3rd Edition: Key Implications of MOMR No. 11 of 2026 on Labor Inspection for Employers

Labor Inspection serves as means for Labor Inspectors to ensure that the implementation of labor norms (norma ketenagakerjaan) at a company or workplace remains in compliance with applicable requirements. Labor Inspection has three main functions, which includes:                                                                                                  

• ensuring the enforcement of labor laws and regulations;
• providing guidance to employers, management, and workers on matters necessary to ensure the effective implementation of labor norms; and
• collecting information on employment relationships and labor conditions, in the broadest sense, as a basis for establishing or improving labor standards.

Following our comparison of the changes to the labor inspection framework under Minister of Manpower Regulation No. 11 of 2026 on Labor Inspection Procedures (“MOMR 11/2026”) with the framework discussed in the 1^st edition of this advisory and our recommendation on the practical steps companies should take to prepare for the updated labor inspection system discussed in the 2^nd edition of this advisory, this advisory focuses on the implications of the changes of labor inspection system for companies as employers.

1. Labor Inspection through Self-Assessment Results on SIAPKerja Website

Under the MOMR 11/2026, the MOM introduced a new inspection mechanism through the SIAPKerja website, particularly the Norma100 platform.

Norma100 serves as a tool for registered companies to assess their level of compliance with applicable labor norms through a self-assessment system. This mechanism enables companies to independently evaluate their compliance, reducing their dependence on Labor Inspectors in ensuring compliance with applicable labor norms.

The implementation of the self-assessment mechanism also supports the inspection function of Labor Inspectors. Through this mechanism, Labor Inspectors may verify a company’s compliance with labor norms without necessarily conducting an on-site inspection. Furthermore, this inspection mechanism allows Labor Inspectors to identify potential compliance issues at an early stage.

Under the self-assessment mechanism, companies are required to complete the questionnaires provided through the platform to assess their compliance with applicable labor norms. The results of the self-assessment will subsequently be verified by Labor Inspectors, and the verification results will be reported to the Head of the relevant Labor Inspection Work Unit.

A. What Should be Submitted?

Before completing the questionnaire, the employer should prepare the following:

• Email addresses of the employer’s representative and employee representative, both of which must be registered under separate SIAPKerja accounts. The employer’s representative and employee representative cannot use the same email address;
• The company’s WLKP Registration Code Number; and
• A photograph or scanned copy of the employee representative’s identification document.

After the above requirements have been submitted, both the employer’s representative and employee representative will be required to complete the questions provided in the self-assessment questionnaire.

B. When should the Company Conduct the Self-Assessment?

The self-assessment should be conducted in accordance with the type of labor inspection applicable to the company. As explained in the 2nd Edition, there are 4 (four) types of labor inspections, namely: (i) initial inspection; (ii) periodic inspection; (iii) special inspection; and (iv) re-inspection, each of which serves a different purpose. The self-assessment through the Norma100 platform is primarily conducted in connection with initial and periodic inspections.

In addition, the employer may only access the Norma100 platform once within a 1 (one)-year period. Once access is granted, the employer will have a maximum of 3 (three) calendar days to complete and submit the self-assessment form.

C. Who is Authorized to Complete the Self-Assessment Form?

The self-assessment form must be completed by two parties namely (i) an employer representative; and (ii) an employee representative. The completion of the self-assessment form must first be initiated by the employer representative. The eligible representatives are as follows:

• Employer Representative: the head of the company or a person appointed by the head of the company (typically, an HR personnel); and
• Employee Representative: a representative from a Labor Union, the Occupational Safety and Health Committee (“P2K3”), a Labor Standards Cadre (Kader Norma Ketenagakerjaan), or another employee representative.

The self-assessment form must be completed using two separate accounts, respectively registered under the employer representative and the employee representative.

d. Verification Mechanism by the Labor Inspector

The verification process by the Labor Inspector will begin with the Norma100 administrator arranging a verification schedule with the company. The verification will then be conducted virtually and attended by the employer representative, employee representative, relevant staff, and the Labor Inspector.

