Environmental approval for building: AMDAL, UKL-UPL and SPPL

This page is for a foreigner who builds a house or villa in Bali, or who buys one from a developer. It states what the regulations say, with the article, and says where they are silent or disagree. It is general information, not legal advice.

The environmental approval is a step of its own, apart from the building permit. The page on building permits covers KKPR, PBG and SLF, and this page does not repeat them. The page on renting a villa to guests covers the business licence, the page on Bali's own rules covers groundwater, waste and setbacks, and the page on zones explains the conditions a spatial plan attaches to a use. Facts are checked against the texts as they stand on 16 October 2026.

Since the Job Creation reform the environmental decision is called Persetujuan Lingkungan (PL, environmental approval), and it belongs to the business licence instead of being a separate permit. UU 32/2009 on environmental protection, as amended by UU 6/2023, defines it as a decision that the plan is environmentally feasible (keputusan kelayakan lingkungan hidup) or a statement of commitment to manage the environment (pernyataan kesanggupan pengelolaan lingkungan hidup) that the central or regional government has approved (Pasal 1 angka 35). The former izin lingkungan (UU 32/2009 Pasal 36) was deleted by UU 6/2023 (Pasal 22 angka 14), and PP 27/2012 on it was repealed by PP 22/2021 (Pasal 529).

The approval is tied to the business licence. It is a precondition for the licence (PP 22/2021 Pasal 3(3)), it ends when the licence ends (Pasal 3(5)), and a renewal of the licence with no change in the activity may rely on the approval that exists (Pasal 3(6)). Older documents stay valid: an izin lingkungan, a Surat Keputusan Kelayakan Lingkungan Hidup or a UKL-UPL recommendation approved before PP 22/2021 took effect on 2 February 2021 remain in force and count as the prerequisite (Pasal 527 huruf a).

Three texts divide the work today. PP 22/2021 on environmental protection and management says what the approval is and who needs it. PP 28/2025 on risk-based business licensing, in force since 5 June 2025 and replacing PP 5/2021, says how the approval is applied for through OSS and how long each step takes (Pasal 78 to 105); what it does not regulate follows the environmental rules (Pasal 105). The Minister's regulation 4/2021 holds the list of activities and sizes.

The statute fixes the principle. An activity with a significant impact needs an Amdal (UU 32/2009 Pasal 22(1)). One without must meet a UKL-UPL standard (Pasal 34(1), as amended). One that needs neither makes an SPPL, which is built into the business number and is set for low-risk activities (Pasal 35, as amended). PP 22/2021 repeats this and lists the criteria of a significant impact, among them changing the shape of the land and the landscape, activities that may pollute or damage the environment, and activities that affect conservation areas or cultural heritage (Pasal 4 to 8).

The Minister's regulation turns the principle into a list (Permen LHK 4/2021, Lampiran I by KBLI code and Lampiran II for activities without a code). An activity on it needs an Amdal when it reaches the size in the Amdal column, a UKL-UPL in the UKL-UPL column and an SPPL in the SPPL column (Pasal 3 to 7). The Minister may move an activity between levels or add one, on a written proposal from a ministry, a governor, a bupati or walikota, or the public (Permen LHK 4/2021 Pasal 8 and 9), and evaluates the lists at least every five years (PP 22/2021 Pasal 9).

We read both texts as they stand on 16 October 2026: the BPK database shows no amendment or replacement of either, and we found no later ministerial list. The list uses the KBLI 2020 codes, while OSS has applied KBLI 2025 since 15 June 2026 (see the glossary entry on KBLI). Ask the environment office which row of the list your plan falls in.

And/or. The multisector row joins land and floor area with and/or, so a plan reaches a column when its land or its floor area reaches the figure. The list does not say which column applies when the land falls in one column and the floor area in another; the cautious reading is the higher level, and the screening in OSS gives the answer for your plot. The UKL-UPL cell of that row calls its second measure land (Luas Lahan) where the row names it floor area (Luas Bangunan); we read it as floor area.

A house and a villa. The multisector row is the fallback: a footnote of Lampiran II says its levels apply to an activity that is not named specifically in its own sector, and/or as the sector rows of Lampiran I direct, and Pasal 7(1) huruf b and (3) send a service business that needs facilities to Lampiran II. The villa and accommodation rows say per the multisector rule, so they follow the first row. An activity listed by name under KBLI 41011 (Konstruksi Gedung Hunian) follows its own row: UKL-UPL below 10,000 m2 and a dash in the SPPL column. What stays open is whether a private house, or a developer's housing project, falls under KBLI 41011 at all, since that is a construction code.

