Verification: titles, zoning, security, code articles, KBLI

Date: 2026-08-13 · four requested checks · sources named against each

1. Remaining term of the master title

Answer: there is nothing to determine it from, and the term itself is wrong.

Source: the land spreadsheet in Google Drive (modified 06.08.2026, owner jooyyrocket@gmail.com), 21 rows.

A master title in the singular does not exist. The Estate is assembled from 21 acquisitions from different previous owners:

The three rows without title: №13 — 450 are, holding type Pipil, status wait; №0 — 64 are, certificate wait; №3.1 — 4 are, holding type agreement. Pipil is a tax and customary document rather than a certificate of right; a plot on Pipil is not let until conversion. That is 12% of the Estate's area in a single block.

Grant and expiry dates for the HGB appear neither in this spreadsheet nor anywhere else in the available data. The remaining term comes only from the certificates themselves — there are 18 of them and they have to be read. Putting a number here without the certificates is not permissible.

What can be said structurally, without the certificates. The acquisitions are dated 2022–2024 (from the PPJB dates and authorisations in the spreadsheet). An HGB under PP 18/2021 runs 30 years, with an extension of 20 and a renewal of 30. Even counting from 2022, the first two cycles end around 2072–2074. A 25+25 lease signed in 2026 runs to 2076. The product structurally exceeds the first two cycles and relies on a third that is not guaranteed.

What changes in the document: the wording "master title" in the singular is replaced by "Title" — the specific certificate on which the plot sits; Annex A becomes a table with one row per title, with dates and remaining term; the remaining term goes into the recitals of the lease as a number; and a condition precedent is added — a plot is not offered unless it sits on a certificated HGB.

2. ITR and RDTR Buleleng

Answer: under the RTRW the land is an agricultural zone; the route to building is a KKPR for each plot; more than half the Estate does not have one.

The official RDTR status for Bali is published by tarubali.baliprov.go.id on the page "Update Status RTRW dan RDTR se-Provinsi Bali". The page did not open from this session — robots.txt timed out. This has to be obtained manually or through counsel.

What the group's own documents give:

• cyber-valley/districts/gesing/bridge.md records, under the RTRW for a neighbouring 4.8 ha plot in the same Gesing: Kawasan Pertanian (agricultural), adjoining Kawasan Lindung (protective green zone), and states expressly that the buyer obtains the KKPR and that the buildable area is confirmed at the KKPR stage.
• the land spreadsheet has a PKKPR column. It is filled for 7 rows out of 21: 200, 400, 28, 445, 445, 88, 88 are — 1,694 are in total, 16.94 ha.

Open item 3 of the strategy is called "highest-priority verification, gates the entire subdivision plan". The data say it is not closed: more than half the area is without a PKKPR, on land whose base status is Kawasan Pertanian.

Two consequences for the agreement follow, both made. The warranty on zoning and KKPR is given for the specific plot rather than for the Estate as a whole. And a condition precedent is added: a plot without a PKKPR for the stated use is neither offered nor priced.

Separately: in a Kawasan Pertanian zone the LP2B question (protected agricultural land) stops being theoretical and is checked for each plot before subdivision.

3. Admissibility of charging a hak sewa

Answer: a charge is impossible. The construction is replaced by an assignment by way of security.

Position: UU 4/1996 on Hak Tanggungan, Pasal 4 lists the objects that may be encumbered — Hak Milik, Hak Guna Usaha, Hak Guna Bangunan (ayat 1) and Hak Pakai over state land that is registrable and transferable (ayat 2). Hak sewa untuk bangunan under UUPA Pasal 44–45 is not in that list and is not registered at BPN, and registrability is the condition of encumbrance.

Provenance, resolved on 24 August 2026: the primary text was retrieved from JDIH Kementerian Keuangan and Pasal 4 is reproduced verbatim, with an English column, on UU 4/1996. The four objects listed there are Hak Milik, Hak Guna Usaha and Hak Guna Bangunan in ayat (1), and Hak Pakai over State land that must be registered and is by its nature transferable in ayat (2). Hak sewa is absent. The position no longer rests on knowledge; it rests on the text. What remains for the notary is the narrower question of whether the cessie tot zekerheid below is the right substitute, not whether a charge is possible.

