How to Set Up a Clinic in Bali

The launch of the Sanur Special Economic Zone (SEZ) in 2022 has created a major new opportunity for health and wellness investment in Bali.

As an investor looking to open a clinic, you can either operate under the general regulations anywhere in Bali or leverage the benefits offered exclusively within the Sanur SEZ.

This guide explains the standard requirements for opening a clinic in Bali and details the unique advantages and different rules that apply within the Sanur SEZ.

A Spotlight on the Sanur SEZ Benefits for Medical Tourism Investors

For investors planning a significant, internationally focused medical or wellness facility, the Sanur SEZ is designed to be a hub with a range of fiscal and non-fiscal benefits. Choosing to set up here offers several advantages over other locations in Bali.

• Tax Holidays: You can receive a Corporate Income Tax (CIT) holiday for 10-20 years for qualifying investments.
• VAT & Import Duty Exemptions: You can benefit from exemptions on Value-Added Tax (VAT) and import duties when bringing in capital goods like expensive medical equipment and other essential supplies.
• Superior Property Rights: The SEZ allows for more secure and longer-term land titles, including the Right to Use (Hak Pakai) and Building Right (Hak Guna Bangunan) for up to 80 years.
• Streamlined Business Licensing: The SEZ operates a One-Stop Service for business licensing, which can significantly speed up the approval process.

Understanding Clinic Types and Foreign Ownership in Bali

Under the general regulations, your eligibility for 100% foreign ownership depends on the type of clinic you establish.

• Klinik Pratama (Primary Clinics): A Klinik Pratama is a primary clinic that handles basic medical issues and preventative care. Presidential Regulation No. 49 of 2021 explicitly allocates this business field, along with other basic health services like private maternity homes, to local Cooperatives and Micro, Small, and Medium Enterprises (MSMEs). This means that a Klinik Pratama is not open to 100% foreign ownership and is therefore not a viable structure for your investment.
• Klinik Utama (Specialized Clinic): A Klinik Utama is a specialized clinic that provides more advanced services and uses specialized equipment. Since foreign investment is permitted in Klinik Utama, you can establish this type of clinic through a PT PMA (Foreign-Owned Company).

Types of Specialized Clinics Foreigners Can Open in Bali

Foreign investors in Bali typically establish cosmetic or wellness clinics, as these fall under specialist services and can have up to 100% foreign ownership. Common examples include:

• Dermatology Clinics (Klinik Dermatologi): Focusing on the diagnosis and treatment of skin conditions.
• Aesthetic & Injection Clinics (Klinik Injeksi Kecantikan): Offering popular non-invasive services like Botox, fillers, and other cosmetic injections.
• Laser Treatment Clinics (Klinik Perawatan Laser): Utilizing advanced laser technology for various aesthetic procedures.
• Plastic Surgery Clinics (Klinik Bedah Plastik): Performing cosmetic and reconstructive surgeries.
• Medical Spas (Spa Medis): Integrating medical procedures with spa treatments for a relaxing, results-oriented experience.
• Holistic Wellness Clinics (Klinik Wellness Holistik): Combining medical aesthetics with traditional therapies and lifestyle guidance for overall well-being.

An Important Note on Licensing: In Indonesia, the complexity and cost of licensing often increase with the level of specialization. For example, a medical spa might need additional permits for specific medical procedures or for its spa amenities like hydrotherapy pools. It’s important to plan for these requirements from the beginning to ensure your business is fully compliant.

Licensing Process When Setting Up Your Clinic in Bali

Establishing your clinic in Bali is a multi-layered process of corporate registration and specific healthcare licensing. Here are the key steps you must follow:

Step 1: Set up Your PT PMA and Obtain a Business License

Regardless of the type of clinic you want to open, the first step is to legally register your company in Indonesia. 

You will need to meet the key requirements, such as at least IDR 10 billion for foreign-owned companies, a registered business address, and a resident director (whether local or foreigner with a valid KITAS/KITAP).

