Indonesia Labour Inspection Rules Under Permenaker 11/2026 and Its 2026 Amendment
What Changed Under Permenaker 11/2026 and Permenaker 15/2026?
Permenaker No. 11 of 2026 introduced a new procedural framework for labour inspections in Indonesia. It took effect on 3 July 2026 and replaced Permenaker No. 33 of 2016, as amended by Permenaker No. 1 of 2020.
The framework was subsequently amended by Permenaker No. 15 of 2026, effective from 12 October 2026. Employers should therefore read Permenaker 11/2026 together with this amendment.
The framework organises labour supervision into three stages:
The October amendment adjusts specific procedures concerning the determination of unpaid worker entitlements, reconsideration of those determinations and the issuance of certain occupational safety and health documents. It also expressly sets a 14-working-day deadline for employers to comply with the payment determination under Article 33.
For employers, preparation should cover both workplace practices and supporting records. Payroll, overtime, social security and other employment documents may become evidence during an inspection or a formal assessment of amounts owed to workers.
The framework was subsequently amended by Permenaker No. 15 of 2026, effective from 12 October 2026. Employers should therefore read Permenaker 11/2026 together with this amendment.
The framework organises labour supervision into three stages:
- preventive and educational measures;
- non-judicial enforcement action; and
- judicial enforcement where an alleged labour offence requires formal investigation.
The October amendment adjusts specific procedures concerning the determination of unpaid worker entitlements, reconsideration of those determinations and the issuance of certain occupational safety and health documents. It also expressly sets a 14-working-day deadline for employers to comply with the payment determination under Article 33.
For employers, preparation should cover both workplace practices and supporting records. Payroll, overtime, social security and other employment documents may become evidence during an inspection or a formal assessment of amounts owed to workers.
October 2026 Update: Payment Determinations and Review Procedures
Permenaker 15/2026 amends the procedures for determining unpaid worker entitlements and reviewing those determinations. The relevant entitlements include overtime pay, minimum-wage shortfalls and work-accident or occupational-disease benefits.
Under amended Article 31(11), the maximum 120-day period for provincial inspectors to determine unpaid entitlements now covers all categories listed in Article 31(2), including the specified social security benefits.
Article 33 expressly requires employers to comply with a payment determination within 14 working days of receiving the inspector’s decision. This deadline is separate from the corrective-action periods stated in Nota Pemeriksaan I and II.
A worker or employer disputing the determination may request reconsideration by the Director General through the head of the provincial manpower office. The request must include reasons and be submitted within 14 working days of receipt. Ministry labour inspectors conduct the reassessment. An employer must implement the resulting redetermination within 14 working days of receiving it.
Employers should record receipt dates, retain payroll and payment evidence, and promptly seek advice when disputing a calculation.
Under amended Article 31(11), the maximum 120-day period for provincial inspectors to determine unpaid entitlements now covers all categories listed in Article 31(2), including the specified social security benefits.
Article 33 expressly requires employers to comply with a payment determination within 14 working days of receiving the inspector’s decision. This deadline is separate from the corrective-action periods stated in Nota Pemeriksaan I and II.
A worker or employer disputing the determination may request reconsideration by the Director General through the head of the provincial manpower office. The request must include reasons and be submitted within 14 working days of receipt. Ministry labour inspectors conduct the reassessment. An employer must implement the resulting redetermination within 14 working days of receiving it.
Employers should record receipt dates, retain payroll and payment evidence, and promptly seek advice when disputing a calculation.
When Can a Labour Inspection Take Place?
Permenaker 11/2026 recognises four types of labour inspection: initial, periodic, special and repeat inspections.
Under Article 17(2), as amended by Permenaker 15/2026, inspections are conducted by provincial labour inspectors in the territory where the workers work. Article 18 also allows Ministry labour inspectors to conduct special and repeat inspections.
An initial inspection may be conducted when a company begins physical operations or obtains its licence, resumes operations, changes its registered office or business location, or transfers ownership.
Periodic inspections may generally take place no sooner than three years after the previous inspection, although different rules may apply to certain occupational health and safety matters.
