Today, 5 October, the one-year grace period written into Indonesia’s new property brokerage standard runs out. Minister of Trade Regulation No. 33 of 2025 was signed on 3 October last year, took effect two days later, and gave every existing brokerage company and every uncertified broker exactly twelve months to comply. That clock stops today.
For the international buyer, the significance is simple. From today, whether the agency selling you a villa and the broker handling the transaction meet the licensing and professional standards the law now sets has a written answer, and most of it can be checked in a few minutes. This article sets out what the regulation requires, where a widely repeated version of it goes wrong, and what a buyer should ask before signing anything.
What the New Standard Requires
The standard sits inside Indonesia’s risk-based licensing system. Property brokerage is classified as medium-high risk, which means a brokerage company must hold two things: a business identification number and a verified standard certificate for its activity. The company must be an Indonesian legal entity. An individual operating independently, or a foreign company working the market from abroad, sits outside the regulated structure.
The personnel rules are precise. Every property broker must hold a competency certificate issued through a professional certification body and must be an Indonesian citizen. The company must employ at least one certified brokerage manager. If it also offers property management or investment consultancy, it must employ at least one certified property manager or investment consultant for that service. Each of these people may be registered at only one business location and may not work for another brokerage at the same time. A broker who breaches that rule faces a recommendation that their certificate be revoked.
The certification levels are set by the national qualification framework: level six for brokers, level seven for managers and consultants. These are not internal training badges. They are assessed credentials, and the certificate number must appear on the broker’s identification and in the written agreement with the client.
Where the Two-Broker Figure Came From
A version of this rule circulating in Bali holds that every foreign-owned company must now employ two certified brokers. That is not what the regulation says.
The two-expert requirement belonged to the previous framework, a 2017 ministerial regulation that governed brokerage companies through a specific licence. That regulation was repealed on 5 October 2025, the day the new standard took effect. The current text requires one certified brokerage manager plus certified brokers for the transaction work. It sets no minimum headcount. Membership of the national brokers’ association carries its own professional standards on top of the regulation, and those are a mark of seriousness rather than a legal floor.
The distinction matters because it is easy to dismiss a rule that is misdescribed. The real requirement is narrower and, for the buyer, more useful.
The Written Agreement Is Now the Test
The most practical change for a buyer is the mandatory written agreement between the brokerage and its client. The regulation lists what it must contain: the identity of both parties, the name of the broker involved and their certificate number, the company’s licence number, the scope of service, the property’s title number, location and condition, the rights and obligations of each side, the commission value or percentage with payment terms, the term of the agreement, and a dispute resolution clause including compensation if either party fails to perform.
Read that list again as a buyer. Every item on it is something a serious adviser should already have been offering. Now it is required, and an agency that cannot produce it is telling you something about how it operates. Co-broking agreements between two agencies must also be in writing, in Indonesian or bilingual, and a foreign agent offering property to buyers in Indonesia must partner with a licensed Indonesian brokerage to do so.
What Foreigners May and May Not Do
This is the part of the regulation most relevant to Bali’s expatriate market. The broker who handles the transaction must be Indonesian. Foreign nationals may hold the manager and consultant roles, subject to the usual immigration and employment requirements, and the regulation explicitly provides for immigration documents in place of a national ID card for those positions. What a foreigner may not do is act as the certified broker on the deal.
For a buyer, the test is not the nationality of the person you first speak to. It is whether a certified Indonesian broker, registered with a licensed company, is named in your agreement and responsible for the transaction. If the answer is no, the arrangement falls outside the standard.
Commission Bands and Itemised Costs
The regulation sets a band for brokerage commission: between 2 and 5 percent of transaction value for a sale, between 5 and 8 percent (10 percent is commonly acceptable for Bali) for a rental, in each case adjusted to the scope of service provided. Fees for property management and investment consultancy are by written agreement. Every commission clause must itemise costs, including tax and any deductions, and the company may pass no more than 70 percent of the commission to the individual broker.
Two further duties reinforce this. The company must display its licence number at its premises, on its website and on every piece of marketing, and must publish the list of its certified experts. It must also file an annual activity report with the Ministry of Trade by 30 April, including its broker list, its locations with coordinates, and its turnover. Online property platforms are required to collect and display the business licence number of each agency and the certificate number of each broker they host.
The regulation also states what a brokerage may not do: give false information, make promises or guarantees that are not certain, make misleading statements, facilitate crowdfunding of property purchases, or facilitate money laundering. In a market where yield projections have long been offered as fact, that clause on uncertain guarantees deserves attention.
How Enforcement Starts
The Ministry of Trade has said publicly that sanctions begin once the socialisation period ends in October 2026, starting with warnings. The regulation’s own ladder runs further: written warning, temporary suspension of business, closure of premises, blocking of websites used for the business, administrative fines, and suspension or revocation of the licence. Sanctions may be applied in sequence or at once.
Enforcement will take time to reach every corner of the island. That is not a reason for a buyer to wait. The standard is already law, the grace period is over, and the documents it requires give a buyer a straightforward way to ask how the agency is structured and who is professionally responsible for the work.
The Five-Minute Check Before You Engage an Agency
Before you sign with any agency in Bali, ask for five things and expect them without delay.
- The company’s business identification number and its verified standard certificate for property brokerage
- The name and competency certificate number of the Indonesian broker who will handle your transaction
- The written agreement, with the seven items the regulation requires
- Commission stated in writing, itemised, with tax and deductions shown
- Confirmation of the professional personnel responsible for your transaction
An agency that provides these in an afternoon has nothing to hide. An agency that explains why they are not really necessary has just answered your question.
Verify the Adviser Before the Villa
Most of the due diligence conversation in Bali is about the property: the title, the zoning, the permits, the rental licence, the exit. That work is essential and it is where we spend most of our time. But the regulation that takes full effect today makes a quieter point. The first thing to verify is the person and the company standing between you and the seller.
At Fullers Properties we work exclusively on the buyer’s side, and our Buyer Advisory Fee is disclosed in writing before any work begins. We welcome the weight the new standard puts on documented responsibility, assessed competence and transparency around fees, because those are the things a buyer should have been able to expect all along. From today, ask for the paper. If it is not there, walk.
The regulatory content in this article was reviewed by Putri Hasquita Ardala, legal adviser.
