Off-Plan Villa Risk in Flores: Read This First

How to read this: Flores Villas is an independent villa & property guide for Flores and Labuan Bajo — we research and compare villas to rent and buy, then connect you with the relevant supplier, broker or owner. We are not an operator, broker or notary, and resort or area names are used only as neutral examples, not claims of affiliation. Foreigners cannot own freehold land in Indonesia; purchases use leasehold, Hak Pakai or a PT PMA, and nominee arrangements carry real risk — always verify with a licensed notary and legal counsel. Rental and purchase figures are indicative ranges by quote, and this is general information, not legal, tax or investment advice.

Off-plan villa risk in Flores is the set of hazards that arise when a buyer commits funds to a villa or resort unit before that building exists — before the foundation is poured, sometimes before permits are finalised, and in many Labuan Bajo cases, before the developer has even resolved the underlying land title. In a mature market with deep contractor pools, a functioning public sale registry, and established project-finance oversight, off-plan purchases carry manageable risks. Flores is not that market. It is an early-stage tourism destination with thin construction capacity, a remoteness cost premium on every kilogram of materials that has to arrive by sea from Java or Bali, no public record of closed transactions to benchmark anything against, and a pattern of adat-land disputes that independent local press has documented repeatedly. This page explains what the specific risks are, what questions you must answer before any deposit leaves your account, and why a “guaranteed yield” attached to a pre-construction villa in Labuan Bajo should be treated as a red flag rather than a selling point. This is general information, not legal, tax, or financial advice. Before committing to any off-plan development in Flores, engage a licensed PPAT and notary practising in Manggarai Barat.

Why Off-Plan in Flores Is a Different Risk Category

Off-plan purchases are normal in plenty of markets. What makes buying off-plan in Labuan Bajo a materially different proposition from the same structure in, say, Bali or Phuket comes down to five compounding factors that each add to the risk profile individually, and interact to produce a more serious exposure when combined.

1. No public sale registry means no comparables

Indonesia has no national equivalent of a land-registry transaction database that records closed sale prices. Everything labelled as a “market price” or “comparable” in Flores and Labuan Bajo is an asking price from a listing, a broker claim, or a developer’s valuation — not a documented settlement. This matters acutely in an off-plan context because the developer’s completion-value estimate (the number that anchors their return-on-investment projection) cannot be cross-referenced against anything verifiable. You are being asked to believe a price point that no public record confirms, in a market where the only closed-transaction data that exists is what participants choose to share privately.

AirROI data for the Labuan Bajo short-term rental market (twelve months, June 2025 to May 2026) gives the only independently collected dataset this market has: an average annual revenue per listing of around US $7,530, average occupancy of 27.3%, average daily rate of US $156, and revenue-per-available-room of US $37. Those numbers are real. They are also the number you should be modelling from if you want to evaluate what a completed villa might generate — not the developer’s pro-forma, which typically assumes a higher ADR, higher occupancy, and none of the management fees, maintenance, or vacancy gap between bookings that reduce gross-to-net yield sharply.

2. A thin contractor pool and a real remoteness premium

Labuan Bajo is geographically remote. Building materials — cement, rebar, tile, sanitary fittings, electrical components — do not exist in local wholesale quantities. Everything arrives by sea, primarily from Java and Bali. Skilled tradespeople (tilers, electricians, plumbers, concrete specialists) are in short supply locally; bringing them from Bali or Lombok adds accommodation and transport costs to their daily rate. There are no large general contractors with deep project-management capacity based in Manggarai Barat; construction here runs through local sub-contractor chains that lack the systems and float to absorb unexpected costs.

The practical consequence is a build-cost premium over Bali of roughly 20–40% for mid-range construction, and more for remote or island plots where a second sea leg is involved. For general planning context only (these are not quotes; get your own contractor estimates): Bali mid-range construction runs approximately IDR 9–13 million per m² by broad industry references; a Flores equivalent under the same standard might come in around IDR 11–18 million per m², with luxury or island-remote builds potentially higher still. A developer whose feasibility study used Bali build-cost assumptions — and some do — is operating on a spreadsheet that does not reflect what construction in this location actually costs.