Special houses. A separate 41011 row (rumah khusus: new government-assisted homes of 28 to 36 m2, built on the land of aid recipients) has its own figures: Amdal from 50 ha (2,500 units), UKL-UPL more than 3 ha and less than 50 ha (150 to 2,500 units), SPPL up to 3 ha (150 units). By its own definition it does not describe a private villa or a villa complex.

Place can override size. A plan in or directly beside a protected area (kawasan lindung) needs an Amdal whatever its size (Permen LHK 4/2021 Pasal 3(3) huruf b; PP 22/2021 Pasal 5(2) huruf b). A plan is directly beside one when the edge of the site touches the border of the area, or when scientific reasoning shows an impact on the area's function (PP 22/2021 Pasal 5(4)); in the second case the business actor asks the environment agency for guidance, and the feasibility team answers whether the plan affects the protected function (Pasal 5(5) and (6)). A plan inside a protected area must also be one that the law allows there (Pasal 5(3)); the approval does not make it lawful.

Lampiran I of PP 22/2021 lists 23 types of protected area. Among them: protected forest, peat, water-recharge area, coastal setback, river setback, the area around a lake or reservoir, nature reserve, mangrove coast, national park, cultural heritage area, groundwater recharge area, spring setback, coral reef, and the conservation areas of the coast and the sea. The sources do not map them to plots; to learn whether your plot is in or beside one, ask the kabupaten environment office and the spatial planning office, and see the page on zones for where the plans are published.

Exceptions. An Amdal is not required, and a UKL-UPL or SPPL applies instead, for a plan in a kabupaten whose detailed spatial plan (RDTR) has been completed with a strategic environmental study (KLHS) made and carried out in a comprehensive and detailed way (PP 22/2021 Pasal 10(1) huruf a, 11(1)). The same holds, for a plan that is not on the Amdal list by size, when the agency that manages the protected area has issued an exemption for it (huruf j). We do not know which Bali plans meet the first condition. The map page shows the stage of each RDTR, including a KLHS meeting; a plan at that stage is not a completed one, and the texts we read do not say who confirms the condition. Ask the environment office whether it applies to your plot.

Bali's provincial spatial plan (Perda Bali 2/2023) adds that cut and fill in a ravine setback must be backed by an environmental document (Pasal 85 huruf g angka 7). The page on building permits covers the height, ravine, beach and river rules, and the page on zones explains that a plan can attach a condition (B1 in the Kuta Selatan plan) that requires an environmental document. We found no provincial regulation (Perda or Pergub) that sets a separate environmental approval for houses or villas.

PP 28/2025 lists the basic requirements of a business together: KKPR, the environmental approval (PL), and PBG with SLF (Pasal 12(1)). A list is not an order, but other texts give one. The check of an Amdal or UKL-UPL application starts with whether the site conforms to the spatial plan and whether any prior approval of the plan is in place (PP 28/2025 Pasal 87(1) huruf a and b, 96(1) huruf a and b), so the KKPR or the plan itself comes first. SIMBG, the national building system, tells an applicant that the environmental document and the space-use document are prerequisites for a PBG application, and that the environmental document comes from the Ministry of Environment or the kabupaten environment office. And a PBG must be held before construction starts (PP 28/2025 Pasal 108(1)).

So the order we read is: KKPR (does the use fit the zoning), then the environmental approval, then PBG before building, then SLF before use. This is our reading of those texts, not a sentence of one regulation. The KKPR, PBG and SLF steps, their time limits and the sanctions for building without a PBG are on the page on building permits.

Changes later. The holder of an SKKL or a PKPLH must apply for a change of the approval when the activity changes: technical specifications that affect the environment, added capacity, extended land, a change of the person responsible, or a plan not carried out within 3 years of issue (PP 22/2021 Pasal 89(1) and (2) huruf a, b, c, g, h). For an Amdal the change is also stated in PP 28/2025 Pasal 86(2). Ask the developer whether what is built is what the approval describes.