A special inspection may be initiated following:
- a complaint or report;
- media coverage; or
- an instruction from the head of the relevant labour inspection unit.
A repeat inspection takes place before an inspection notice or a notification that no violation was found is issued. Article 24 links this procedure to doubts held by the head of the labour supervision unit about the earlier findings and a case review concluding that another inspection is necessary.
Employers should therefore not assume that an inspection will occur only according to a predictable schedule. A worker complaint, reported workplace incident, public information or significant change in the company’s operations may lead to additional scrutiny.
The inspection must be based on a formal assignment order. Depending on the type of review, inspectors may observe workplace activities, request information or clarification, examine employment documents and verify the company’s online self-inspection results through SIAPkerja.
Under Article 17(2), as amended by Permenaker 15/2026, inspections are conducted by provincial labour inspectors in the territory where the workers work. Article 18 also allows Ministry labour inspectors to conduct special and repeat inspections.
An initial inspection may be conducted when a company begins physical operations or obtains its licence, resumes operations, changes its registered office or business location, or transfers ownership.
Periodic inspections may generally take place no sooner than three years after the previous inspection, although different rules may apply to certain occupational health and safety matters.
A special inspection may be initiated following:
- a complaint or report;
- media coverage; or
- an instruction from the head of the relevant labour inspection unit.
A repeat inspection takes place before an inspection notice or a notification that no violation was found is issued. Article 24 links this procedure to doubts held by the head of the labour supervision unit about the earlier findings and a case review concluding that another inspection is necessary.
Employers should therefore not assume that an inspection will occur only according to a predictable schedule. A worker complaint, reported workplace incident, public information or significant change in the company’s operations may lead to additional scrutiny.
The inspection must be based on a formal assignment order. Depending on the type of review, inspectors may observe workplace activities, request information or clarification, examine employment documents and verify the company’s online self-inspection results through SIAPkerja.
What Can Labour Inspectors Review?
During an inspection, labour inspectors may examine whether the company complies with applicable employment and occupational health and safety requirements.
Depending on the purpose and scope of the inspection, the review may include:
- employment agreements and company regulations;
- employee records and mandatory workforce reporting;
- wages, overtime, working hours and rest periods;
- social security registration and contributions;
- leave and employee benefit records;
- termination and compensation documents;
- foreign-worker permits and supporting records;
- occupational health and safety procedures; and
- evidence relating to a complaint or suspected violation.
Inspectors may request data or supporting evidence and obtain statements from company representatives, workers or other relevant persons. The regulation provides standard forms for recording statements and the transfer of requested documents or evidence.
Before providing information, the company should verify the inspector’s identity, review the formal assignment order and designate an authorised representative to coordinate the inspection. Documents should be complete, consistent and provided in an organised manner.
Employers should cooperate with a lawful inspection, but they should also keep a record of the documents submitted, explanations provided and any follow-up requested by the inspector. Where the subject is legally or technically complex, the company should obtain professional advice before making formal written representations.
Depending on the purpose and scope of the inspection, the review may include:
- employment agreements and company regulations;
- employee records and mandatory workforce reporting;
- wages, overtime, working hours and rest periods;
- social security registration and contributions;
- leave and employee benefit records;
- termination and compensation documents;
- foreign-worker permits and supporting records;
- occupational health and safety procedures; and
- evidence relating to a complaint or suspected violation.
Inspectors may request data or supporting evidence and obtain statements from company representatives, workers or other relevant persons. The regulation provides standard forms for recording statements and the transfer of requested documents or evidence.
Before providing information, the company should verify the inspector’s identity, review the formal assignment order and designate an authorised representative to coordinate the inspection. Documents should be complete, consistent and provided in an organised manner.
Employers should cooperate with a lawful inspection, but they should also keep a record of the documents submitted, explanations provided and any follow-up requested by the inspector. Where the subject is legally or technically complex, the company should obtain professional advice before making formal written representations.
What Happens After a Labour Inspection?
After completing an inspection, the labour inspector prepares a report recording the company details, findings, legal analysis, conclusions and recommended follow-up.
