HPL (Hak Pengelolaan) is a state land-management right — not ownership — granted under Indonesian law to an authorised body to manage and utilise state land. At Parapuar, BPOLBF (Badan Pelaksana Otorita Labuan Bajo Flores) holds HPL over approximately 129.6 ha of what was Hutan Bowosie, a forested hill zone above Labuan Bajo town; the certificate for this HPL Zone 1 was handed to BPOLBF on 15 September 2023 by Deputy Minister ATR/BPN Raja Juli Antoni. That figure is frequently mis-rendered in English-language reports as “129,609 hectares” — a number-format error caused by reading the Indonesian decimal comma in “129,609 ha” as a thousands separator. The correct area is ≈129.6 ha, roughly 1.3 square kilometres. Investors entering Parapuar do not buy freehold. Every right they receive is derivative: it flows from BPOLBF’s HPL through one of six cooperation instruments.
What Hak Pengelolaan Actually Is Under Indonesian Land Law
Hak Pengelolaan is defined in PP 18/2021 (Government Regulation on Land Rights, Rights on Land in State Land, and Third-Party Land) as a right held by a government body or state-owned institution to manage and utilise a plot of state land. The HPL holder does not own the land in the freehold sense; that remains with the state (Hak Bangsa, Art. 1 UUPA). What HPL gives its holder is the exclusive authority to:
- Plan and use the land according to its designated function;
- Grant derivative rights — Hak Guna Bangunan (HGB), Hak Pakai, or use-agreements — to third parties;
- Receive a share of proceeds from third-party utilisation;
- Supervise and coordinate use within the HPL boundary.
For an investor, this structure means BPOLBF sits permanently in the chain of title. You do not register a right directly against the underlying land; you register a right derived from BPOLBF’s authority over that land. That distinction matters enormously for financing, exit options, and risk allocation.
The legal basis for BPOLBF holding this HPL runs through Perpres No. 32 Tahun 2018 (signed 5 April 2018), which designated a specific zone within Hutan Nggorang Bowosie in Manggarai Barat for the tourism authority area, and gave BPOLBF an authoritative (otoritatif) role — not just coordinative — over that core area. The forest-release process flowed through KLHK (the Ministry of Environment and Forestry) and then formalised as HPL through ATR/BPN. The specific KLHK SK (decree) number and date have not appeared in any publicly accessible source. This is a genuine documentation gap. Investors doing title due diligence should request this SK directly from BPOLBF and verify through the ATR/BPN digital certificate system.
The HGB-on-HPL Mechanism: General Law vs Parapuar Reality
Indonesian law gives BPOLBF tools to bring private capital onto HPL land. The most commercially recognised instrument is HGB (Hak Guna Bangunan) granted above HPL — essentially a long-term registered building right layered on top of the state management right. PP 18/2021, Art. 37–38, sets the national maximum terms:
- Initial HGB term
- Up to 30 years
- First extension
- Up to 20 years (requires the right to have been utilised and maintained)
- Renewal
- Up to 30 years (new application; not automatic)
- Theoretical maximum
- 80 years (30 + 20 + 30) — still well short of the 99-year leasehold some brokers quote
These are national ceilings permitted by law. No publicly available BPOLBF document confirms whether the Parapuar cooperation instrument takes the form of HGB-on-HPL, a straight utilisation cooperation agreement (KSP), or another scheme — and no Parapuar-specific term in years has been published. Several consultancy websites quote 25–30 year “leasehold” figures for the Parapuar area; those figures are not sourced from any BPOLBF document we have been able to locate, and you should not treat them as confirmed. Ask BPOLBF’s Investment and Cooperation Division for the specific instrument and term applicable to any lot you are evaluating.
A PT PMA (foreign-majority incorporated company) is eligible to hold HGB in Indonesia, including HGB derived from HPL — this is a standard path for foreign-backed hotel and resort projects. HGB can be mortgaged (Hak Tanggungan), which matters for project financing, though lenders will scrutinise the BPOLBF cooperation agreement carefully given the derivative structure.
