• Insights

Immigration Compliance Lookouts for Indonesia

April 21, 2015

Country / Territory

  • IndonesiaIndonesia

Related contacts

Porthole Headshot Image Fragomen [Singapore][Partner][KennethLau]

Kenneth Lau

Partner

Singapore, Singapore

Email

[email protected]

T:+65 6854 5168

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Porthole Headshot Image Fragomen [Singapore][Partner][KennethLau]

Kenneth Lau

Partner

Singapore, Singapore

Email

[email protected]

T:+65 6854 5168

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Porthole Headshot Image Fragomen [Singapore][Partner][KennethLau]

Kenneth Lau

Partner

Singapore, Singapore

Email

[email protected]

T:+65 6854 5168

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

By: Kenneth Lau

When sending expatriates to work in Indonesia, it is important that companies take a very compliance-minded approach to the immigration system. The process of obtaining a work permit in Indonesia, for example, will be coursed through multiple government agencies, including the Ministry of Manpower & Transmigration (MOMT) and the Directorate General of Immigration (DGI). It is crucial that companies comply with the rules of all government touch-points along the way. The below highlights several common areas of concern, pertaining to immigration and work permit compliance.
 
Business travelers
 
As they do in many countries in the region, business visits can occupy a gray area under Indonesian immigration law. Generally, under the Indonesian immigration regulations, visitor visas are granted to foreign nationals traveling to Indonesia for government duties, educational visits, social visits, cultural visits, tourism, business visits, family visits, journalistic activities, or transit to other countries. In practice, business travelers should take care that their activities (and the frequency and duration of such visits) do not give the appearance that they are working in the country.
 
While there are different modes of entry for business visitors (including Visa-Free entry, the Visa-on-Arrival and the Consulate-issued Visit Visa), such visitors should take care to understand the requirements for each as well as the conditions. For example, while there is a seven-day visa-on-arrival for certain special economic zones, these should really only be used for tourism purposes or to participate in conferences, seminars or events sponsored by international organizations or by the Indonesian government.
 
The specific activities that can be performed will depend on the status under which the traveler enters. Generally speaking, the following business activities should be permissible:
 
  • Attending business meetings, business negotiations, and the like;
  • Holding business discussions, such as for the sale and purchase of goods and services;
  • Participating in seminars or international exhibitions;
  • Attending a conference held by the company’s head office or representative office in Indonesia; or
  • Exploring opportunities in business development, investment, or sales.
 
If a business trip (even a brief one) will involve activities other than those outlined above, a work permit would likely be required.
 
Job titles for expatriates
 
The work permit process for expatriates can be confusing and difficult to navigate for employers. One aspect that has made it more complicated is choosing the appropriate job title for the expatriate to hold in Indonesia. As a rule, the proposed job title should match up with the expatriate’s job description and industry.
 
The MOMT has a listing of job titles by industry that can be held by expatriates. Some industries, such as Trading, Service, or Consulting, are more heavily restricted than others. If a proposed job title is not on the listing, then this may pose a risk of rejection by the MOMT for that particular job title.
 
Additionally, under a new MOMT announcement, the maximum validity period for work permit applications submitted by companies in the Service, Trading, and Consulting industries would be six months for Advisor positions, with no renewals allowed. The rationale here is that, for such positions, a local Indonesian worker can be trained to take over the position within that period of time (so that it is unnecessary for an expatriate to hold that position in the long term).
 
Under this backdrop, companies are encouraged to work closely with their immigration provider to ascertain the likelihood of rejection of an application for a particular job title as well as any other lookouts.
 
Sponsoring entities
 
Often, companies will be looking to send their employees to work in Indonesia without having their own corporate setup in place. This poses additional challenges to the work permit process as there must be a legal entity in place that is eligible to sponsor.
 
Under such a scenario, it is important that the company identify an appropriate work permit sponsor in Indonesia. There must be a bona fide connection between the work permit sponsor in Indonesia and the sending company in such a case. For instance, it would not be appropriate for a third party to sponsor the application if that third party has no corporate ties to the sending company (i.e., subsidiary) or any other agreement (such as a service agreement or contract) with the sending company. The activities carried out by the expatriate in Indonesia should generally be in line with the objectives and purposes of their Indonesian sponsoring entity.
 