What went into §2.9 in place of a charge: assignment of the right by way of security (cessie tot zekerheid) by notarial deed on notice to the Estate; the Estate acknowledges the secured creditor, issues it the Estate Certificate, and notifies it of a material breach before terminating, granting the same cure period as the Holder; on enforcement the creditor takes the whole bundle under 2.5.2 and accedes under 2.5.4, with no transfer fee — the fee is taken on its subsequent sale.

This also strengthens the argument for a negative pledge, though the underlying asymmetry has since narrowed: Articles of Association Article 12(3) now prohibits the Company from charging its land at all, by the nature of its constitution, not merely with consent as this section originally described. The Holder still may not charge his right at all — the negative pledge in the deed is the Holder's own backstop, not the only thing standing between him and an encumbrance.

4a. Numbering of the KUHPerdata articles in §2.7

Answer: not confirmed. It could not be verified from this session.

Wikisource is unavailable from the environment, Indonesian primary sources return 403 or metadata only, and the search index returns sixteenth-century English statutes for this query.

What is known structurally and does not amount to proof: Buku III KUHPerdata, chapter Bab VII Sewa Menyewa, occupies roughly articles 1548–1600, so 1588–1592 fall within the chapter on leases rather than on sale. For a clause about leasing a plot that is an argument for the reference being correct rather than against it. "Rather" is not a basis for signature.

The precise question for the notary, in one paragraph: confirm that Pasal 1588–1592 KUHPerdata govern the lease of land stated by area and the consequences of a divergence between actual and stated area; that they are dispositive; and that waiving them is permissible where the boundaries are objectively determinable. If the articles are the wrong ones, §2.7 is empty and the whole per aversionem construction rests on nothing.

The item has been added to the document's open questions.

4b. Locational scope of the KBLI in Pasal 3 of the Articles

Answer: this data is not in the Articles, it is in the NIB. The structure has been entered into Annex A.

The Articles give eight codes: 68111 real estate owned or leased · 68200 real estate on a fee or contract basis · 55199 other short-term accommodation · 56101 restaurant · 96122 SPA · 82302 special event organiser · 55192 campgrounds and caravan parks · 93299 other amusement and recreation.

Locational scope is not stated in the Articles at all: it lives in the NIB in the OSS RBA system, where each KBLI entry is tied to a business address, a risk class and a permit status. I have no access to OSS.

What needs to be exported and placed into Annex A — one row per KBLI × address pair:

How to obtain it: OSS RBA → company account → cetak NIB → daftar kegiatan usaha; take the address, scale, risk and status for each row; reconcile the addresses against the list of titles in Annex A.

Check first of all the discrepancy already noted at v0.3: the NIB shows a different address for 68111 than for the other codes. 68111 is the code under which leases are granted. If its location does not cover the plot, the warranty in §9A.1 is untrue for that plot — and Pasal 12(2)(c) of the Articles gives the Director authority to sign leases precisely within 68111 and 68200.

The second consequence of the list, already entered into §2.6: 55199 and 55192 are held by the Company and cannot be held by a foreign individual Holder. A sublet with occupation runs under the Company's licence; bare land with no accommodation service runs under the Holder's responsibility.

Summary

This is not legal advice. Two items — the charge and the article numbering — are stated from knowledge rather than from a retrieved primary source, and are marked as requiring confirmation. The figures for areas and PKKPR are computed from the land spreadsheet and are reproducible.

Sources: UU No. 4 Tahun 1996 — JDIH BPK RI · UU No. 4 Tahun 1996 — JDIH ATR/BPN · Update Status RTRW dan RDTR se-Provinsi Bali · Categories of Property Rights in Indonesia — SSEK · Jenis-jenis Hak atas Tanah — Klinik Hukumonline