3. Construction delays are common and hard to penalise

Delays in Indonesian construction are not exceptional events. They are the default. The specific factors in Flores compound the baseline: wet-season monsoon disrupts sea transport of materials from roughly November to March; local contractor capacity is already stretched by the tourism infrastructure build-out that followed the super-priority designation; and small developers frequently manage cash flow by starting Stage One construction with deposits from the first buyers before the project finance for the full development is in place. When that model hits a cost overrun or a slower-than-expected sales pace, Stage Two is funded by Stage Three deposits, and completion dates slip.

The legal framework for penalising a developer for delay in an off-plan context in Indonesia is not strong. Developer liability provisions in Indonesian consumer protection law exist (Law No. 8 of 1999 and its implementing regulations), but enforcing them against a small developer in a regional court, when the contract is drafted by the developer’s own legal team, is practically difficult. A developer who delivers six months late, or eighteen months late, is rarely in the position of having violated a clearly specified contractual deadline with a clear financial remedy attached. The specific terms in your sale-and-purchase agreement govern what recourse you actually have — which is exactly why that document needs to be reviewed by an independent PPAT or lawyer before you sign it, not after.

4. The adat-land and certificate-fraud pattern

Independent Indonesian-language regional press — Floresa, Koran Timur, Berita Flores — has documented a recurring pattern in Manggarai Barat: SHM (Hak Milik) certificates presented as valid titles where the underlying chain traces back to an adat (customary) land conversion that was incomplete, disputed, or improperly handled. In a handful of documented cases, the same underlying plot appears under more than one certificate. This is not the majority of transactions here. It is a documented pattern that any buyer in this market should treat as a known risk to check against, not a theoretical concern.

In an off-plan context, this risk is compounded by timing. A buyer who pays a deposit before the developer has completed the title chain on the underlying land is exposed to the possibility that the land the development will be built on is not cleanly owned. By the time a dispute over the underlying title becomes visible — via a court proceeding, a competing certificate claim, or a blocking notation at the BPN — the deposit may already be in the developer’s account and the construction may have started. Recovering that deposit from a developer in a disputed-title scenario is not straightforward. This is why the title question must be resolved before any money changes hands, not after.

5. No established track record to evaluate

In a mature off-plan market, a buyer can evaluate the developer by looking at their completed projects: Did the last development deliver on time? What do the finished units look like? What are owners in those units actually earning? In Labuan Bajo, the off-plan market is genuinely new, and the number of developers with a completed, income-generating track record in the Flores market specifically is small. A developer who is selling an off-plan opportunity based on projected outcomes from Bali projects, or who is new to Flores entirely, is asking you to bear the full pioneer risk of their learning curve in this specific market.

Questions to Answer Before Any Deposit

Each of the questions below maps to a real failure mode. If you cannot get a clear, documented answer to any of them, that is information about the project — not a temporary gap that will fill in after you have signed.

Who holds the land title and under what right?

Before an off-plan deposit, you need the answer to: who is the registered landowner on the BPN certificate right now; what type of right is registered (SHM, SHGB, SHP, or another type); and whether that right is encumbered by a Hak Tanggungan (mortgage lien) or any blocking notation. You need the certificate number so your PPAT can conduct a formal BPN title search at the Kantor Pertanahan Manggarai Barat. If the developer cannot provide the certificate number, or is evasive about the title type, that is a reason to pause — not a reason to trust a verbal assurance and pay anyway.

If the land is held by the developer under SHM (Hak Milik), the question of how a foreign buyer ends up with a legally valid interest in the completed villa is immediately relevant. Hak Milik cannot be held by foreigners (individuals or PT PMA) under Law No. 5 of 1960. The developer’s structure for selling to foreign buyers — whether via a leasehold (Hak Sewa) contract over the villa, or via a PT PMA entity that will hold HGB over the land — must be specified in the documents before you pay anything.

Is the developer’s structure compliant for a foreign buyer?

This is where off-plan development in Indonesia gets legally specific fast. The three structures a foreign buyer can legitimately use are:

Hak Sewa (leasehold) over the completed villa

The developer retains the underlying land right; the foreign buyer holds a notarised lease over the villa unit for a defined term. Typically 25–30 years with contractual extension options. The enforceability of very long stacked extensions has not been widely tested in NTT courts — structure carefully and confirm your PPAT is comfortable with the specific drafting.

PT PMA + HGB (foreign-investment company holding Right to Build)

The foreign buyer incorporates a PT PMA in Indonesia, and that company either buys from the developer holding HGB over the land, or joins a joint-venture structure. Carries ongoing annual corporate compliance obligations: tax filing, BKPM annual reporting, accounting. These costs are real and are frequently underestimated in developer projections.

