Chapter 9

Title and Permits

Figures converted from Indonesian rupiah at historical FX rates — see data/company.json.fx_rates. Ratios, margins, and multiples are unitless and unchanged.

CBDK's land is registered and unencumbered: the IPO prospectus lists 267 building-right certificates covering 7,935,124 sqm across four group companies, every one of them recorded as not pledged. Two facts sit underneath that and appear nowhere in the accounts. Each certificate carries an expiry date, and 57.9% of the certificated area expires by the end of 2042. After minority interests, 83% of that land belongs to CBDK's own shareholders.

Sources: certificate schedules in the IPO prospectus [1] [2] [3] [4]; effective ownership percentages [5]. Expiry and effective-area shares are derived.

The only parcel-level record of the land

Every chapter of this report that has priced CBDK's land — the carrying cost per square metre in Land at Cost, the run-off residual in Backlog Run-Off — has worked from an area and a cost figure in the notes. The notes give one line: land and buildings ready for sale and land under development with building-right (Hak Guna Bangunan, or HGB) status measured 3,678,961 sqm at 31 December 2025, and undeveloped land measured 3,341,874 sqm [6]. The undeveloped half — 47.6% of the reserve — carries no stated title status in any period of the accounts. At 31 March 2026 the HGB-status figure was 3,626,873 sqm [7].

Section VIII.13 of the IPO prospectus answers the question the accounts leave open. It lists, certificate by certificate, every parcel legally registered to the company and its subsidiaries: number, issue date, village, area, expiry date, and encumbrance status [1]. The four schedules together total 7,935,124 sqm — more than the 7,020,835 sqm of land the FY2025 sustainability data reports, because handovers during 2025 have since moved parcels out of the group. All 267 entries carry the same note in the encumbrance column: tidak sedang dijaminkan — not currently pledged.

Sources: certificate schedules [1] [2] [3] [4]; ownership percentages at 31 March 2026 [5]. Effective area is derived.

A fifth subsidiary, the advertising vehicle ASGE, held no land or buildings at all at the prospectus date [4].

Two-thirds of the certificated area sits in subsidiaries CBDK does not wholly own. Applying the effective interests disclosed at 31 March 2026 — MAS 77.35%, CGIC 78.46%, CKI 57.00% [5] — leaves 6,605,278 sqm attributable to CBDK's own shareholders, or 83.2% of the gross reserve. On the ownership levels that applied when the shares listed, when CBDK held 55.89% of both MAS and CGIC, the same schedules attributed 5,352,892 sqm, or 67.5% [8]. The three subscription rounds of 2025 examined in Ownership and Affiliates therefore bought roughly 1.25 million sqm of effective land area — the physical counterpart of the equity arithmetic set out there. Any per-square-metre figure computed on the gross reserve overstates what accrues to the listed company by about a fifth.

The expiry profile

HGB is a term right. Each certificate in the schedules carries a tanggal berakhir hak — a date on which the right ends — and those dates cluster.

Source: derived from the certificate schedules in the IPO prospectus [1] [2] [3] [4]. Row-level areas sum to 794.4 ha against the schedules' own entity totals of 793.5 ha, a difference of 0.1%.

The concentration is in two dates. A single certificate held by MAS — SHGB No. 00225, issued 31 August 2018 over Tanjung Burung — covers 2,869,168 sqm, 36.1% of the entire certificated reserve, and expires in November 2042 [2]. Four parcels registered to CBDK itself — 577,000, 472,282, 283,900 and 125,500 sqm in Kosambi Barat — expire on 21 August 2038, and with smaller parcels bring the 2038 cohort to 155.4 ha [1].

Source: derived from the certificate schedules in the IPO prospectus [1] [2].

Two clocks of similar length

The inventory book releases slowly. CBDK charged $48.2 million of real-estate cost against revenue in FY2025 [9] against inventories of $838.7 million at 31 March 2026 [10]. At that rate the book takes about 17 years to clear, and about 15 years at the three-year average release rate — the arithmetic worked through in Land at Cost. Counting from mid-2026, that lands between 2041 and 2043.

The title clock runs to a similar length. By the end of 2042, the building rights over 57.9% of the certificated area will have reached their stated expiry. The two clocks are not the same event, and the difference matters: an expiry is a renewal obligation, not a loss of the asset.

Indonesian building rights are granted for a fixed term and are extendable and renewable, and a developer's normal course is to split the master certificate and issue individual title to each buyer well before the parent right matures. The clearest statement of that in this corpus comes from a peer with the same regime and the same regency. ASRI discloses in its own accounts that its land is held under HGB with terms of 20 to 30 years maturing between 2026 and 2043, and adds that management sees no obstacle to extension because all the land was lawfully acquired and is supported by adequate proof of ownership [11].

That is the strongest fact against reading the expiry profile as a risk, and it is a strong one. What is missing is CBDK's own version of it. The audited statements for FY2021, FY2022 and FY2023 do not mention building rights at all; from FY2024 onward the inventory note gives an area and nothing else. In no period of the record does it state the term of those rights, the years in which they mature, whether extension has been applied for, or what extension costs. The note gives area and encumbrance status and stops [6]. No provision, accrual or contingent liability for title extension appears anywhere in the accounts, and no figure in this corpus sizes what extending 460 hectares of building rights would cost. That is a disclosure gap rather than evidence of a problem, and it is the reason the expiry profile above had to be built from a prospectus rather than read from a note.