The Six Cooperation Schemes BPOLBF Offers (Skema Lahan BPOLBF)
BPOLBF’s official FAQ (in Indonesian; the page has been compromised by spam injection as of mid-2026, which is itself a flag about the state of official digital infrastructure) lists six cooperation instruments available to investors on the HPL land at Parapuar. Below is a plain-English rendering of each, with a note on its typical use case and the critical unpublished variables.
| Scheme (Indonesian) | English label | Typical use | Key unpublished variables |
|---|---|---|---|
| Sewa Aset | Asset lease | Leasing an existing BPOLBF-owned structure or facility; operator brings fitout capital | Rent rate, term, renewal, performance conditions |
| Pinjam Pakai | Loan-for-use | Non-commercial or semi-public use of BPOLBF land/facilities; rarely applicable to private investors | Eligibility criteria; whether commercial activity is permitted |
| KSP (Kerja Sama Pemanfaatan) | Utilisation cooperation | Investor builds and operates on BPOLBF land; revenue share to BPOLBF; standard for hotels and attractions | Revenue-share percentage, minimum guaranteed return to BPOLBF, reversion of improvements |
| BGS / BSG (Bangun Guna Serah / Bangun Serah Guna) | Build–Operate–Transfer / Build–Transfer–Operate | BGS: investor builds, operates for the agreed term, then transfers asset to BPOLBF. BSG: investor builds, transfers, then BPOLBF leases back for operations. Used for larger infrastructure or hospitality assets | BOT term, asset valuation at transfer, post-transfer lease-back terms |
| KSPI (Kerja Sama Penyediaan Infrastruktur) | Infrastructure provision cooperation | Investor co-finances or builds infrastructure (roads, utilities, facilities) within the zone in exchange for rights or revenue participation | Infrastructure cost-sharing formula, right-of-recovery, exclusivity |
| KETUPI (Kerja Sama Terpadu Pemanfaatan dan Infrastruktur) | Integrated utilisation and infrastructure cooperation | Combines operational rights with infrastructure investment obligations; BPOLBF’s most complex scheme, designed for anchor investors committing capital to both a facility and its supporting infrastructure | Scope definition, infrastructure vs. operational split, regulatory approval pathway |
None of these schemes includes a publicly published tariff or standard template. BPOLBF’s public position is that terms are negotiated per investor, per lot, based on a selectivity and sustainability screening. For investors accustomed to fixed-price estate models — Mandalika, Nuvasa Bay — the absence of published lot pricing and standard lease terms is a structural difference worth noting before you engage advisers on assumptions.
If you want to explore the cooperation path in detail, our enquiry form can connect you with independent legal and market-entry specialists who have worked with similar HPL structures across Indonesian tourism zones.
What BPOLBF Has Certified — and What Remains Zone 1 Only
The September 2023 HPL certificate covers Zone 1 of Parapuar — approximately 129.6 ha. BPOLBF references a total planned zone of about 400 ha (used consistently in BKPM and ministry promotion materials, though no publicly accessible cadastral or regulatory document confirms “400 ha” as a certified area). The difference between the certified 129.6 ha and the promoted 400 ha figure suggests either that HPL Zones 2 and beyond are pending certification, or that the broader 400 ha encompasses buffer and coordination areas outside the current HPL boundary.
This distinction matters to investors for a direct reason: the 19 lots offered by BPOLBF sit within the HPL-certified area. Lots outside the certified boundary cannot legally receive HGB-on-HPL or formal cooperation instruments until the HPL for that area is also registered. Before committing to any lot, confirm with BPOLBF whether the specific lot falls within the September 2023 HPL certificate or a later one.
Zone breakdowns circulating in the media — Cultural ±114.73 ha, Leisure ±63.59 ha, Wildlife ±89.25 ha, Adventure ±132.43 ha — originate from a single critical-essay source (omong-omong.com, “Komodifikasi Hutan Bowosie”) and have not been confirmed by any BPOLBF masterplan document available to the public. Treat these as indicative proportions, not verified lot boundaries.