If no violation is identified, the company must receive a written notification. If the inspector identifies non-compliance, the company receives Nota Pemeriksaan I — a formal written order describing the findings, applicable legal provisions, required corrective action and compliance deadline.
The employer or company representative must carry out the required corrections and report their completion with supporting evidence. The deadline stated in Nota Pemeriksaan I must be reasonable and may not exceed 30 working days from receipt.
If the company does not comply within that period, the inspector may issue Nota Pemeriksaan II within three working days. This second notice acts as a final warning and may provide up to 14 working days for compliance.
If Nota Pemeriksaan II is still not implemented, the matter may be escalated through:
- an investigation by an authorised labour civil servant investigator;
- a recommendation for administrative sanctions; and/or
- other measures permitted by applicable legislation.
For certain serious alleged violations, judicial enforcement may begin without completing the preventive and non-judicial stages first. Examples include specified fatal or permanently disabling workplace accidents, unlawful child labour and other suspected labour offences involving criminal elements.
Employers should therefore treat every inspection notice as a formal compliance document. Corrective action should be completed within the stated period, supported by clear evidence and reported to the competent labour inspection authority.
These inspection-notice deadlines should not be confused with the deadline for implementing a formal determination of unpaid worker entitlements. Under Article 33, as amended by Permenaker 15/2026, an employer must implement that determination within 14 working days of receiving the inspector’s decision. The company should identify which document it has received, record the receipt date and confirm the applicable procedure and deadline.
If no violation is identified, the company must receive a written notification. If the inspector identifies non-compliance, the company receives Nota Pemeriksaan I — a formal written order describing the findings, applicable legal provisions, required corrective action and compliance deadline.
The employer or company representative must carry out the required corrections and report their completion with supporting evidence. The deadline stated in Nota Pemeriksaan I must be reasonable and may not exceed 30 working days from receipt.
If the company does not comply within that period, the inspector may issue Nota Pemeriksaan II within three working days. This second notice acts as a final warning and may provide up to 14 working days for compliance.
If Nota Pemeriksaan II is still not implemented, the matter may be escalated through:
- an investigation by an authorised labour civil servant investigator;
- a recommendation for administrative sanctions; and/or
- other measures permitted by applicable legislation.
For certain serious alleged violations, judicial enforcement may begin without completing the preventive and non-judicial stages first. Examples include specified fatal or permanently disabling workplace accidents, unlawful child labour and other suspected labour offences involving criminal elements.
Employers should therefore treat every inspection notice as a formal compliance document. Corrective action should be completed within the stated period, supported by clear evidence and reported to the competent labour inspection authority.
These inspection-notice deadlines should not be confused with the deadline for implementing a formal determination of unpaid worker entitlements. Under Article 33, as amended by Permenaker 15/2026, an employer must implement that determination within 14 working days of receiving the inspector’s decision. The company should identify which document it has received, record the receipt date and confirm the applicable procedure and deadline.
How Should Employers Prepare for a Labour Inspection?
Employers should not wait for a complaint or formal inspection notice before reviewing their labour compliance. A practical internal check should cover both employment documentation and actual workplace practices.
Before an inspection, the company should:
- verify that employment agreements, company regulations and internal policies are current and consistent;
- review wages, overtime, working hours, leave and employee benefit records;
- confirm BPJS registration and contribution records;
- check mandatory workforce reporting and any required foreign-worker documentation;
- review occupational health and safety procedures, training records and incident documentation;
- ensure that the company’s information and self-inspection data in SIAPkerja are accurate where applicable;
- designate an authorised representative to communicate with inspectors; and
- organise records so that requested documents can be provided without unnecessary delay.
The company should also identify discrepancies between written policies and actual workplace practices. An employment agreement may appear compliant, for example, while payroll records, overtime arrangements or day-to-day procedures show a different position.
If potential non-compliance is identified, the company should document the issue, determine the corrective action required and retain evidence that the correction has been implemented. Material issues involving wages, termination, foreign workers, workplace accidents or occupational safety should be reviewed with qualified Indonesian employment or legal professionals.
