GR 18/2021 has extended the possibility for foreigners (individuals with stay permits and foreign legal entities with representative office in Indonesia) to also own a strata title [right of ownership] of residential apartment units in buildings built on a 'right to build' land title; and to lease land under 'Land Management Rights'. The right to ownership of strata title can, however, only be owned by foreigners if the strata titles are built in: specific economic zones; free trade and free port zones, industrial zones, other economic zones. Before, foreigners were only able to hold lease rights to apartment units in buildings built on a 'right to use' land title or to lease land under a 'right to use' land title. In summary, GR 18/2021 has broadened access to land and real estate by foreigners, but in a limited manner (certain locations, e.g. SEZs etc.) and subject to size, price conditions (see GR18/2021). However, the regime for foreign-owned legal entities established in Indonesia has not changed. Foreign investors are still required to incorporate locally to invest in the same conditions as domestically-owned companies. In that respect, there are no restrictions on foreign real estate investments carried out via a locally incorporated companies, except for the fact that such investors are not entitled to freehold title [hak milik] which is reserved to indonesian citizens and designed corporation meeting specific requirements. For the purpose of the OECD FDIRRI, it is assumed that foreign investments in real estate not for business or own residential purposes via a locally incorporated company is possible and allows the investor to hold such real estate assets under conditions which are substantially similar to that of domestic investors. Hence, only a restriction on local incoporation is recorded in the FDIRRI database.

Previously: The ownership of strata titles (Hak Milik atas Satuan Rumah Susun - “HMSRS”)[condominium units] depended on the underlying land title. For example, if the underlying land title is HGB (right to build), only the qualified persons to hold such title (i.e. Indonesian citizens and Indonesian legal entities, including 100% foreign invested (PMA) companies) could purchase a strata title (unit) in the building. This was equally applicable for "right to build" on vacant land. Foreign-owned companies, as currently the case, were only forbidden from acquiring land and condominium units over 'right to own' (freehold) [Hak milik] titles, which are reserved to Indonesian citizens and corporation meeting specific requirements. See the related horizontal measures for the restrictions on the types of titles that can be held by companies, including foreign-owned ones, in Indonesia.
"CHAPTER IV - BUSINESS RIGHTS, BUILDING USE RIGHTS, AND USE RIGHTS TO LAND
Part One - Business Use Rights
Paragraph 1 - Subject of Business Use Rights
Article 19
(1) The right to cultivate is granted to:
a. Indonesian citizens; and
b. a legal entity established under Indonesian law and domiciled in Indonesia.
Paragraph 2 - Land that can be granted with a land use right
Article 21
(1) Land that can be granted with a Cultivation Right includes:
a. State Land; and
b. Land Management Rights.
Paragraph 3 - Term of Business Use Rights
Article 22
(1) The right to cultivate is granted for a maximum period of 35 (thirty five) years, extended for a maximum period of 25 (twenty five) years and renewed for a maximum period of 35 (thirty five) years.
(2) After the period of granting, extension and renewal as referred to in paragraph (1) ends, the land with the right to cultivate will again become Land Directly Controlled by the State or Land with Management Rights.
[...]
Paragraph 5 - Obligations, Prohibitions and Rights of Business Use Rights Holders
Article 27
(1) The holder of the right to cultivate is obliged to:
a. carry out agricultural, fishery and / or livestock business according to the designation and requirements as stipulated in the decision to grant the right no later than 2 (two) years after the right is granted;
[...]
Part Two - Building Use Rights
Paragraph 1 - The Subject of Building Use Rights
Article 34
(1) The right to use the building is given to:
a. Indonesian citizens; and
b. a legal entity established under Indonesian law and domiciled in Indonesia.
[...]
Paragraph 2 - Land that can be granted with building use rights
Article 36
(1) Land that can be granted with building use rights includes:
a. State Land;
b. Land Management Rights; and
c. Freehold land.
Paragraph 3 - Term of Building Use Rights
Art 37
(1) Building use rights over State Land and Land Management Rights are granted for a maximum period of 30 (thirty) years, extended for a maximum period of 20 (twenty) years, and renewed for a maximum period of 30 (thirty) years. .
(2) The right to build on freehold land is granted for a maximum period of 30 (thirty) years and can be renewed with a deed of granting the right to build on the right of ownership.
[...]
Paragraph 5- Obligations, Prohibitions, and Rights of Building Use Rights Holders
Article 42
(1) The holder of the right to use the building is obliged to:
a. carry out the development and / or exploit the land in accordance with the purpose of designation and requirements as stipulated in the decision to grant the right no later than 2 (two) years after the right is granted;
[...]
Article 44
(1) The right to use the building has the right to:
a. use and utilize the Land in accordance with its allocation and requirements as stipulated in the decision and grant agreement;
b. constructing and owning a building on the land which is granted with the right to use the building as long as it is for personal use and / or business support in accordance with the provisions of laws and regulations; and / or
[...]