How Parapuar’s HPL Model Compares to Town Alternatives
Investors evaluating Parapuar often also look at land acquisition in Labuan Bajo town or at Golo Mori. The three paths differ fundamentally in legal structure, cost basis, and counterparty risk. The table below uses verified law and sourced figures; broker asking prices are flagged as unverified.
| Parameter | Parapuar (HPL sublease / HGB-on-HPL via BPOLBF) | Labuan Bajo town (HGB via PT PMA over private SHM) | Golo Mori / Tana Mori (ITDC estate) |
|---|---|---|---|
| Underlying land right | State HPL; BPOLBF is permanent superior right-holder | Private SHM (freehold title) owned by seller; investor registers HGB above it | State land managed by ITDC (BUMN); similar HPL-derived structure |
| Can foreigners/PMA hold? | Yes — PT PMA eligible for HGB-on-HPL (PP 18/2021) | Yes — PT PMA holds HGB directly (standard path) | Yes — same PT PMA / HGB path |
| Published land term (max, general law) | Not published for Parapuar; PP 18/2021 allows up to 30+20+30 yrs for HGB | Up to 30+20+30 yrs (PP 18/2021) | Not publicly confirmed; subject to ITDC cooperation terms |
| Land acquisition cost | No published tariff; negotiated with BPOLBF per lot | Broker asking prices IDR 2–15M/m² near town (UNVERIFIED single-source listings; not transaction data); deal-specific | Not publicly disclosed |
| Minimum PT PMA capital (standard) | IDR 10 billion issued/paid-up + >IDR 10 billion total investment excluding land & buildings, per KBLI per project location (Peraturan BKPM No. 4/2021) | ||
| KEK / tax incentive | None — Parapuar is NOT a KEK | None — town land is not KEK-zoned | Proposed KEK, NOT yet established by PP as of mid-2026; verify against Dewan Nasional KEK list |
| Counterparty on exit/renewal | BPOLBF (government body); renewal subject to government policy | Private landowner; commercially negotiable | ITDC (BUMN); policy-subject |
| Foreigner direct ownership | Blocked — Hak Milik closed to foreigners (UUPA Art. 21); nominee arrangements void (Art. 26(2)) | Same — no freehold for foreigners; PT PMA or Hak Pakai (for individuals with valid stay permit) | Same |
The most important practical contrast: in town, you negotiate with a private landowner who holds SHM (freehold), so your HGB sits above a private right that is commercially transferable. At Parapuar, your HGB sits above BPOLBF’s HPL, which is a state right tied to BPOLBF’s mandate under Perpres 32/2018. If that mandate were modified, or if BPOLBF’s authority changed, the implications for renewal and extension could be more complex than in a private-land deal. This is not a reason to avoid Parapuar — state HPL structures underpin major Indonesian projects from Nusa Dua to Mandalika — but it is a reason to have independent counsel review the cooperation agreement before signing.
Parapuar’s HPL Land Status and the Bowosie Forest Question
The land now certificated as BPOLBF’s HPL was, until Perpres 32/2018, a state production forest: Hutan Produksi Bowosie (part of the wider Nggorang Bowosie forest complex). Production forest conversion to non-forestry use in Indonesia requires a release decree (SK Pelepasan Kawasan Hutan) from the Ministry of Environment and Forestry (KLHK). That SK has not appeared in any publicly accessible media or NGO documentation for this case. Floresa.co, Sunspirit for Justice and Peace, and WALHI NTT have all referenced the conversion process in their coverage; none published the SK number. This is a live documentation gap, not a settled record.
Four kampung — Racang Buka, Kaper, Lancang, and Nggorang — claim long-term customary occupation and farming of portions of Bowosie, with residents citing use since at least the 1990s and some claims extending to the 1960s–70s. In 2022, residents physically blocked land-clearing machinery in the Parapuar area. Demonstrations ran through 2022–2023 in Labuan Bajo. AMAN Nusa Bunga framed the claims as adat land rights. As of mid-2026, no publicly documented comprehensive settlement, compensation scheme, or formal recognition of adat claims has been recorded. BPOLBF proceeded: HPL certificate September 2023, groundbreaking for Parapuar Park August 2024, investor commitments announced April 2025.