The risk register does not mention land

The prospectus sets out eighteen risk factors across four categories and closes with management's declaration that all risks material to the company have been disclosed and ranked by weight [12]. The list runs from weakening purchasing power and competition through interest rates, raw-material availability, changing consumer preference, corporate actions, human resources, marketing capability, regulatory compliance and technology [13] [14]. None of the eighteen concerns land rights, title expiry, land acquisition or the security of the certificates. The nearest are a generic risk of failing to meet industry regulations and permits, and a generic risk of legal claims [14] [15].

Two Tangerang peers treat it differently. ASRI names disputes over land ownership rights as a legal risk that can delay development and add cost [16]. Lippo Karawaci sets out the permit stack its projects depend on — location permits and KKPR, building permits, certificates of occupancy and environmental approvals — as a named business-continuity risk [17].

The environmental approval belongs to an affiliate

The prospectus is explicit about where CBDK's environmental permission comes from. Its projects proceed by reference to the environmental approval, AMDAL and traffic-impact analysis (Andalalin) held in the name of PT KML, relying on the exemption in Article 10(1)(f) of Government Regulation 22/2021 for activities inside an area already covered by an area-level AMDAL and area-level environmental approval. Because it operates under KML's area approval, CBDK itself was required only to file a statement of capability to manage and monitor the environment, obtained through the OSS system on 18 September 2024 [18].

PT KML is the same commonly controlled party that owns the 187,740 sqm site under the NICE convention centre and leases it to IPN for twenty years at a rent that varies with IPN's own profit or loss, at a stated transaction value of $97.3 million [19]. Its role in the permit chain is broader than that lease and had not surfaced in the transaction analysis in Ownership and Affiliates or the venue economics in MICE and Hotel Economics: the area-level environmental consent that allows CBD PIK2 to be built sits with an entity CBDK neither controls nor consolidates, and no fee, term or termination condition for that arrangement is disclosed anywhere in the corpus. Project-level permits do sit with CBDK — the Islamic Financial Center, for instance, holds its own environmental permit, building permit and a certificate of fitness for occupancy valid to 18 March 2029 [20] — but the umbrella consent above them does not.

The location permit is the one part of the chain the prospectus treats as settled. CBDK's izin lokasi, granted by the Regent of Tangerang in 2014, covered acquisition of 399,405 sqm out of a total 1,400,000 sqm, of which 1,090,946 sqm had already been released; the prospectus records that under ATR/BPN Regulation 13/2021 no extension application is required because the company has already obtained all the land it needs for its business [20].

The litigation record

Nothing in the corpus contradicts a clean legal position. At the prospectus date the company and its subsidiaries were not party to any civil, criminal, competition, arbitration, tax, labour, bankruptcy or suspension-of-payment proceeding, and no member of either board had been involved in one [21]. The FY2025 annual report repeats it for the year then ended [22]. Set beside the encumbrance column — 267 certificates, none pledged — and the note that no inventory was used as collateral at either year end [6], the land is unlitigated and unmortgaged. For a reader whose first test is whether a claim can be forced against the asset, that combination is the substantive answer, and it is consistent with the solvency position set out in Backlog Run-Off.

Two flaws in the schedules

The certificate tables are typed records and they carry typographical errors, which is worth stating before anyone reads a single row as a finding. Certificate SHGB No. 318/Tanjung Pasir, 20,785 sqm registered to CGIC, is printed with an expiry date of 26 January 2015 — ten years before the prospectus was published — while the certificate immediately below it, issued on the same day in 1981, expires in 2053 [3]. The largest certificate in the group, SHGB No. 00225, is printed as expiring 31/11/2042, a date that does not exist [2]. The row-level areas also sum 0.1% above the schedules' own entity totals. These are transcription defects of the same order as the reversed segment percentages and the corrected land-area figure already on the record; they argue for reading the expiry profile as a shape rather than as a date-accurate register.

The larger limitation is age. The schedules describe the position at the prospectus date in December 2024. Nothing in the eighteen months since — two quarterly filings, one annual report, four presentations — restates the certificate position, updates the expiry dates, or discloses the title status of the 3,341,874 sqm of undeveloped land [6].

What would change the read

The evidence supports a plain conclusion: the asset underneath CBDK is legally held, unpledged and unlitigated, and it belongs to the listed company's shareholders to the extent of 83%, not 100%. The expiry profile is a cost and administrative obligation concentrated in 2038 and 2042 rather than a threat to ownership, and the peer record suggests extension is routine — but CBDK has never said so in its own accounts, and no number in this corpus prices it.

Three things would move that read, and each is checkable in a specific filing.

A note in the half-year or FY2026 accounts stating the term and maturity of the group's building rights, in the form ASRI already uses, would convert the expiry profile from a derived estimate into a disclosed schedule. Its absence for a second full annual cycle would mean the only parcel-level record of an $838.7 million asset remains a document published at the IPO.

Any extension or renewal charge appearing in the cash-flow statement, in prepaid taxes, or as a new provision would be the first quantification of what the 2038 and 2042 cohorts cost. Prepaid taxes have already been the line where land-related outflows accumulate.

A restated certificate schedule, or an appraisal of the undeveloped 3,341,874 sqm naming its title status, would close the gap that has forced every valuation in this report to work from historic cost. The KML environmental arrangement is the related item to watch: any disclosure of a fee, term or termination right attaching to the area-level AMDAL would size a dependency currently carried at nil.