Hak Pakai (Right to Use)

Available to foreign individuals holding a valid KITAS or equivalent Indonesian residency permit. Tenure figures vary by source and regulatory era (20+20, 25–70, and 30+20+30 years have all been cited); confirm the current applicable duration with a PPAT under GR 18/2021. Only useful if you hold the qualifying residency permit.

What is not a compliant structure is a nominee arrangement — any setup where the land or villa is registered in an Indonesian citizen’s name while a foreigner provides the funds and holds a private side-agreement claiming beneficial ownership. That structure is non-compliant with Law No. 5 of 1960, can be declared null and void by a court, and leaves the foreigner with no enforceable claim if anything goes wrong. If a developer, agent, or “legal advisor” presents nominee ownership as the mechanism for foreign buyers to acquire an off-plan villa in Flores, find a different developer, agent, or advisor. This is general information; confirm the applicable structure with a licensed PPAT before signing any agreement.

What permits exist right now?

Indonesia replaced the old IMB (Izin Mendirikan Bangunan) building permit system with a new framework — the PBG (Persetujuan Bangunan Gedung, or Building Approval) under Law No. 11 of 2020 and its implementing Government Regulation No. 16 of 2021. The PBG is the permit you need to confirm exists before construction starts. Ask the developer for the PBG document number and verify it directly with the Dinas Pekerjaan Umum (Public Works office) in Manggarai Barat. If the permit is “in process,” find out at what stage, and ask what happens to your deposit if the permit is refused or requires redesign.

Separately, confirm the underlying land zoning via the RTRW (regional spatial plan) for Manggarai Barat and the RDTR (detailed spatial plan) for Labuan Bajo where it applies. A plot marketed as a beachfront villa site may sit within a coastal setback zone that makes the planned footprint non-compliant, or may abut a conservation buffer adjacent to Komodo National Park. Zoning problems are not automatically fixed by a building permit being issued; they are sometimes a reason a permit has not yet been issued, and they are sometimes a reason a completed building faces retroactive enforcement action. Ask your PPAT to run the zoning check as part of the due-diligence process on any pre-construction villa in Indonesia.

How are staged payments protected?

Off-plan developments typically ask buyers to pay in stages tied to construction milestones: deposit on signing; a further tranche on foundation completion; another on roof structure; final payment on handover. The protection question is: what keeps your money safe if the project stalls between stages?

In a well-structured off-plan transaction, staged payments are held in an independently controlled escrow or client account until the relevant milestone is certified. In practice, many Indonesian off-plan developers — especially smaller regional ones — do not offer escrow: milestone payments go into the developer’s operating account and are used to fund construction, with the buyer bearing the liquidity risk if construction pauses. There is no Indonesian government-mandated escrow requirement for off-plan residential villa sales comparable to what exists in some other markets.

Before you pay an off-plan development flores deposit, ask these specific questions in writing: Is there a neutral escrow account for buyer funds? If so, who is the escrow holder and what are the release conditions? If there is no escrow, what security does the buyer have against the developer’s insolvency or abandonment of the project? What specific milestones trigger each payment tranche, and how is milestone completion independently certified? What happens if a milestone is not reached within the contractually specified time? What is the refund process, including timeline and currency, if the buyer exercises a contractual right to withdraw?

If you cannot get documented answers to these questions, the deposit protection in this project is weaker than the brochure implies.

What happens if the project stalls?

Developers rarely advertise their stall scenario, but it is the question that matters most in a thin, early-stage market. A project stalls when the developer runs short of cash mid-construction — either because the early-stage sales pace was slower than their model assumed, because build costs overran, or because a title or permit problem emerged that froze construction pending resolution. In that scenario, your funds are already deployed, the asset is incomplete, and your options are limited.

The specific remedies depend entirely on your sale-and-purchase agreement. Does it include a fixed-completion deadline with a clearly specified financial remedy for delay? Does it specify what constitutes project abandonment and what the buyer’s rights are at that point? Is the developer a legal entity (PT) with audited accounts and verifiable assets, or an individual or informal group? A project sold through a corporate entity at least gives you a juridical person to pursue legally; an individual developer in a regional jurisdiction is harder to reach via litigation.