This matters for investors beyond ethics. Unresolved land conflict carries practical risk: project delays when demonstrations recur; reputational exposure for international brands (Dusit has a US$15M commitment, reported April 2025, single-source, UNVERIFIED); potential ESG/IFC performance-standard scrutiny for any project seeking development finance. BPOLBF’s position — that the HPL is “clean and clear” — is its own statement about its own certificate. Independent legal review of the full chain from KLHK SK through HPL certificate is standard due diligence here, not optional.
Bowosie is also Labuan Bajo’s main water-catchment forest. The Wae Mese spring is the named primary PDAM source for a town that already runs on intermittent supply. Critics — including WALHI NTT — warn that clearing and impermeable surfacing in the catchment worsens recharge rates and raises flood and landslide risk in the surrounding kampung. BPOLBF’s public pledge is that only ~20% of the HPL area will be built; roughly 80% remains green. Civil-society analysts flag that fragmentation and access-road drainage impacts extend beyond the built footprint even on “green” land. Both the pledge and the critique are on the public record; neither is a reason to dismiss the other.
Infrastructure Status: What Exists vs What Is Planned
As of mid-2026, the infrastructure confirmed as physically existing inside Parapuar consists of:
- An access road of approximately 1.5 km — widely cited in BPOLBF and ministry communications; no PUPR public record confirming specifications, construction cost, or formal completion date has been found. As of May 2025 reporting, approximately 200 m of road remained incomplete.
- A 360° viewpoint used for the recurring Weekend at Parapuar (WAP) event series, including the PENTAS x WAP 2026 edition on 6 June 2026 which drew 1,044 visitors (Antara, sindonews).
- Basic event facilities at the viewpoint area — staging, temporary vendor infrastructure. Parapuar Park groundbreaking was held 8 August 2024; completion and operational status UNVERIFIED.
Everything else in BPOLBF’s promotional materials — the zipline, luge, elevated 360° cycling circuit, cable car, inclinator, Kampung Parapuar cultural village, amphitheater, wellness lots, adventure zone infrastructure — is planned or committed, not built. The distinction is not a criticism of BPOLBF’s vision; it is information that investors need when modelling construction timelines and utility availability.
On utilities specifically: no public project-level document confirms the sequencing or budget for water, electricity, and telecommunications inside the HPL boundary. PLN Labuan Bajo capacity and the PDAM Wae Mese supply situation are town-level constraints that Parapuar sits upstream of — literally, in the case of water. The 2025 national infrastructure budget cuts (new-build allocations at PUPR were materially reduced) are an external headwind for any infrastructure co-investment scheme. Per-lot utility availability must be verified directly with BPOLBF before any lot commitment.
What Is Not in the Public Record: A Due Diligence Checklist
This is not a comprehensive legal checklist — you need Indonesian land counsel and a notary (PPAT) for that. It is a list of specific items that are absent from publicly accessible sources and therefore need to be raised directly with BPOLBF.
- KLHK SK number and date for the Hutan Produksi Bowosie release — without this, the chain of title from production forest to HPL certificate cannot be independently traced.
- Specific cooperation instrument applicable to the lot you are evaluating (KSP, BGS, KETUPI, or other) and the exact term in years.
- Published lot tariff or base rental — there is none; pricing is negotiated. Know your comparables before entering negotiation.
- Zone 1 HPL boundary map with cadastral coordinates — the certificate exists, but the plot map (peta bidang) should be obtained from ATR/BPN to confirm lot boundaries.
- Utility service agreements per lot — PLN connection capacity, PDAM allocation, telecommunications access.
- Status of land claims from the four kampung — not as a veto, but to understand whether any compensation or social agreement covers the specific lot area.
- Current BPOLBF directorate contacts for investment cooperation — BPOLBF leadership has shifted (Frans Teguh served as Acting Dirut through 2025; Andhy M.T. Marpaung appears in 2026 broadcast coverage as Plt Dirut; permanent appointment status unverified). Confirm the current authorised contact before submitting any cooperation proposal.
For investors who want support navigating these gaps, our enquiry form can facilitate introductions to independent legal and market-entry specialists with direct experience in HPL-based cooperation structures in Indonesia — and if you proceed with a specialist through us, they may pay us a referral fee at no extra cost to you.