Part Three - Usage Rights
Paragraph 1- Subject of Use Rights
Article 49
(1) Usage rights consist of:
a. right of use with a period of time; and
b. right of use for as long as it is used.
(2) The right to use with a period as referred to in paragraph (1) letter a is granted to:
a. Indonesian citizens;
b. a legal entity established under Indonesian law and domiciled in Indonesia;
c. foreign legal entities that have representatives in Indonesia;[...]
e. Foreigners.
(3) The right to use as long as it is used as referred to in paragraph (1) letter b shall be granted to:
a. Central Government agencies;
b. Regional government;
c. village government; and
d. representatives of foreign countries and representatives of international agencies.
[...]
Paragraph 3 - Term of Use Rights
Article 52
(1) Use rights over State Land and Land Management Rights with a period of not exceeding 30 (thirty) years are extended for a maximum period of 20 (twenty) years, and renewed for a maximum period of 30 (thirty) year. [...]
(3) The right to use with a period of time over the land with ownership rights, is granted for a maximum period of 30 (thirty) years and can be renewed with a deed of granting usufructuary rights over the land with ownership rights.
[...]
CHAPTER V - HOUSEHOLD UNIT
Part One - Subject of Property Rights on Apartment Units
Article 67
(1) Ownership rights over Apartment Units are given to:
a. Indonesian citizens;
b. Indonesian legal entity;
c. Foreigner who has a license in accordance with the provisions of laws and regulations;
d. foreign legal entities that have representatives in Indonesia; or
e. representatives of foreign countries and international institutions that are located or have representatives in Indonesia.
[...]
Article 71
(1) Residential houses or occupancy that can be owned by foreigners are:
a. house tread on land;
a1. right of use; or
a2. right of use above:
- property rights, which are controlled by virtue of an agreement granting usufructuary rights over property rights with the deeds of the Land Deed Making Official; or
- Management Rights, based on land utilization agreements with Management Rights holders.
b. Flats built on a plot of land:
b1. use rights or rights to build on State Land;
b2. use rights or rights to build over the Land Management Rights; or
b3. Right to use or right to build on freehold land.
(2) Apartment built on land with usufructuary rights or building use rights as referred to in paragraph (1) letter b is a Apartment Unit built in a special economic zone, free trade and free port areas, industrial areas, and other economic zones.
Article 72
(1) Ownership of residential or residential houses for foreigners as referred to in Article 71 is granted with the following limitations:
a. minimum price;
b. land area;
c. number of land parcels or apartment units; and
d. designation for residential or residential.
Article 73
(1) Further provisions regarding the procedures for granting and limiting the ownership of a residential or residential house by foreigners as referred to in Article 69 to Article 72 are regulated in a Ministerial Regulation.[...]" (Government Regulation Number 18 of 2021 concerning Management Rights, Land Rights, Apartment Units, and Land Registration [google translation])
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"CHAPTER VIII - PROCEDURES FOR GRANTING AND LIMITS ON OWNERSHIP
RESIDENTIAL HOUSE OR RESIDENTIAL BY FOREIGN PEOPLE
Article 185
Foreigners who have immigration documents issued by the authorized agency can have a residence or residence in the form of:
a. landed house on land:
1. Right of Use over State Land; or
2. Right of Use above:
a) Property rights, which are controlled based on an agreement on the granting of usage rights on property rights with the deed of the Land Deed Making Officer; or
b) Management Rights, based on land use agreements with Management Rights holders.
b. flats built on plots of land:
1. Right of Use or Right to Build on State Land;
2. Use rights or building use rights over land with management rights; or
3. Use rights or building use rights on land with ownership rights.
Article 186
(1) The ownership of a residential or residential house for Foreigners as referred to in Article 185 is given the following limitations:
a. for landed houses:
1. houses in the category of luxury homes in accordance with the provisions of laws and regulations;
2. 1 (one) plot of land per person/family; and/or
3. the land area is no more than 2,000 m2 (two thousand square meters);
b. for flats with the category of commercial flats.
(2) In terms of having a positive economic and social impact, the landed house as referred to in paragraph (1) may be given more than 1 (one) plot of land or an area of more than 2,000 m2 (two thousand square meters), with the permission of the Minister.
(3) The restrictions referred to in paragraph (1) are exempted from the ownership of a residential or residential house by representatives of foreign countries and/or representatives of international agencies. [...]" (Regulation No 18 of 2021 of the Minister of Agrarian Affairs and Spatial Planning/Head of the National Land Agency of the Republic of Indonesia concerning Procedures for Determining Management Rights and Land Rights [google translation])
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"Can I buy and own land in Indonesia?
Investors can buy and own land in Indonesia for a certain period of time using the following rights:
Exploitation rights (Hak Guna Usaha or HGU) are granted for a maximum of 25 years and can be extended for another 25 years. For companies that require a longer period, HGU for not more than 35 years can be granted.
Building rights (Hak Guna Bangunan or HGB) are rights to build and to own buildings on land that does not belong to someone for a period of no more than 30 years and can be extended for no more than 20 years.