A private house. PP 22/2021 gives the approval to every business and/or activity with a significant or an insignificant impact (Pasal 3(1)), and defines an activity as any form of activity that can change the natural surroundings and affect the environment (Pasal 1 angka 11). We found no article that exempts the private house of an individual. PP 28/2025 puts the duty on business actors (Pasal 78(1)), and Permen LH/BPLH 22/2025 names the route for an activity that is not a business (Pasal 2(2)). Whether an owner who builds one house for himself needs an SPPL, a UKL-UPL or nothing is not stated in terms, and the list of sizes carves out no private homes.

In practice SIMBG asks every PBG applicant to hold an environmental document before applying, and Badung's checklist for a PBG lists it (see the page on building permits). Plan for the building permit office to ask for one even for a private house, and ask the environment office which document and which form your house needs.

A villa let to guests. This is a business. The business actor needs the approval as a basic requirement before the business licence (PP 28/2025 Pasal 12(1), 78(1)), and the villa row of the list uses the multisector figures. The licence, the tourism standard and the risk level of a villa are on the page on renting a villa to guests.

A development. The list measures the activity in land and floor area. For a development ask which land and floor area the approval covers, and whether it covers every phase and every plot sold to buyers; we found no text that says how phased or split projects are counted. Where one business has more than one KBLI code in integrated activities on one continuous site, the environmental document follows the highest level required (PP 28/2025 Pasal 78(6)). Pasal 13 excuses a trade or service business in a building or complex shared with others from the basic requirements when the manager already holds KKPR, PL, PBG and/or SLF; the text speaks of trade and services and does not name villas, so we do not know whether it reaches the operator of a villa in a complex.

What to ask for. Ask the developer for the document that matches the level, with its number, date and issuer: for an Amdal the Surat Keputusan Kelayakan Lingkungan Hidup (SKKL); for a UKL-UPL the persetujuan Pernyataan Kesanggupan Pengelolaan Lingkungan Hidup (PKPLH); for a small project the SPPL, a self-statement that OSS issues automatically with the NIB (PP 28/2025 Pasal 78(3), 101(2)). A project approved before 2 February 2021 may hold an older izin lingkungan, SKKL or UKL-UPL recommendation, which stays valid (PP 22/2021 Pasal 527 huruf a). Check that the name, the place and the size in the document are those of the project you are buying.

What is public. Amdalnet, the Ministry of Environment's system, shows a public list of announcements of Amdal and UKL-UPL applications with their comment periods (tabs Amdal, Addendum, UKL-UPL and Audit; 2,272 entries on 16 October 2026), and under Data and Information on the Environmental Approval a list of approvals (460 entries). The rows of the first page that we read were issued by the Minister and date from 2022 and 2023; we did not read the other pages. The statute requires the feasibility decision to be announced to the public through an electronic system (UU 32/2009 Pasal 39, as amended). The Ministry says that anyone who needs the file of an SKKL or a PKPLH can ask its directorate for it by email.

What is not public, as far as we found. On 16 October 2026 we found no public search of the approvals of one kabupaten, and no search in OSS by company name that shows the environmental approval (the NIB search shows the NIB only; see the page on checking a developer). The Badung environment office page that we read lists a single licence of 2018 and is not a register. For a project the bupati approved, ask the developer for the document, and ask the kabupaten environment office to confirm its number and date in writing. The page on checking a developer covers the company, its owners and the registers.

Administrative sanctions. A person who runs a business or activity without the approval, or without the licence that contains it, faces administrative sanctions (UU 32/2009 Pasal 82A, inserted by UU 6/2023 Pasal 22 angka 32). The statute lists five: a written warning, government coercion (paksaan pemerintah), an administrative fine, freezing the business licence and revoking it (Pasal 82C). The Minister, governor or bupati/walikota must apply them when an inspection finds a breach, each for the approvals they issued (PP 22/2021 Pasal 505, 506, 508).

The fine for having no approval is a share of the investment value, applied together with government coercion (Permen LH/BPLH 6/2026 Pasal 43 to 45): 2.5 percent if the business holds its licence but no approval, 5 percent if it holds neither, with a ceiling of Rp3,000,000,000 for each violation. The investment value is the fixed capital plus the working capital. The 5 percent also applies when the specifications change, land is extended or an activity is added in a way the licence does not cover (Pasal 45(2)). PP 22/2021 states the same percentages and ceiling (Pasal 514 to 516). Permen LH/BPLH 6/2026, in force since 15 June 2026, replaced Permen LHK 14/2024 on the same subject, so older sources quote the earlier regulation.