With that in mind, it may be possible, for instance, for a customer in Indonesia to sponsor the expatriate (if their entity meets the eligibility criteria) as there should be an agreement in place between the sending company and the customer in Indonesia. The customer should be aware, however, of its obligations as the sponsor.
 
The bottom line for companies wishing to send their employees on assignment into Indonesia is that they must ensure that an appropriate sponsoring entity is in place.
 
Co-laborer requirement
 
One of the most important requirements of the initial application of the work permit process (the RPTKA – Rencana Penggunaan Tenaga Kerja Asing – or Foreign Manpower Utilization Plan) is that the Indonesian sponsoring company must provide details of the appointment of local Indonesian workers as counterparts (co-laborers) of the expatriates. The rationale of this rule is that the expatriate should be training their co-laborer to eventually take over the role when they end their assignment.
 
The MOMT is strictly enforcing a 1:1 ratio (at least) for the co-laborer requirement. In practice, the co-laborer should hold a role similar to that of the expatriate (or at least overlap in nature). The co-laborer should be in the same business function as the expatriate and either equal or one position below the expatriate in the company’s hierarchy. The MOMT officer has discretion to determine what qualifications of the co-laborer are sufficient for the position.
 
The co-laborer rule is designed to ensure that Indonesian companies are staffing up with local Indonesians (in fact, the MOMT will often look beyond just the 1:1 ratio for co-laborers and review the total headcount of the company as a factor as well when making their decisions). It is therefore important for companies wishing to sponsor expatriates to ensure that they also have sufficient numbers of local employees.

Country / Territory

  • IndonesiaIndonesia

Related contacts

Porthole Headshot Image Fragomen [Singapore][Partner][KennethLau]

Kenneth Lau

Partner

Singapore, Singapore

Email

[email protected]

T:+65 6854 5168

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Porthole Headshot Image Fragomen [Singapore][Partner][KennethLau]

Kenneth Lau

Partner

Singapore, Singapore

Email

[email protected]

T:+65 6854 5168

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Porthole Headshot Image Fragomen [Singapore][Partner][KennethLau]

Kenneth Lau

Partner

Singapore, Singapore

Email

[email protected]

T:+65 6854 5168

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Explore more at Fragomen

Blog post

Polish Citizenship by Descent: Finding Family Records and Navigating Polish Archives

Poland Immigration Strategy Director Tomasz Rogala and Senior Associate Tomasz Rdzanek explain how applicants pursuing Polish citizenship by descent can locate family records, navigate archives and obtain documentary evidence that can be used in citizenship proceedings.

Learn more
Generic Insights

Fragomen news

2026年10月 米国移民法ダイジェストLearn more

Awards

Fragomen Recognized in 2027 Best Law Firms® Rankings in the United States

Fragomen has been recognized in the 2027 edition of Best Law Firms®, earning a National Tier 1 ranking in Immigration Law and 16 regional rankings across the United States.

Learn more

Media mentions

Global Underwater Hub: The Specialist Skills Needed to Deliver Future Offshore Projects

Director Kelly Hardman explores how early UK immigration planning and investment in domestic skills can help offshore businesses access the specialist expertise needed to deliver future projects.

Learn more

Media mentions

SHRM: Why ‘Hush Trips’ Can Pose Big Risks for Employers and Workers

Senior Counsel Jo Antoons explains the immigration, social security, insurance, employment law and tax risks that undisclosed international remote work can create for employers.

Learn more

Media mentions

Times of India: Immigration After the Midterms: A New Congress, but Who Holds the Power?

Senior Counsel Mitch Wexler discusses the potential impact of the US midterm elections on immigration policy and the areas where bipartisan support could shape future developments.

Learn more

Blog post

UK Earned Settlement: When Immigration Status Becomes an Incentive for Growth and Compliance

In a new blog, UK Government Affairs Strategy Director Shuyeb Muquit examines what the framework could mean for employers, including potential impacts on sponsorship costs, retention planning, employee communications and support for internationally mobile workers and their families.

