Regulation Watch · Property and Construction · Indonesia, including every province and regency or city in Bali
Protected Rice-Field Conversion Needs an ATR Recommendation
Presidential Regulation 4/2026 blocks conversion of mapped protected rice fields that have not yet been integrated into sustainable-food-agricultural land in the spatial plan until the ATR Minister issues a land-use change recommendation.
- Published
- Presidential Regulation 4/2026 was enacted and promulgated on 4 February 2026 in State Gazette 2026 No. 11. Coordinating Minister for Food Regulation 2/2026 was enacted on 1 April and promulgated on 24 April 2026 in State Bulletin 2026 No. 263.
- Effective
- Presidential Regulation 4/2026 took effect on 4 February 2026. Coordinating Minister for Food Regulation 2/2026 took effect on 24 April 2026.
- Added to Watch
- 15 September 2026
Who is affected
Landowners, buyers, developers, PT PMA companies, foreign investors and shareholders, lenders, landlords and tenants planning a change of use, architects, planners, notaries and PPATs, contractors, and advisers assessing land for villas, hotels, housing, commercial buildings, industry, or other non-rice-field use.
Practical impact
A parcel shown on the protected-rice-field map, known as the Peta Lahan Sawah yang Dilindungi or Peta LSD, cannot be converted while it has not yet been integrated as sustainable-food-agricultural land in the applicable spatial plan unless the ATR Minister first gives a land-use change recommendation. Verification expressly compares the latest rice-field data with land rights, permits, concessions, KKPR, location determinations, spatial-plan subzones, irrigation, national strategic projects, and industrial activity. A land title, a favourable-looking RDTR zone, an old permit, or a PBG application therefore does not by itself resolve LSD compatibility.
Late discovery: Presidential Regulation 4/2026 was enacted, promulgated, and made effective on 4 February 2026, replacing Presidential Regulation 59/2019. It remains actionable because its parcel-level control applies now to prospective projects and to pre-existing applications that had not obtained the required recommendation when the new regulation took effect.
The protected map is not limited to technically irrigated fields. The regulation allows irrigated and non-irrigated rice fields, including rain-fed fields, in protected or cultivation areas to enter the verification process. Verification uses current satellite interpretation and land, permit, concession, KKPR, location, spatial-plan, irrigation, sustainable-agricultural-land, forest, and other supporting maps, normally at 1:5,000 scale or 1:10,000 where 1:5,000 cannot be used.
The key development control sits in Article 17. If land appears on the Peta LSD but has not yet been integrated as KP2B or LP2B in the spatial plan, it cannot be converted before the ATR Minister issues a recommendation for change of land use. Existing LSD maps must be integrated into sustainable-food-agricultural areas or land, and new or revised spatial plans must perform that integration. The regulation does not say that an ATR recommendation overrides the controls applying after a parcel has become KP2B or LP2B.
The transition is important for land already in a pipeline. Applications involving land acquisition, location determination, KKPR, or permission to change land use that were filed before 4 February but remained without the recommendation are processed under Presidential Regulation 4/2026. Developers should therefore reopen legacy due diligence rather than assuming that an earlier filing date preserves the former procedure.
Coordinating Minister for Food Regulation 2/2026, effective 24 April 2026, makes the inter-agency process operational. Its task force checks the latest Lahan Baku Sawah against permits, national strategic projects, and industrial activity; the resulting Peta LSD becomes the basis for KP2B in RTRW and LP2B in RDTR. In Bali this national layer must be checked together with the province's productive-land rules and the relevant regency or city RTRW and RDTR. PBG or SLF documents cannot cure an incompatible land use.
Required action
- Before acquiring, leasing, financing, designing, or marketing a site, overlay the exact parcel against the current Peta LSD and Lahan Baku Sawah data as well as the applicable RTRW, RDTR, KP2B or LP2B, protected-area, green-zone, irrigation, and land-right records.
- Obtain written parcel-level confirmation from the competent land and spatial-planning authorities where the map status is unclear; do not rely only on a broker's map screenshot, the certificate description, or the apparent condition of the land.
- If the parcel is mapped as LSD but is not yet integrated into KP2B or LP2B and a non-rice-field use is proposed, confirm the ATR land-use change recommendation route before treating the project as buildable or committing construction capital.
- Revalidate any conversion, land-acquisition, location, KKPR, or land-use application filed before 4 February 2026 that was still awaiting the required recommendation on that date, because Article 26 makes the new regulation applicable to it.
- Make LSD, LP2B or KP2B, RTRW and RDTR compatibility—and any required recommendation—a documented condition precedent in the land, lease, financing, joint-venture, and construction arrangements, with a clear long-stop date and exit or refund mechanism.
- Do not treat PBG or SLF processing as a substitute for land-use compatibility. Align the land recommendation, KKPR and spatial approvals before filing or relying on building approvals for the proposed use.