Right to Use (Hak to Use) is the right to use and/or collect products, from land that is directly controlled by the state, or land that is owned by another person who gives the rights and obligations specified in the decision regarding the granting of his right by an authorized official, or in agreement to work the land, as long as it does not conflict with the spirit and provisions of the law.
HGU, HGB and Usage Rights may be owned by Indonesian citizens, foreigners residing in Indonesia, legal entities established under Indonesian law and based/having offices in Indonesia, and foreign companies having representative offices in Indonesia.
HGU and HGB ownership is permitted to change during the contract period. However, land use rights can be transferred to other parties with the approval of the relevant government officials. Individual land use rights may also change hands
Can  foreigner or PT. PMA  purchase a property in Indonesia?
Yes, it depends on the type of property:
1. For a landed building (house, office, factory) it is only allowed for a foreigner or PT. PMA and the status of the land is The Right of Building (HGB) or the Right of Use.  Regarding the ownership of landed house, recently the Government of Indonesia has revealed the new Government Regulation No. 103 of 2015 on House Ownership of Foreigners Residing in Indonesia. This regulation allows foreigners to buy a landed houses under the Right of Use category for a period up to 80 years (an initial period of 30 years and can be extended twice by 20 years and a further 30 years).
2. For a condominium or apartment and office space, the foreigner or PT. PMA can own it as long as it isnt a part of a government-subsidized housing development and the land status of the building is strata title status under the Right of Use. Still based on the same regulation, regarding apartments, foreigners are allowed to purchase an apartment under the Right of Use category and this is only involves luxurious apartments priced over IDR 10 billion.[...]"(BKPM website, "National Single Window for Investment>FAQ>Category: land ownership", website content. ).
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"The second part
Sarusun Ownership
Article 47
(1) As a proof of ownership of sarusun on the land of property rights, building rights or use rights on state land, building rights or use rights on the management rights land is issued SHM sarusun.
(2) SHM sarusun as referred to in paragraph (1) shall be issued to every person who qualifies as the holder of land rights. [..]" (Law No. 20 of 2011 regarding Apartments Units (Rumah Susun))
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"CHAPTER 11 - THE RIGHTS ON LAND WATER AND AIR SPACE, AND LAND REGISTRATION [...]
PART III: RIGTH OF OWNERSHIP [Hak Milik] [...]
Article 21.
(1). Only an Indonesia citizen may have rights of ownership.
(2). Corporations which may posses the right of ownership and its requirements shall be determined by Government.
[...]
PART V: THE RIGHT OF BUILDING [...]
Article 36.
(1) Those who may posses the right of building are:
a. Indonesian citizen; b. Corporation established according to Indonesia Law and having their domicile in Indonesia.
[...]
PART VI: THE RIGHT OF USE [...]
Article 42.
Those who may obtain the right of use are:
a. Indonesian citizen; b. Foreigner residing in Indonesia; c. Corporation which have been established according to Indonesian Law and having they seat in Indonesia; d. Foreign corporations having a representation in Indonesia. [...]" (ACT NO. 5 OF 1960 CONCERNING BASIC REGULATIONS ON AGRARIAN PRINCIPLES)
Government Regulation Number 18 of 2021 concerning Management Rights, Land Rights, Apartment Units, and Land Registration [google translation]
Regulation No 18 of 2021 of the Minister of Agrarian Affairs and Spatial Planning/Head of the National Land Agency of the Republic of Indonesia concerning Procedures for Determining Management Rights and Land Rights [google translation]
BKPM website, "National Single Window for Investment>FAQ>Category: land ownership", website content. 
Law No. 20 of 2011 regarding Apartments Units (Rumah Susun)
ACT NO. 5 OF 1960 CONCERNING BASIC REGULATIONS ON AGRARIAN PRINCIPLES [google translation]
Law Concerning Investment No. 67/2007 [google translation]
[<a href="https://jdih.atrbpn.go.id/api/download/946/Terjemahan%20PP%20No%2018%20Tahun%202021.pdf">GR 18/2021</a>],[<a href="https://peraturan.bpk.go.id/Home/Details/209828/permen-agrariakepala-bpn-no-18-tahun-2021">Reg</a>],[<a href="https://nswi.bkpm.go.id/nswi_dev/faq">BKPM</a>],[<a href="https://peraturan.bpk.go.id/Home/Details/39256/uu-no-20-tahun-2011">Law</a>],[<a href="https://peraturan.go.id/common/dokumen/ln/1960/UU0051960.pdf">Act</a>],[<a href="https://peraturan.go.id/common/dokumen/ln/2007/uu25-2007.pdf">Law</a>],[<a href="https://resourcehub.bakermckenzie.com/en/resources/global-corporate-real-estate-guide/asia-pacific/indonesia/topics/real-estate-law#:~:text=HGB%20title%20is%20a%20right,maximum%20period%20of%2020%20years.">Other</a>]