Learn more

Blog post

What the 2026 Midterm Election Results Mean for U.S. Business Immigration and Employers

In a new blog, Partner K. Edward Raleigh examines what the election results could mean for employers and where businesses should focus now, from immigration compliance and workforce planning to state response procedures and preparation for increased scrutiny.

Learn more

Media mentions

The PIE: UK to Increase HPI Visa Cap and Expand Eligibility to 150 Universities

Manager Russell Hodges discusses how the HPI visa expansion could help UK employers attract global talent.

Learn more

Fragomen news

Fragomen Expands Asia Pacific Presence with New Vietnam Offices

Fragomen has opened new offices in Hanoi and Ho Chi Minh City, expanding its presence and immigration capabilities across Asia Pacific.

Learn more

Media mentions

Human Resources Director: Global Mobility Risk Can No Longer Be an HR Afterthought

Partner Jack Kim discusses how organizations can take a more strategic approach to global mobility through actionable intelligence, proactive workforce planning and preparation for geopolitical disruptions.

Learn more

Blog post

UK Budget 2026: What the Government’s Immigration Plans Mean for Employers

In a new blog, UK Government Affairs Strategy Director Shuyeb Muquit examines what this direction could mean for employers, including why access to international talent may increasingly be considered alongside investment, productivity, innovation, regional growth and long-term workforce development.

Learn more

Blog post

Polish Citizenship by Descent: Finding Family Records and Navigating Polish Archives

Poland Immigration Strategy Director Tomasz Rogala and Senior Associate Tomasz Rdzanek explain how applicants pursuing Polish citizenship by descent can locate family records, navigate archives and obtain documentary evidence that can be used in citizenship proceedings.

Learn more
Generic Insights

Fragomen news

2026年10月 米国移民法ダイジェストLearn more

Awards

Fragomen Recognized in 2027 Best Law Firms® Rankings in the United States

Fragomen has been recognized in the 2027 edition of Best Law Firms®, earning a National Tier 1 ranking in Immigration Law and 16 regional rankings across the United States.

Learn more

Media mentions

Global Underwater Hub: The Specialist Skills Needed to Deliver Future Offshore Projects

Director Kelly Hardman explores how early UK immigration planning and investment in domestic skills can help offshore businesses access the specialist expertise needed to deliver future projects.

Learn more

Media mentions

SHRM: Why ‘Hush Trips’ Can Pose Big Risks for Employers and Workers

Senior Counsel Jo Antoons explains the immigration, social security, insurance, employment law and tax risks that undisclosed international remote work can create for employers.

Learn more

Media mentions

Times of India: Immigration After the Midterms: A New Congress, but Who Holds the Power?

Senior Counsel Mitch Wexler discusses the potential impact of the US midterm elections on immigration policy and the areas where bipartisan support could shape future developments.

Learn more

Blog post

UK Earned Settlement: When Immigration Status Becomes an Incentive for Growth and Compliance

In a new blog, UK Government Affairs Strategy Director Shuyeb Muquit examines what the framework could mean for employers, including potential impacts on sponsorship costs, retention planning, employee communications and support for internationally mobile workers and their families.

Learn more

Blog post

What the 2026 Midterm Election Results Mean for U.S. Business Immigration and Employers

In a new blog, Partner K. Edward Raleigh examines what the election results could mean for employers and where businesses should focus now, from immigration compliance and workforce planning to state response procedures and preparation for increased scrutiny.

Learn more

Media mentions

The PIE: UK to Increase HPI Visa Cap and Expand Eligibility to 150 Universities

Manager Russell Hodges discusses how the HPI visa expansion could help UK employers attract global talent.

Learn more

Fragomen news

Fragomen Expands Asia Pacific Presence with New Vietnam Offices

Fragomen has opened new offices in Hanoi and Ho Chi Minh City, expanding its presence and immigration capabilities across Asia Pacific.

Learn more

Media mentions

Human Resources Director: Global Mobility Risk Can No Longer Be an HR Afterthought

Partner Jack Kim discusses how organizations can take a more strategic approach to global mobility through actionable intelligence, proactive workforce planning and preparation for geopolitical disruptions.

