INDONESIA'S NEW REGULATION ON THE EMPLOYMENT OF FOREIGN MANPOWER: OFFERING SOME CLARITY WHILE RAISING QUESTIONS

The Indonesian Government has finally issued various implementing regulations of the Omnibus Law on Job Creation. Four implementing regulations have been issued on the employment sector: 1. Government Regulation No. 34 of 2021 on The Utilization of Foreign Manpower (“GR 34/2021”) 2. Government Regulation No. 35 of 2021 on Fixed Term Employment, Outsourcing, Working Hours and Rest Times and Termination (“GR 35/2021”) 3. Government Regulation No. 36 of 2021 on Wages (“GR 36/2021”) 4. Government Regulation No. 37 of 2021 on The Job Loss Security Program (“GR 37/2021”). In this series of advisories, we highlight the main features of these regulations.

Issue 9, February 2026 | Bank Indonesia’s new PJP framework introduces activity bundling, refined capital requirements, and transitional protections for existing providers. This Advisory outlines the key regulatory changes in the 2025 Regulations.

Issue 20, October 2025 | Amid rising demand for gold, Indonesia has introduced a new licensing regime for bullion banks, changing the way gold-related financial services are regulated and offered.

Key obligations for foreign ESOs once they are registered with the Minister of Communication and Informatics (MOCI) to comply with MOCI Regulation No. 5 of 2020 on ESOs in the Private Sector (as amended).