2nd Edition: Preparing for Indonesia’s New Labor Supervision Framework: A Company’s Guide

Issue 32, August 2026

Our previous edition highlighted the key changes introduced by Minister of Manpower Regulation No. 11 of 2026 on Procedures for Labor Inspection (“MOMR 11/2026”), which replaced the previous regulatory framework in 2020.

This 2^nd edition focuses on the practical steps companies should take to prepare for the updated labor inspection system, which more structured, documented, and time-sensitive, including the key information they should understand and the documents they should have readily available, as outlined below:

Self-Assessment Through SIAPKerja

In relation to the development of the labor inspection system, companies now have the option to conduct a website-based self-assessment through the SIAPkerja platform. The employer or management, together with employee representatives, must complete an electronic compliance checklist, which will then be verified by a labor inspector. However, the self-assessment does not replace or limit the labor inspector’s authority to conduct a formal inspection. The verification results must be documented and reported to the head of the relevant labor inspection unit. In light of this, companies should ensure that the information uploaded to SIAPkerja is consistent with their internal records and supporting documents.

Considerations for Companies with Foreign Workers

During the labor inspection, a labor inspector may remove a foreign worker from a work location or workplace if the foreign worker’s employment does not comply with the applicable laws and regulations. The labor inspector may also prohibit the employer from continuing to employ the foreign worker concerned. The removal must be documented in formal minutes. Consequently, the employer may be required to immediately cease employing the foreign worker if the labor inspector finds non-compliance, which may significantly impact the employer’s operations.

In this regard, companies should periodically review the approved Foreign Worker Utilization Plan (RPTKA) and other relevant manpower permits for their foreign employees and ensure that their positions, periods of employment, work locations, and other employment details remain accurate, valid, and consistent with the actual working arrangements.

Types of Inspections

Under MOMR 11/2026, formal inspections cover monitoring and surveillance, observation and assessment, requests for clarification, examination of employment documents, and verification of the company’s website-based self-assessment through SIAPkerja. During the inspection process, any required clarification will be conducted online or in person and must be documented in signed minutes. Inspectors conducting an inspection must act under an inspection order issued by the head of the relevant labor inspection unit.

Generally, inspections are conducted by provincial labor inspectors in the province where the relevant employee works. Special inspections and re-inspections may also be conducted by Ministry of Manpower inspectors.

There are four types of inspections recognized under MOMR 11/2026:

The inspection must be completed within a maximum of 60 working days, and the inspection report must be issued within 60 working days from the date of the inspection order. The specified timeline allows for a thorough inspection process, with the outcome expected within several months. Given the above, companies should be prepared for inspections that may extend over a longer period, which may require further coordination with labor inspectors and continued availability of employment records.

The outcome includes an inspection report followed by either a notification that no violation was found or an Inspection Note identifying the violation and ordering corrective action to be implemented by the employer or management. The implementation report and supporting evidence must be provided within the period stated in the Inspection Note.

In terms of compliance, the labor inspector will first issue Inspection Note I within seven working days after the inspection report is received by the head of the inspection unit. The reasonable period for compliance by the company may not exceed 30 working days after receipt. If the company fails to comply, Inspection Note II must be issued within three working days, and the company will be given a further reasonable period of up to 14 working days after receipt to comply. Continued non-compliance may result in a criminal investigation, a recommendation for administrative sanctions, or other lawful enforcement action.

In light of the above, it is recommended that:

1. Companies should establish clear internal procedures for managing labor inspections and responding to Inspection Notes.
2. Employers should appoint an authorized representative to coordinate with the labor inspector, manage all documents and statements provided during the inspection, retain copies of submitted materials and signed minutes, and promptly address and report compliance with any Inspection Note within the applicable deadline to avoid sanctions.
3. Companies should retain all inspection documents, including notification letters confirming compliance, as these may provide an important record of the inspection outcome and assist in demonstrating past compliance during future inspections or regulatory reviews.

Testing

Separate from an ordinary inspection, inspectors may conduct testing where an object requires calculation, analysis, measurement, or technical testing. Employment-norm testing may determine deficiencies in overtime pay, minimum wages, and occupational accident or occupational disease benefits. K3 testing may cover work equipment, materials, work methods, employees and the working environment, and may be conducted at the planning, installation, relocation, repair or use stage. It may be a first, periodic, special or repeat tests. If the object fails to meet K3 requirements, the relevant work process may be prohibited or stopped until compliance is established by a certificate confirming that the requirements have been met.

The general steps for testing labor standards are set out below.

Serious Violations

Under the current regime, certain serious violations, including fatal workplace accidents, unlawful employment of children, and other violations of labor standards containing criminal elements, may proceed directly to a criminal investigation, which will be carried out by an Employment Civil Servant Investigator. Given this, employers should review their occupational safety and child labor compliance frameworks to minimize the risk of serious violations that may now result in an immediate criminal investigation.

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If you have any questions, please contact

1. Fitria Marsha Qitara Rajasa, Associate - fitria.rajasa@makarim.com
2. Hendrik Alfian Pasaribu, Senior Associate - hendrik.pasaribu@makarim.com
3. Rudy Andreas Sitorus, Partner - rudy.sitorus@makarim.com
4. Reagan Roy Teguh, Partner - reagan.teguh@makarim.com

_{M&T Advisory is a digital publication prepared by the Indonesian law firm, Makarim & Taira S. It informs generally on the topics covered and should not be treated as legal advice or relied upon when making investment or business decisions. Should you have any questions on any matter contained in M&T Advisory, or other comments in general, please contact us at the emails provided at the end of this article.}