Indonesian consumer protection law provides general remedies for consumers against business actors, but applying those remedies against a small developer in a regional court is not fast, not cheap, and not predictable. The best protection against the stall scenario is doing the diligence before you pay — not constructing a recovery plan after the problem materialises.

The “Guaranteed Yield” Red Flag

Off-plan villa marketing in Labuan Bajo — and across Indonesia more broadly — frequently includes a yield guarantee or ROI projection. The headline numbers vary; the structure is typically the same: the developer or affiliated management company promises the buyer a guaranteed rental return of some percentage (12%, 15%, 18% are numbers that have appeared in the market) for a specified number of years after handover, often backed by a leaseback arrangement where the developer manages the villa and the buyer receives a floor return regardless of actual occupancy.

Several things make these guarantees worth scrutinising rather than taking at face value.

The independent rental data for the Labuan Bajo market does not support headline yield figures at the top end of what is marketed. AirROI’s twelve-month dataset (June 2025 to May 2026) puts average revenue per listing at around US $7,530 and average occupancy at 27.3%. If you take a villa priced at, say, US $250,000 and apply a “guaranteed” 15% yield, that implies US $37,500 in annual income — five times what the average active listing in this market actually generated in the dataset period. Even assuming the specific villa outperforms the market average materially, the gap between a guaranteed yield claim and a realistic income projection is significant.

For context: even in mature Indonesian rental markets, gross yields average roughly 8.3% nationally. Bali, with a far deeper demand base and longer-established distribution channels, runs around 5.8% gross. A pre-construction villa risk indonesia framing of 12–18% net in a market with 27% occupancy and no established booking infrastructure is an extraordinary claim. Extraordinary claims need extraordinary evidence, which means independently verified historical occupancy and revenue data from comparable completed units in this specific market. If that data does not exist — because the development is the first of its kind, or because the developer is new to Flores — the yield figure is a projection, not a track record.

The guarantee itself is also worth examining. A guaranteed-yield clause is only as strong as the guarantor. If the guarantee is provided by the developer itself (not by an independent escrow or bond), then the guarantee fails at precisely the moment you are most likely to need it: when the developer is in financial difficulty. A guarantee from a related management company has similar limitations if that company’s solvency is tied to the project performing as projected.

None of this means guaranteed-yield structures are always dishonest or always worthless. They mean the buyer has to understand what exactly is being guaranteed, by whom, under what conditions the guarantee can be suspended or cancelled, and what recourse exists if it is not honoured. These are questions to put to your independent PPAT or legal advisor, not to the developer’s sales team.

The Title Structures in Plain Terms

Because off-plan transactions necessarily involve a future title configuration that does not yet exist, it helps to be clear about what the options look like at completion. The table below summarises the structures relevant to a foreign buyer in Flores. Confirm all specifics with a licensed PPAT in Manggarai Barat; this is general information, not legal advice.

Title structures for a foreign buyer of an off-plan villa in Flores — general information as of mid-2026; not legal advice; confirm with a licensed PPAT in Manggarai Barat

Structure	Legal basis	Indicative tenure	Foreign buyer eligibility	Practical notes for off-plan buyers
Hak Sewa (leasehold) over completed villa	Notarised lease agreement; underlying land stays with developer or landowner	Typically 25–30 yr base, with contractual extension options	Any foreign buyer (individual or company)	Most common structure in the Labuan Bajo market. Confirm the lease is properly notarised and that extension options are clearly specified. Long stacked extensions not widely tested in NTT courts.
PT PMA + HGB over the completed building	PT PMA company holds Right to Build on the land; foreign shareholder holds the company	~30 yr, extendable	Foreign investor via a licensed PT PMA; requires BKPM incorporation	Compliant for commercial rental operation. Annual compliance costs (tax, BKPM reporting, accounting) typically IDR 20–50 M/yr or more by market reference — confirm with an accountant.
Hak Pakai (Right to Use)	Registered right under GR No. 103/2015 and GR 18/2021	Varies; confirm current figures with PPAT under GR 18/2021	Foreign individual holding valid KITAS or equivalent	Least common for commercial villa investment; more suited to a foreign resident intending to occupy the property. Lapses if KITAS expires without renewal.
Nominee arrangement (Hak Milik in Indonesian citizen’s name)	Non-compliant with Law No. 5 of 1960 (UUPA)	—	No legitimate route	Can be declared null and void. Foreign buyer has no enforceable claim on breakdown. GR 18/2021 requires relinquishment within one year. Do not use.