Here’s the summary of this process:

1. Business name reservation
2. Choose the right KBLI code: You must select the appropriate Indonesian Standard Business Classification (KBLI) code. This choice is critical as it defines your legal scope of activities.
3. Prepare Documents: Your company’s deed of establishment, shareholder information, and tax identification number (NPWP) to complete the process.
4. MoHLR Approval: The Ministry of Law and Human Rights approves the status as a legal entity. You will then secure your tax ID (NPWP).
5. Securing Business Identification Number (NIB) via the OSS.

Recommended Reading: How to register a company in Bali as a Foreigner

Emerhub’s experts will handle this process on your behalf. We will prepare the necessary documentation in line with your planned activities and register your company.

Step 2: Secure a Clinic Permit (Izin Klinik)

Once your business entity is legally registered, the next step is to secure approval from the Ministry of Health to operate as a clinic, called a Clinic Permit (Izin Klinik).

At this stage, you must meet specific requirements for your clinic as per the local regulations. These include aspects such as:

• Clinic Facility: Minimum space, proper ventilation, lighting, accessibility, and a licensed medical waste disposal plan.
• Equipment: You must have all necessary and approved equipment for the services you offer (e.g., lasers, injection tools).
• Personnel: You must have qualified and licensed Indonesian doctors and nurses on staff.
• Operational Procedures: Documented protocols for infection control, patient management, and emergencies are required.

Step 3: Ensure Your Staff Has Medical Practice Licenses (Surat Izin Praktik/SIP)

SIP is an individual practice license. It allows doctors, dentists, and certain other health professionals to work at a specific facility. Therefore, before you can open your clinic and start offering services, you must ensure that your medical personnel have the appropriate licenses.

If you plan to hire foreign medical professionals, they must meet additional requirements under the Health Law No. 17 of 2023:

• Pass a competency evaluation in Indonesia
• Undergo a three-month adaptation program to understand the local practices
• Register with the Indonesian Medical Council (KKI) to secure the SIP

Please note that each SIP is valid only for the specific clinic or hospital where the practitioner is registered.

Step 4: Register All Medical Products and Devices (if applicable)

In Indonesia, every product or equipment that touches a patient must be registered and approved for use in the country. Your responsibility for this registration depends entirely on how you source your products and medical devices.

For instance, if you source from a licensed Indonesian distributor, the distributor is responsible for ensuring the products are registered. In that case, you need to take care of two things:

1. You must do your due diligence. Confirm your supplier is legitimate and their products have legal approval for local use.
2. Your staff has the proper training and is certified by the official distributor to legally operate any medical equipment

However, if you plan to import products or devices yourself, you will be responsible for the entire registration process with the appropriate authorities. In that case, you will need to register your cosmetic products with the National Agency of Drug and Food Control (BPOM) and register medical devices with the Ministry of Health (MOH).

Sanur SEZ Advantage: Clinics inside the Sanur SEZ benefit from exemptions on import duties and taxes for medical equipment and are not subject to the same import restrictions or mandatory Indonesian National Standard (SNI) requirements as businesses elsewhere in Bali.

Special Considerations for Opening “Medical Spas”

The Indonesian KBLI (business classification) system doesn’t have a direct code for “medical spa.” The most suitable code depends on its dominant focus:

• If the medical aspect is dominant, you might classify your business under KBLI Division 86 (Human Health Activities). This allows for procedures like injectables or laser treatments.
• If the spa aspect is dominant, KBLI 96122 (Spa Activities) may be suitable. However, you must verify its foreign ownership rules.

To ensure you choose the most accurate and compliant KBLI code for your specific clinic type and services, it’s recommended to consult with Emerhub’s local experts.

How Emerhub Can Help You Get Started

Whether you are targeting the unique benefits of the Sanur SEZ or planning to open a clinic elsewhere in Bali, navigating the legal and regulatory landscape is complex. Which is why having local experts by your side is invaluable for a smooth and compliant setup.

Emerhub’s team of consultants in Bali handles the entire process, from establishing your PT PMA company to securing the necessary operating licenses from the Ministry of Health. We ensure your business is structured correctly and that your products and equipment are properly registered with the relevant authorities, saving you from navigating the bureaucracy yourself.

Fill out the form below to discuss your plans with our team.