Who is liable. The sanctions are addressed to the person responsible for the business or activity (penanggung jawab usaha dan/atau kegiatan). The texts we read do not say how they apply to a buyer who takes over a building or a villa that was built without the approval. Ask your notary to see the approval before you buy, and how a missing one is dealt with in the sale contract.

Criminal provisions. UU 32/2009 Pasal 109, as amended by UU 6/2023 (Pasal 22 angka 36), punishes a person who runs a business without the licence or approval and thereby causes casualties or damage to health, safety or the environment. The statute set prison of 1 to 3 years and a fine of Rp1,000,000,000 to Rp3,000,000,000. UU 1/2026 on the adjustment of criminal penalties, in force since 2 January 2026, restates it (Lampiran I nomor 150): prison of up to 3 years and/or a fine of up to category III, which is Rp50,000,000 for a natural person (UU 1/2023 Pasal 79(1) huruf c), with no special minimum (the general minimum fine is Rp50,000, Pasal 78(2)). For a corporation, such as a developer company, UU 1/2023 Pasal 121 sets a fine of at least category IV, Rp200,000,000, unless the statute provides otherwise, and, where the prison term is under 7 years, at most category VI, Rp2,000,000,000 (Pasal 121(1) and (2) huruf a; Pasal 79(1) huruf d and f). An official who issues an approval without an Amdal or UKL-UPL faces up to 3 years and/or category III (Pasal 111 as amended).

To the developer: Which level of environmental approval does the project have: Amdal, UKL-UPL or SPPL? May I see the document with its number, date and issuer? Does it name this project, this plot and this land and floor area? Does it cover every phase and every plot or unit being sold?

To the developer: Was it issued before 2 February 2021 (an older izin lingkungan) or under the current rules? Has the project changed since in land, floor area, capacity or the party responsible, and was the approval changed? Which technical approvals did it need (wastewater, emissions, hazardous waste, traffic), and may I see them?

To the kabupaten environment office (DLH) and the licensing office (DPMPTSP): Which level does a house or villa of this land and floor area need on this plot? Is the plot in or beside a protected area, a setback or a water-recharge area? Does an RDTR with a completed KLHS apply here? Can you confirm the number and date of this project's approval in writing?

To the notary: Is the environmental approval among the documents you check before the deed? What does the contract say if the approval is missing or proves wrong? Who answers for a fine, and who for the cost of correcting the project?

Whether a private house, or a developer's housing project, falls under KBLI 41011 (Konstruksi Gedung Hunian, a construction code), and so under its own row (UKL-UPL below 10,000 m2, no SPPL entry), or is read through the multisector row (SPPL below 1 ha and 5,000 m2). The texts we read do not say.

Whether a private house built by its owner needs any environmental approval, or only the environmental document that SIMBG asks for, and which document the kabupaten accepts.

How the multisector figures work when the land and the floor area fall in different columns, what built (terbangun) measures, and how a phased project or plots sold separately are counted.

Whether the standard-specific UKL-UPL form, with its automatic route, exists in the system for a villa. The annex of PP 28/2025 lists a villa as a medium-low risk activity (see the page on renting a villa to guests), but its villa row does not name the environmental document.

Which Bali plan meets the condition of the Amdal exception in PP 22/2021 Pasal 10(1) huruf a (an RDTR completed with a KLHS), and who confirms it.

Whether a buyer who takes over a built villa needs a new approval or a change of the existing one. PP 22/2021 Pasal 89(2) huruf h names a change in the identity of the person responsible among the reasons to change an approval, but it speaks of the holder of an SKKL or PKPLH.

The fees for assessing an Amdal or a UKL-UPL and the cost of technical approvals: we did not read them.

A public register of the approvals of a kabupaten. We found none. The Ministry's list covers the Minister's decisions, and the first page we read shows 2022 and 2023. The link Data SPPL dan UKL-UPL Menengah Rendah on Amdalnet points to amdal.menlhk.go.id, which did not open on 16 October 2026.

The rules of each kabupaten. We found no Perda or Pergub of Bali on the environmental approval for houses or villas, and we did not read the environmental rules or checklists of each kabupaten.

Sources that differ from the texts. Permen LH/BPLH 6/2026 replaced Permen LHK 14/2024, so older sources on sanctions quote the earlier regulation. The list of sizes uses KBLI 2020 codes while OSS applies KBLI 2025. PP 22/2021 and the list were issued under UU 11/2020 on job creation, which UU 6/2023 replaced; we read their text as unchanged.