A documented internal compliance review can help the employer respond consistently, demonstrate cooperation and reduce the risk that an avoidable record-keeping issue develops into a formal enforcement matter.
Employers hiring foreign nationals should also review the announced TKA and OSS integration framework, including the consistency of company records, worker information and application procedures.
Before an inspection, the company should:
- verify that employment agreements, company regulations and internal policies are current and consistent;
- review wages, overtime, working hours, leave and employee benefit records;
- confirm BPJS registration and contribution records;
- check mandatory workforce reporting and any required foreign-worker documentation;
- review occupational health and safety procedures, training records and incident documentation;
- ensure that the company’s information and self-inspection data in SIAPkerja are accurate where applicable;
- designate an authorised representative to communicate with inspectors; and
- organise records so that requested documents can be provided without unnecessary delay.
The company should also identify discrepancies between written policies and actual workplace practices. An employment agreement may appear compliant, for example, while payroll records, overtime arrangements or day-to-day procedures show a different position.
If potential non-compliance is identified, the company should document the issue, determine the corrective action required and retain evidence that the correction has been implemented. Material issues involving wages, termination, foreign workers, workplace accidents or occupational safety should be reviewed with qualified Indonesian employment or legal professionals.
A documented internal compliance review can help the employer respond consistently, demonstrate cooperation and reduce the risk that an avoidable record-keeping issue develops into a formal enforcement matter.
Employers hiring foreign nationals should also review the announced TKA and OSS integration framework, including the consistency of company records, worker information and application procedures.
Frequently Asked Questions
Must an Employer Receive Advance Notice Before a Labour Inspection?
Not necessarily. The procedure depends on the type and circumstances of the inspection.
A labour inspection must be supported by a formal assignment order, but employers should not assume that every inspection will be announced substantially in advance. Special inspections may arise from a complaint, media report or instruction from the competent labour inspection authority.
When inspectors arrive, the company should verify their official identification and assignment order, identify the scope of the inspection and appoint an authorised representative to coordinate the company’s response.
A labour inspection must be supported by a formal assignment order, but employers should not assume that every inspection will be announced substantially in advance. Special inspections may arise from a complaint, media report or instruction from the competent labour inspection authority.
When inspectors arrive, the company should verify their official identification and assignment order, identify the scope of the inspection and appoint an authorised representative to coordinate the company’s response.
How Long Does an Employer Have to Correct a Violation?
The applicable deadline depends on the document the employer receives.
For Nota Pemeriksaan I, the corrective-action deadline must be reasonable and may not exceed 30 working days from receipt. If the employer does not comply, the inspector may issue Nota Pemeriksaan II within three working days, allowing up to 14 additional working days for compliance.
A formal determination of unpaid worker entitlements follows a separate rule. Under Article 33, as amended by Permenaker 15/2026, the employer must implement that determination within 14 working days of receiving the inspector’s decision.
Check the document type, record when it was received and organise the required response and supporting evidence around the applicable deadline.
For Nota Pemeriksaan I, the corrective-action deadline must be reasonable and may not exceed 30 working days from receipt. If the employer does not comply, the inspector may issue Nota Pemeriksaan II within three working days, allowing up to 14 additional working days for compliance.
A formal determination of unpaid worker entitlements follows a separate rule. Under Article 33, as amended by Permenaker 15/2026, the employer must implement that determination within 14 working days of receiving the inspector’s decision.
Check the document type, record when it was received and organise the required response and supporting evidence around the applicable deadline.
Can an Employer Challenge a Determination of Unpaid Worker Entitlements?
Yes. Under Article 34, as amended by Permenaker 15/2026, an employer or worker who disagrees with a provincial labour inspector’s determination may request a redetermination by the Director General through the head of the provincial manpower office.
The request must include reasons and be submitted within 14 working days of receiving the determination. It may be submitted directly or through an authorised representative supported by a power of attorney.
Ministry labour inspectors conduct the reassessment. Under amended Article 37(6), the employer must implement the resulting redetermination within 14 working days of receiving it.
