An update on Land Valuation Rule: Highlights on Minister of Agrarian Affairs and Spatial Planning Regulation No. 3 of 2026
On February 25, 2026, the Minister of Agrarian Affairs and Head of the National Spatial Planning Agency (the “Minister”) issued Regulation No. 3 of 2026 on Land Valuation (“Regulation 3/2026”), which will come into effect on May 25, 2026.
The legal framework for land valuation in Indonesia was previously not comprehensive. Prior regulations merely mentioned or implicitly recognized the government’s authority to determine the value of plots of land. Regulation 3/2026 introduces clearer provisions regarding the object, implementation, utilization and objectives of land valuation.
We set out below several key adjustments and changes introduced under Regulation 3/2026.
♦ Products of Land Valuation
According to Article 1(1) of Regulation 3/2026, land valuation is a process undertaken to estimate the value of a plot of land or a designated zone. Land valuation may be used to determine the Land Value Zone (Zona Nilai Tanah or “ZNT”) and the Value of a Plot of Land (Nilai Bidang Tanah or “NBT”). ZNT represents a defined area comprising multiple NBTs that have relatively similar values. NBT, on the other hand, represents the value assigned to an individual plot of land. The results of ZNT and NBT are reflected in the ZNT Map and NBT Map, respectively. Both maps are made available electronically through the Minister’s land mapping application, BHUMI, or may be requested directly to land offices.
♦ Subject and Object of Land Valuation
Although the authority to conduct land valuation rests with the Minister, the actual valuation is carried out by a land appraiser, who may be either a civil servant or a non-civil servant. As mentioned earlier, land valuation may be conducted on a plot of land or for a group of plots of land (zone). Article 3 of Regulation 3/2026 states that the land subject to valuation may include both agricultural and non-agricultural land, but excludes areas designated as forest areas. It should be noted that land valuation does not take into account any building or vegetation growing on the land.
♦ Land Valuation Process
Pursuant to Article 7 of Regulation 3/2026, in conducting the land valuation, the appraiser will require two sets of data: first, the transaction data, which consists of information relating to sale and purchase activity within a certain period. Second, offering data, which consists of information on the prices at which properties are offered to potential buyers during a specific period. Furthermore, surveys may be conducted with respondents as well, including landowners who have conducted transactions or who are planning to sell their land, property agents, property developers, government officials, village heads, residents in the surrounding area.
♦ Land Valuation Update
Under Regulation 3/2026, updates to land valuation may be conducted in the event of changes to the physical form of the land. Such changes may arise from land administration services (including land registration, plot of land separation, plot of land combination, recalculation of land area, upgrade on land data) or from natural causes.
In addition, the integration of the updated Land Value Maps into the existing maps is scheduled to take place on January 1st. However, it remains unclear whether this integration is intended to occur as one-time update or as an annual process.
This development may be relevant for businesses in the real estate sector, as it provides a reference for the most up-to-date land values.
♦ Utilization of Land Valuation Map
Regulation 3/2026 provides that the Land Valuation Map may be utilized to support land related and spatial planning services, as well as other interests related to land value.
Land value zones serve several important functions, including the following:
1. Guidance for determining the Sale Value of Taxable Object (Nilai Jual Objek Pajak or NJOP);
2. Support for spatial planning, assisting the government in conducting urban planning;
3. Enhancement of transparency in the property market by providing the public with reasonable references for land prices;
4. References for investment planning, particularly in relation to land and land rights.
AKSET
Please contact Adhitya Ramadhan (aramadhan@aksetlaw.com) or Muhammad Dzaki Ramadhan Al Rizal (mrizal@aksetlaw.com) for further information.
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