location
This avoids treating the accommodation license as a universal authorization for every revenue-generating service inside the property.
Licensing Due Diligence Should Connect With the Wider Hotel Review
Business licensing should also be compared with other legal layers of the property.
Depending on the transaction, investors may need separate reviews of:
- Land rights and lease arrangements
- Zoning and spatial-use conformity
- PBG or historical IMB
- SLF
- Environmental documentation
- Corporate ownership and shareholder changes
- Tax and financial compliance
Lombok Legal ID’s NIB OSS RBA registration guide provides a broader explanation of the OSS licensing system, while foreign investors can separately review the PT PMA setup guide.
Use a Red-Flag Matrix Before Acquisition or Investment
A useful licensing review should explain the consequence of each finding.
| Finding | Due-Diligence Question |
|---|---|
| NIB and activity verified | Does the OSS profile match the actual hotel? |
| Legacy KBLI remains | Does it need conversion or another OSS update? |
| Activity missing | Which entity should register and license it? |
| Supporting permission missing | Is it required before that activity continues? |
| Hotel scope does not match operation | What correction or licensing action is required? |
| Ownership or operator will change | Which corporate and OSS records need updating? |
Material findings can then be incorporated into the transaction structure, conditions before closing or the buyer’s post-acquisition compliance plan.
Practical Hotel Licensing Checklist
Before acquiring, investing in or restructuring a hotel operation in Lombok, consider confirming:
- Legal operating entity
- Current NIB
- Current OSS project records
- Correct KBLI 2025 classification
- Conversion of relevant historical KBLI records
- Hotel classification and operating scope
- Applicable business licensing status
- Tourism business standards
- Relevant PB UMKU
- Restaurant and other supporting activities
- Licenses held by third-party operators
- Changes required after acquisition or restructuring
The objective is not to accumulate documents. It is to determine whether the government’s business data accurately reflects the hotel that is actually being operated.
Conclusion
A hotel NIB is an important starting document, but it should not be the end of licensing due diligence.
A stronger review follows the sequence operating entity → actual business activities → KBLI 2025 → OSS project scope → business licensing → tourism standards → PB UMKU → supporting activities → acquisition or restructuring updates.
For investors in Lombok, this approach creates a clearer distinction between an operating hotel and a hotel whose corporate and licensing records have been verified against its current commercial activities.
Review the Hotel’s OSS and Licensing Profile Before You Invest
An existing hotel’s NIB can be only the starting point. Comparing the legal operator, KBLI, OSS project data, tourism standards and supporting permissions with the hotel’s actual activities can identify licensing gaps before they become part of an acquisition or restructuring plan.
For a consultation based on the hotel’s current corporate and licensing documents, discuss the project with Lombok Legal ID and prepare the NIB, OSS records, company documents and a list of the activities currently operated at the property.
FAQ – Hotel Business Licensing Due Diligence in Lombok
Is an NIB enough to prove that a hotel in Lombok is fully licensed?
No. An NIB is an important part of the OSS record, but due diligence should also examine the registered KBLI, project scope, applicable business licensing, tourism standards and relevant supporting permissions.
Which KBLI applies to hotels in Indonesia in 2026?
KBLI 2025 is the current classification. OSS places hotel and hotel-resort activities within sub-group 5510, with separate classifications for five-star through one-star hotels and non-star hotels.
What if an existing hotel still has a KBLI 2020 record?
The record should be checked against KBLI 2025 and the current OSS data. OSS provides an official KBLI 2020-to-2025 conversion process, so investors should confirm whether the existing business profile has been correctly transitioned.
Are a hotel, resort and villa always registered under the same KBLI?
No. The correct classification depends on the actual accommodation model and official KBLI description. Hotel and hotel-resort activities are included under KBLI 2025 sub-group 5510, while some other short-term accommodation activities use different classifications.
Why should an investor review the hotel’s actual revenue activities?
Accommodation may not be the hotel’s only activity. Restaurants, bars, events, wellness services and other operations can create separate KBLI or supporting-permission questions, particularly where another company operates part of the property.
What is PB UMKU in hotel licensing?
PB UMKU is licensing that supports particular business activities. The applicable PB UMKU depends on what the hotel actually operates. Current OSS hotel pages display categories including health suitability certification and alcohol-related direct-sale permissions where relevant.
Do all hotels require the same OSS licenses?
No. The licensing pathway depends on the selected KBLI, project scope, business characteristics, supporting activities and other regulatory conditions. Investors should review the actual OSS project rather than use another hotel’s checklist.
Which tourism regulation should an existing hotel review in 2026?
Minister of Tourism Regulation No. 6 of 2025 is currently in force and governs tourism business standards, supervision and administrative sanctions under the risk-based licensing framework.
Should restaurant and bar licenses be reviewed separately during hotel due diligence?
Yes. Investors should identify which entity operates each supporting activity, whether the relevant activity is registered in OSS and whether the necessary supporting permissions apply to the actual operation.
What licensing issues should be checked after buying an existing hotel?
Review whether ownership, company data, project information, KBLI activities, operator arrangements or other OSS records need to be updated after the transaction. The exact actions depend on whether the investor is acquiring shares, assets, property or operating rights.
References & Sources
- Government Regulation No. 28 of 2025 on Risk-Based Business Licensing – JDIH BKPM
- Minister of Tourism Regulation No. 6 of 2025 on Tourism Business Standards, Supervision and Administrative Sanctions
- BPS Regulation No. 7 of 2025 on the Indonesian Standard Industrial Classification
- OSS KBLI 2025 – Hotel and Similar Accommodation Activities
- OSS Guide for Converting KBLI 2020 to KBLI 2025