A Realistic Pre-Purchase Checklist for Off-Plan Buyers

Before you pay any deposit on an off-plan development in Flores, work through each item below. These are not bureaucratic formalities. Each corresponds to a real risk that has materialised for buyers in this market or comparable early-stage Indonesian markets.

• Land title: Obtained the certificate number; instructed your PPAT to run a BPN title search at Kantor Pertanahan Manggarai Barat; confirmed title type, registered owner, area, and absence of lien or blocking notation.
• Developer structure: Confirmed how the developer’s legal structure translates into a title right for a foreign buyer at completion (Hak Sewa, HGB via PT PMA, or Hak Pakai); rejected any nominee framing; reviewed the draft sale-and-purchase agreement with your own PPAT, not the developer’s lawyer.
• Permits: Seen the PBG (Persetujuan Bangunan Gedung) document number and verified it with the Dinas Pekerjaan Umum in Manggarai Barat, or confirmed at what stage the application sits and what conditions attach; confirmed zoning via RTRW/RDTR for the specific plot.
• Adat chain: Asked how the developer acquired the land and whether that acquisition traces back through a complete, documented chain; checked for any competing claims or documentation gaps; had your PPAT run the adat history check alongside the BPN search.
• Payment protection: Established whether buyer funds go into an escrow account or directly to the developer; confirmed what security exists if construction halts; confirmed the refund mechanism in writing.
• Milestone schedule: The contract specifies construction milestones with dates, independent certification of each milestone, and a financial remedy if any milestone is missed by a defined period.
• Completion deadline: A hard completion date is in the contract, with a specified remedy (not merely “best efforts”) for the developer’s failure to meet it.
• Developer track record: Verified at least one completed project by the same developer in Indonesia, ideally in Flores or NTT, where completed buyers can speak to their actual experience — not just a brochure reference.
• Yield claims: Any guaranteed yield figure has been interrogated for the identity and creditworthiness of the guarantor, the mechanism and conditions of the guarantee, and how it compares to independently available short-term rental data (AirROI for Labuan Bajo: average US $7,530/yr revenue, 27.3% occupancy over the twelve months to May 2026).
• Exit route: Considered who the resale buyer pool is for a leasehold or HGB-structure villa in this market, given that foreign-ownership structures reduce the eligible buyer pool and there is no liquid secondary market in Flores off-plan resales.

Build Costs: What the Developer’s Numbers May Not Reflect

Cost overruns on off-plan development in Flores are not exceptional events. They are a predictable consequence of the supply chain. For planning purposes only — these figures are general references, not quotes, and your specific project must be costed by a local contractor and verified by an independent quantity surveyor — mid-range construction in Bali by broad industry references runs in the region of IDR 9–13 million per m². The Flores remoteness premium on that baseline is roughly 20–40%. A plot on an offshore island with an additional sea transfer adds more. Luxury finishes and infinity pools add more still.

A developer whose feasibility model used Bali build costs as the proxy for a Flores project has a structural optimism bias in their numbers from the start. Ask the developer for their quantity surveyor’s bill of quantities and the contractor quotes underlying the construction-cost figure in their prospectus. If they cannot produce those, the cost figure is an estimate, and the contingency provision against cost overruns is the relevant question: what happens to the project, and to your deposit, if construction costs come in 30% over budget?

Infrastructure is a related variable that developer pro-formas sometimes handle lightly. Electricity on Flores runs on the PLN grid for the Flores sub-system, which relies significantly on diesel generation; outages are reported as common across NTT, and most operating villas use backup generators as standard — an ongoing opex item. Water in the Labuan Bajo area is under stress during the dry season; limited PDAM (municipal water) coverage means many properties rely on trucked water or boreholes with storage tanks. A villa that is not connected to reliable electricity and water cannot operate as a short-term rental at the yield assumptions in the developer’s projection. Confirm the infrastructure plan for the specific plot before accepting any pro-forma.

Seasonality and the Liquidity Reality

Flores is a highly seasonal market. AirROI data shows peak monthly revenue in August and September around US $1,424/month with occupancy reaching roughly 40%; low season drops to around US $720/month. That is a 2:1 peak-to-low revenue ratio. A developer’s yield projection using an annualised average rate without reflecting that distribution pattern is presenting the number in the most flattering light.