The verification will take the form of a virtual interview conducted by the Labor Inspector with both the employer representative and employee representative. During the verification process, the Labor Inspector will also review the following employment-related documents:

• Company Regulation or Collective Labor Agreement (as applicable);
• Payroll records;
• A list of Occupational Safety and Health (“OSH”) personnel and equipment;
• Overtime Work Orders (Surat Perintah Lembur – “SPL”), where applicable;
• Proof of payment of BPJS Employment contributions;
• Occupational Safety and Health Committee (“P2K3”) documentation (P2K3 Management Structure and its most recent report);
• Occupational Safety and Health Management System (“SMK3”) certificate; and
• Any other employment-related documents required to be submitted under the relevant form.

The overall verification process is aimed to evaluate the company’s compliance with each applicable labor norm, and assess and score the company’s level of compliance with the applicable labor norms.

E. What Output Will the Company Receive as a Result of the Self-Assessment?

Upon completion of the self-assessment and verification process, the company will receive 2 (two) documents, namely: (i) the Verification Results Report (Laporan Hasil Verifikasi – “LHV”); and (ii) the Norma100 Compliance Certificate (Sertifikat Kepatuhan Norma100).

The LHV is a summary report containing the results of the verification conducted by the Labor Inspector based on the answers and explanations provided by the employer representative and employee representative in the checklist.

The LHV will include the company’s labor compliance score, as determined based on the Labor Inspector’s verification. The company’s level of compliance with applicable labor norms is categorized into 3 (three) levels as follows:

• High Compliance Level (Green)               = score of 91 – 100
• Medium Compliance Level (Yellow)         = score of 71 – 90
• Low Compliance Level (Red)                  = score of ≤ 70

Where any non-compliance or discrepancies are identified, the LHV will also include recommendations for improvement in the form of notes from the Labor Inspector who conducted the verification. These recommendations are intended to assist the company in addressing the identified issues in accordance with the guidance provided by the Labor Inspector during the verification process.

Meanwhile, the Norma100 Compliance Certificate is a written document issued by the Ministry of Manpower as evidence of the verification process and an indication of the company’s labor conditions and compliance with applicable labor norms.

2. Expanded Authority of Labor Inspectors and Key Considerations for Companies

Compared to the previous regulation governing labor inspections, i.e., Minister of Manpower Regulation No. 33 of 2016 (“MOMR 33/2016”), MOMR 11/2026 expands the authority of Labor Inspectors. Under MOMR 33/2016, the authority of Labor Inspectors was generally limited to (i) entering a company or workplace where work was suspected to be carried out; and (ii) summoning employers or other relevant parties to obtain information regarding alleged violations of labor norms.

MOMR 11/2026 expands these authorities by granting 2 (two) additional authorities to the Labor Inspectors, namely:

• taking necessary measures; and/or
• taking other actions in accordance with the applicable laws and regulations.

With these additional authorities, Labor Inspectors may directly take or implement necessary measures during the various stages of a labor inspection, particularly where there are indications of violations of applicable labor norms. These measures include:

• sealing work equipment to prevent its operation;
• prohibiting or suspending work processes;
• suspending the process of placing workers;
• withdrawing child workers from the workplace;
• removing foreign nationals employed by an employer from a work location and/or workplace where their employment does not comply with the applicable laws and regulations; and/or
• prohibiting the employer from employing the relevant foreign national;

in which actions are required to be reported in the Minutes that will be signed by the employer’s representative, the Labor Inspector, and the Head of the Labor Inspection Work Unit.

The expanded authority of Labor Inspectors means that companies may face more direct and immediate measures in the event of violations or non-compliance with applicable labor norms. For example, as further discussed in the 2nd Edition of this Advisory, a company may be required to immediately cease employing a foreign worker if the Labor Inspector identifies non-compliance with the applicable requirements.

Accordingly, companies should exercise greater caution and pay closer attention to their compliance with prevailing labor norms in response to potentially longer and more detailed inspections. This includes both general labor norms, such as obligations to pay overtime wages, comply with minimum wage requirements, and provide employment accident and/or occupational disease benefits, as well as OSH norms, such as ensuring that equipment used at the workplace has the required certifications and is operated and used in accordance with the applicable requirements.

-----

Click the "download file" button to read the PDF version.

If you have any questions, please contact

1. Edward Jeremiah Maruli Sitorus, Associate - edward.sitorus@makarim.com
2. Hendrik Alfian Pasaribu, Senior Associate - hendrik.pasaribu@makarim.com
3. Reagan Roy Teguh, Partner - reagan.teguh@makarim.com
4. Rudy Andreas Sitorus, Partner - rudy.sitorus@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.}