Hak Pakai and Individual Foreign Investors
The HPL and HGB discussion above focuses on corporate investors, specifically PT PMA. Individual foreign nationals who hold a valid Indonesian stay permit (KITAS/KITAP, certain visa types) can hold Hak Pakai over residential property — but Hak Pakai in this context applies to certain property categories in specific price bands set by province (Kepmen ATR/BPN). The NTT province minimum property price threshold for foreigner Hak Pakai has not been confirmed from an accessible current source and must be verified before any individual acquisition. Hak Pakai over state/HPL land is a separate instrument from Hak Pakai over private land; at Parapuar the relevant path for an individual would likely still be through a PT PMA or through BPOLBF cooperation. Do not conflate the two without advice.
The nominee path — where a foreign investor uses an Indonesian citizen as the registered title-holder with a side agreement securing effective control — has been repeatedly voided by Indonesian courts. Under UUPA Art. 26(2), land acquired through a nominee arrangement falls to the state, and the foreign investor’s money is not recoverable. This is not a loophole; it is a known and enforced prohibition.
Frequently Asked Questions
What does HPL mean at Parapuar, and does it affect my investment security?
HPL (Hak Pengelolaan) means BPOLBF holds a state land-management right over approximately 129.6 ha of Parapuar — a right that enables it to grant derivative HGB or cooperation rights to investors, but which keeps the state permanently in the superior position in the title chain. Your investment security depends on the cooperation agreement with BPOLBF, which is not publicly templated. A well-drafted agreement registered at the relevant ATR/BPN office provides meaningful legal protection; an unregistered or vague agreement does not. Independent legal review before signing is not optional for serious investors.
Can a PT PMA hold HGB on top of BPOLBF’s HPL at Parapuar?
PP 18/2021 permits HGB-on-HPL for PT PMA entities — this is the standard legal mechanism for foreign-invested hotels and resorts on HPL land across Indonesia. Whether BPOLBF has adopted HGB-on-HPL as the specific instrument for Parapuar lots, or prefers a KSP or KETUPI cooperation agreement instead, has not been publicly confirmed. Ask BPOLBF’s Investment and Cooperation Division which instrument applies to the specific lot you are evaluating, and request the relevant draft cooperation document before engaging a notary.
What is the land term (lease duration) at Parapuar?
No public BPOLBF document specifies a term in years for Parapuar. The general law under PP 18/2021 allows HGB terms of up to 30 years initial + 20-year extension + 30-year renewal — a theoretical 80-year maximum. Some broker and consultancy sites quote 25–30 years for the area; those figures are not sourced from any BPOLBF document we can locate. The actual term you receive will be in the cooperation agreement you negotiate. Confirm the term and renewal conditions in writing before committing capital.
Does Parapuar carry any special tax incentives or KEK status?
Parapuar is not a KEK (Kawasan Ekonomi Khusus). The fiscal incentives available in KEK zones — income-tax reductions, PPN/PPnBM facilities, customs exemptions — do not apply. BPOLBF’s public undertakings cover facilitation, land legality, and coordination — not fiscal incentives. General tax facilities such as the PP 78/2019 tax allowance may be available depending on KBLI code and eligibility criteria, but must be evaluated case-by-case with a tax adviser. The post-2025 status of the tax-holiday window (PMK 130/2020) is policy-sensitive; verify current applicability before relying on it in any business plan.
What are the Bowosie forest and community claims, and do they affect title?
Bowosie was a state production forest before Perpres 32/2018 designated it for BPOLBF’s tourism authority area. Four kampung — Racang Buka, Kaper, Lancang, and Nggorang — claim customary occupation and farming rights that predate the designation; they physically resisted land clearing in 2022. BPOLBF holds an HPL certificate issued September 2023, which under Indonesian state-land law gives it a formally recognised management right. However, the KLHK forest-release decree underpinning that certificate has not appeared in any public source, and no comprehensive settlement with the four kampung communities has been publicly documented. The formal title position and the community claims run in parallel rather than one extinguishing the other — this is the honest characterisation of the current situation. Thorough due diligence should include a review of the KLHK SK and an inquiry into the status of community claims on the specific lot.