The CV business formation process in Bali in 2026 should be handled in two layers: form the partnership correctly through the Ministry of Law’s business-entity administration system, then complete the NIB and activity-specific licensing through OSS. The process is different from incorporating a PT, and the current CV registration framework changed in October 2025.
A practical sequence is structure → partners → activities → name check → notarial deed → AHU registration → registration certificate → OSS licensing.
CV Business Formation Process: The 2026 Sequence
Step 1 — Confirm that CV is the right business structure
Before preparing a deed, understand what a CV legally is.
Under Minister of Law Regulation No. 25 of 2025, a CV is a partnership established by one or more limited partners and one or more complementary partners to conduct business continuously.
AHU’s current business-entity profile service places CV data within its non-legal-entity business-entity system alongside firms and civil partnerships.
That structure makes CV materially different from a limited liability company. The choice should therefore be based on ownership, liability, contracting needs and future investment plans rather than on an assumption that CV is simply a smaller version of a PT.
There is also a critical foreign-investment issue. For an investor planning foreign investment, Article 5 of Law No. 25 of 2007 on Investment provides that foreign investment must generally be conducted through an Indonesian limited liability company, unless a law provides otherwise.
Foreign-investment projects should therefore review the PT PMA route rather than assuming a CV can be used as the investment vehicle. Bali Legal ID’s PT PMA formation guide covers that structure separately.
Step 2 — Define the complementary and limited partners
The partner roles should be understood before the deed is drafted because they are not legally identical.
The same Minister of Law Regulation No. 25 of 2025 defines the complementary partner as the partner entitled to act for and on behalf of the CV and jointly liable to third parties up to that partner’s personal assets.
A CV must therefore be structured with at least the complementary and limited-partner roles contemplated by the regulation. The founders should agree on who will act for the business, how economic participation is arranged and what rights and obligations belong to each partner before those terms are recorded in the deed.
Step 3 — Define the business activities before drafting the deed
Write down the activities the CV will actually perform before the notarial documents are finalized. This becomes important both for the deed and for the later OSS licensing stage.
The commercial description should be specific enough to distinguish the core business from possible secondary activities. A trading operation, consulting activity, restaurant and construction business can have different licensing paths even when each is operated through a CV.
This stage is also where founders should identify the intended address and operating location because those details can affect later licensing and project planning.
Step 4 — Have the notary check the proposed CV name
CV registration is now governed by a newer rule than many older online guides still cite.
The current official record for Minister of Law Regulation No. 25 of 2025 lists it as in force, while the former 2018 CV registration regulation has been revoked.
Under Article 4 of Minister of Law Regulation No. 25 of 2025, establishment registration is submitted by the founders together or by the partners through a notary and is filed electronically through the Business Entity Administration System.
The same Article 4 requires the notary to check the proposed CV name before registration, and the regulation sets criteria including Latin lettering, availability within the system and restrictions against names contrary to public order or morality.
Do the name check before assuming a proposed trading name can be used in the deed and registration.
Step 5 — Execute the establishment deed
Once the partner structure, business activity and name are settled, the founders can proceed with the notarial establishment deed.
The deed should reflect the actual partnership rather than temporary arrangements made only to complete registration. The founders should settle the business activities, partner roles, internal rights and obligations and intended duration before signing.
Under Articles 6 and 7 of Minister of Law Regulation No. 25 of 2025, the notary uploads the establishment deed and required declaration and must retain specified records including founder identity, business activities, partner rights and obligations, the CV’s duration, address evidence and beneficial-owner data.
Step 6 — Register the CV through AHU within 60 calendar days
The signing date of the deed starts an important statutory filing period.
Article 5 of Minister of Law Regulation No. 25 of 2025 requires establishment registration to be submitted no later than 60 calendar days from the date the CV establishment deed is signed.
The regulation also states that where the application exceeds that period, the establishment-registration request cannot be submitted under that deed through the stated procedure. That makes the deed date a real compliance checkpoint rather than an informal planning date.
The filing itself is electronic through the Business Entity Administration System and is handled through the notarial process established by the current regulation.
Step 7 — Obtain the registration certificate
Successful AHU registration produces the evidence that the CV has been registered within the Ministry of Law’s business-entity administration system.
Article 8 of Minister of Law Regulation No. 25 of 2025 provides that the Director General issues the CV’s registration certificate when the application is accepted and delivers it electronically through the Business Entity Administration System to the notary.
This registration certificate should not be confused with the NIB or with activity-specific business licensing. Those belong to the next regulatory layer.