Learn more

Blog post

UK Budget 2026: What the Government’s Immigration Plans Mean for Employers

In a new blog, UK Government Affairs Strategy Director Shuyeb Muquit examines what this direction could mean for employers, including why access to international talent may increasingly be considered alongside investment, productivity, innovation, regional growth and long-term workforce development.

Learn more
Fragomen.com home
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
Search Fragomen.com
  • Our Services
    For EmployersFor IndividualsBy IndustryCase Studies
  • Our Tech & Innovation
  • Our People
  • Our Insights
    Worldwide Immigration Trends ReportsMagellan SeriesImmigration AlertsEventsMedia MentionsFragomen NewsBlogsPodcasts & Videos
  • Spotlights
    Travel and Mobility Considerations: Situation in the Middle EastNavigating Immigration Under the Second Trump AdministrationImmigration Matters: Your U.S. Compliance RoadmapCenter for Strategy and Applied InsightsView More
  • About Us
    About FragomenOfficesResponsible Business PracticesFirm GovernanceRecognition

Our Services

  • For Employers
  • For Individuals
  • By Industry
  • Case Studies

Our Tech & Innovation

  • Our Approach

Our People

  • Overview / Directory

Our Insights

  • Worldwide Immigration Trends Reports
  • Magellan Series
  • Immigration Alerts
  • Events
  • Media Mentions
  • Fragomen News
  • Blogs
  • Podcasts & Videos

Spotlights

  • Travel and Mobility Considerations: Situation in the Middle East
  • Navigating Immigration Under the Second Trump Administration
  • Immigration Matters: Your U.S. Compliance Roadmap
  • Center for Strategy and Applied Insights
  • View More

About Us

  • About Fragomen
  • Offices
  • Responsible Business Practices
  • Firm Governance
  • Recognition
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
Important Updates
Important Updates
November 6, 2026 | Saudi ArabiaSaudi Arabia: Temporary Regularization Initiative for Certain Yemeni Nationals
November 6, 2026 | CanadaCanada: 2027–2029 Immigration Levels Plan Maintains Overall Targets and Adds Permanent Residence Spaces
November 6, 2026 | CanadaCanada: Longer Employment Duration and Expanded Access Under Temporary Foreign Worker Program Low-Wage Stream
November 6, 2026 | IrelandIreland: Employment Permits Portal Offline Following Unauthorized Activity
November 6, 2026 | Saudi ArabiaSaudi Arabia: Pre-Travel Registration Now Possible for Land Border Arrivals, with Process to Become Mandatory in 2027
November 6, 2026 | Saudi ArabiaSaudi Arabia: Temporary Regularization Initiative for Certain Yemeni Nationals
November 6, 2026 | CanadaCanada: 2027–2029 Immigration Levels Plan Maintains Overall Targets and Adds Permanent Residence Spaces
November 6, 2026 | CanadaCanada: Longer Employment Duration and Expanded Access Under Temporary Foreign Worker Program Low-Wage Stream
November 6, 2026 | IrelandIreland: Employment Permits Portal Offline Following Unauthorized Activity
November 6, 2026 | Saudi ArabiaSaudi Arabia: Pre-Travel Registration Now Possible for Land Border Arrivals, with Process to Become Mandatory in 2027
November 6, 2026 | Saudi ArabiaSaudi Arabia: Temporary Regularization Initiative for Certain Yemeni Nationals
Subscribe

Stay in touch

Subscribe to receive our latest immigration alerts

Subscribe

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • AI Transparency Statement
  • UK Regulatory Requirements

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • AI Transparency Statement
  • UK Regulatory Requirements

Have a question?

Contact Us
  • LinkedIn
  • Youtube
  • Instagram
  • Facebook
  • TikTok
  • Twitter

© 2026 Fragomen, Del Rey, Bernsen & Loewy, LLP, Fragomen Global LLP and affiliates. All Rights Reserved.

Please note that the content made available on this site is not intended for visitors / customers located in the province of Quebec, and the information provided is not applicable to the Quebec market. To access relevant information that applies to the Quebec market, please click here.