Equally important is the liquidity question at exit. Foreign-ownership structures reduce the pool of eligible resale buyers. A Hak Sewa leasehold villa with, say, eighteen years remaining on the base term is a different asset from a freehold property: the remaining term affects resale value, and the pool of buyers who can legally acquire it — and who want to — in the Flores market specifically is narrow. There is no organised secondary market in part-built or completed off-plan units in this market. If your investment thesis requires a clean exit within a defined horizon, the exit route needs to be thought through as carefully as the entry.

Ready to talk through a specific development or get a vetted PPAT referral in Manggarai Barat? Use our enquiry form or reach us on WhatsApp at +62 811-139-4145-63 or bd@juaraholding.com. If you proceed with a partner we refer, they may pay us a referral fee at no extra cost to you.

Frequently Asked Questions

What is the biggest risk of buying off-plan in Labuan Bajo?

There is no single biggest risk — the off-plan risk in Labuan Bajo is a combination of interacting exposures that each need to be managed. The most consequential in the Flores context is probably the land-title risk: paying a deposit before confirming that the developer holds a clean, unencumbered, undisputed title over the plot. The pattern of adat-land disputes and certificate irregularities documented in regional press means that a certificate that looks valid may carry an underlying chain problem that surfaces only after your money is in. Close behind it is the developer-solvency risk in a market with no established track record: if the project stalls mid-construction, your recovery options are limited. Both risks are reduced, not eliminated, by thorough due diligence before any deposit. This is general information, not legal or financial advice; consult a licensed PPAT in Manggarai Barat before committing funds.

Can a foreigner legally buy an off-plan villa in Flores?

A foreigner can hold a legal interest in a completed villa in Flores via three compliant structures: Hak Sewa (notarised leasehold), Hak Pakai (Right to Use, available to foreign individuals with a valid KITAS), or HGB held by a PT PMA (foreign-investment company). The off-plan structure must be designed so that at completion the foreign buyer ends up in one of these compliant positions. Freehold (Hak Milik) is not available to foreigners under Law No. 5 of 1960, and a nominee arrangement — where Hak Milik is held in an Indonesian citizen’s name with a private side-agreement — is non-compliant and can be declared void. Confirm the specific structure with a licensed PPAT before signing any purchase agreement. This is general information, not legal advice.

What should I check before paying a deposit on a pre-construction villa in Flores?

At minimum, before an off-plan development deposit leaves your account: confirm the land certificate exists and is clean via a formal BPN title search conducted by your PPAT; verify that a PBG (building permit) exists or is at an advanced, documented stage of approval; confirm the plot zoning permits the intended development; establish how the developer’s structure translates into a legally valid foreign-buyer title at completion; and review the draft sale-and-purchase agreement with your own independent PPAT — not the developer’s legal team. If any of these cannot be confirmed before the deposit, that is reason to pause, not to trust assurances. This is general information, not legal advice.

Are guaranteed ROI or guaranteed yield claims on off-plan villas in Indonesia reliable?

Treat them with significant scepticism, particularly in Flores. The only independent short-term-rental dataset for the Labuan Bajo market (AirROI, June 2025 to May 2026) shows average annual revenue per listing around US $7,530 and average occupancy of 27.3%. Marketing claims of 12–18% yields or 20–30% annual land appreciation are single-source, marketing-driven figures with no independent underlying data behind them, and they are inconsistent with what the actual rental market generates. Even mature markets like Bali run around 5.8% gross yield. A guaranteed-yield clause is also only as strong as the guarantor’s financial position; if the guarantee is provided by the developer itself rather than an independent third party, it fails precisely when the developer is in difficulty. Ask your independent legal advisor to review any yield guarantee clause before you rely on it. This is general information, not financial advice.

What building permit do I need to check for an off-plan villa in Flores?

Indonesia replaced the old IMB (Izin Mendirikan Bangunan) with the PBG (Persetujuan Bangunan Gedung) under Law No. 11 of 2020 and its implementing Government Regulation No. 16 of 2021. For any off-plan development in Flores or Labuan Bajo, ask the developer for the PBG document number and verify it independently with the Dinas Pekerjaan Umum in Manggarai Barat. If the PBG has not yet been issued, find out exactly where the application stands, what conditions remain outstanding, and what contractual protection you have if the permit is refused or materially delayed. A development marketed as “permits in process” is asking you to carry the permit risk alongside the construction risk. That is a negotiating point, not a standard term to accept without scrutiny. This is general information, not legal advice.