Step 8 — Continue to NIB and risk-based business licensing
Registration of the CV does not automatically complete the licensing requirements for its actual commercial activities.
The licensing stage is governed nationally by Government Regulation No. 28 of 2025, the current risk-based business licensing framework.
After AHU registration, the business should address its licensing layer through OSS, whose official portal describes the NIB as the official identity for starting or operating a business and states that the risk-based system uses four risk levels to determine required licences and obligations.
The practical rule is to review each intended activity rather than treating NIB issuance as universal proof that the CV can immediately conduct every planned business. Depending on the activity and risk level, additional licences, standards or supporting requirements may apply.
Bali Legal ID’s OSS RBA registration guide provides a more detailed explanation of this separate licensing stage.
CV Formation Readiness Checklist
The following table summarizes the main points to compare before choosing the next step.
| Stage | Ready to proceed when | Review before proceeding when |
|---|---|---|
| Entity choice | CV matches the ownership and liability structure | Foreign investment is planned |
| Partners | Complementary and limited-partner roles are clear | Founders assume all partners have identical authority and liability |
| Activities | Actual products or services are defined | Business purpose remains vague |
| Name | Notary has completed the required name check | Proposed name is treated as automatically available |
| Deed | Partner rights, obligations, activities and duration are settled | Material terms remain unresolved |
| Filing period | Registration can be submitted within 60 calendar days of signing | The deed is approaching or has passed the filing deadline |
| AHU registration | Registration certificate has been issued | Founders assume the deed alone completes registration |
| OSS | NIB and activity-specific licensing outputs are reviewed | Registration certificate is treated as an operating licence |
Use this comparison as a starting point, then confirm how each point applies to the facts and documents in the specific case.
Conclusion
The CV business formation process in Bali is not the same as PT incorporation. A CV uses a complementary-and-limited-partner structure, is registered through the Ministry of Law’s business-entity administration system and then moves separately into the OSS licensing framework.
For a new CV in 2026, use the current Minister of Law Regulation No. 25 of 2025 rather than the revoked 2018 registration regulation. Confirm that CV is the correct structure, define the partners and activities, complete the name check and notarial deed, submit registration within 60 calendar days, obtain the registration certificate and then complete the NIB and any activity-specific risk-based licensing requirements.
Choose the Business Structure Before You File
If you are deciding between a CV, PT PMDN or PT PMA structure for a Bali business, Bali Legal ID’s business setup service can be used as the consultation starting point, while its listed services include PT PMDN Setup, PT PMA Setup and NIB OSS RBA Registration.
Request a consultation before committing to the entity structure, deed or licensing path, particularly where foreign investment, multiple activities or a long-term property commitment is involved.
Bali Legal ID can help you review the applicable service scope.
For help coordinating the records and next steps discussed above, review our business setup services in Bali.
Read More: Business Setup Bali for PT PMA, PT PMDN & OSS RBA Registration
FAQ CV Business Formation Process in Bali
What is the current regulation for forming a CV in Indonesia?
Minister of Law Regulation No. 25 of 2025 is the current regulation governing legal-service administration for CVs, civil partnerships and firms. It took effect on 13 October 2025 and revoked the former Minister of Law and Human Rights Regulation No. 17 of 2018.
Does a CV need a notary for registration?
Yes. Under the current regulation, establishment registration is submitted by the founders or partners through a notary and filed electronically through the Business Entity Administration System.
How long after signing the deed can a new CV be registered?
The current regulation requires the establishment registration to be submitted within 60 calendar days from the date the establishment deed is signed.
Can a foreign investor use a CV instead of a PT PMA?
For foreign investment, Article 5 of Indonesia’s Investment Law generally requires the investment to be conducted through an Indonesian limited liability company unless another law provides otherwise. A foreign-investment project should therefore be reviewed under the PT PMA framework rather than assuming a CV is available.
Does the CV registration certificate replace an NIB?
No. The Ministry of Law registration certificate evidences CV registration, while the NIB and risk-based business licensing are handled through the separate OSS licensing framework.
References & Sources
- Minister of Law Regulation No. 25 of 2025 on Legal Services for Civil Partnerships, Firms and Commanditaire Partnerships — peraturan.go.id
- Minister of Law Regulation No. 25 of 2025 — Official Status Record — peraturan.go.id
- Law No. 25 of 2007 on Investment — peraturan.go.id
- AHU Online Business Entity Profile Search — ahu.go.id
- Government Regulation No. 28 of 2025 on Risk-Based Business Licensing — peraturan.go.id
- Official OSS Risk-Based Business Licensing Portal — oss.go.id