Before submitting a request, organise the disputed calculations, payroll records, payment evidence and other supporting documents. Obtain advice on the applicable procedure and any obligations that remain while the request is being considered.
The request must include reasons and be submitted within 14 working days of receiving the determination. It may be submitted directly or through an authorised representative supported by a power of attorney.
Ministry labour inspectors conduct the reassessment. Under amended Article 37(6), the employer must implement the resulting redetermination within 14 working days of receiving it.
Before submitting a request, organise the disputed calculations, payroll records, payment evidence and other supporting documents. Obtain advice on the applicable procedure and any obligations that remain while the request is being considered.
Can a Labour Inspection Be Triggered by an Employee Complaint?
Yes. A complaint or report may provide the basis for a special labour inspection. A special inspection may also arise from media coverage or an instruction issued by the head of the competent labour inspection unit.
Employers should therefore maintain accurate employment records and an internal process for handling workplace complaints. Resolving concerns early and documenting the company’s response may help prevent unresolved employment issues from developing into formal disputes or enforcement matters.
Employers should therefore maintain accurate employment records and an internal process for handling workplace complaints. Resolving concerns early and documenting the company’s response may help prevent unresolved employment issues from developing into formal disputes or enforcement matters.
Can Labour Inspectors Request Company and Employee Documents?
Yes. Depending on the purpose and scope of the inspection, labour inspectors may request employment records, company information, supporting documents and explanations from company representatives, workers or other relevant persons.
The company should verify the inspector’s identification and formal assignment order before providing the requested information. It should also keep a clear record of every document submitted and designate an authorised representative to coordinate the response.
Documents should not be altered, concealed or created retrospectively. If a requested record is unavailable or requires clarification, the company should explain the position accurately and obtain professional advice where necessary.
The company should verify the inspector’s identification and formal assignment order before providing the requested information. It should also keep a clear record of every document submitted and designate an authorised representative to coordinate the response.
Documents should not be altered, concealed or created retrospectively. If a requested record is unavailable or requires clarification, the company should explain the position accurately and obtain professional advice where necessary.
What Role Does SIAPkerja Have in Labour Inspections?
Permenaker 11/2026 incorporates SIAPkerja into the labour supervision process. Inspectors may use the system to review and verify information submitted through the company’s online self-inspection process.
Employers should ensure that information entered in SIAPkerja is accurate, current and consistent with their employment records and actual workplace practices. An inconsistency between online information and supporting documents may require clarification during an inspection.
The exact reporting and self-inspection requirements applicable to a particular employer should be confirmed according to the company’s activities, workforce and location.
Employers should ensure that information entered in SIAPkerja is accurate, current and consistent with their employment records and actual workplace practices. An inconsistency between online information and supporting documents may require clarification during an inspection.
The exact reporting and self-inspection requirements applicable to a particular employer should be confirmed according to the company’s activities, workforce and location.
What Happens If an Employer Ignores an Inspection Notice?
Failure to comply with Nota Pemeriksaan I may result in the issue of Nota Pemeriksaan II as a final warning. If the company still fails to implement the required corrective action, the matter may be referred for investigation, a recommendation for administrative sanctions or other measures permitted by applicable legislation.
The consequences will depend on the nature of the violation and the legal provisions involved. For certain suspected offences, particularly those involving serious workplace accidents, unlawful child labour or other criminal elements, judicial enforcement may begin without completing every earlier supervisory stage.
An employer should therefore respond to each notice within the stated deadline, complete the required corrections and provide supporting evidence to the competent authority.
The consequences will depend on the nature of the violation and the legal provisions involved. For certain suspected offences, particularly those involving serious workplace accidents, unlawful child labour or other criminal elements, judicial enforcement may begin without completing every earlier supervisory stage.
An employer should therefore respond to each notice within the stated deadline, complete the required corrections and provide supporting evidence to the competent authority.
Should a Company Conduct an Internal Labour Compliance Review?
Yes. A periodic internal review can help the company identify inconsistencies before they become the subject of a complaint or formal inspection.
The review should compare written employment documents with actual practices relating to wages, overtime, working hours, leave, BPJS, foreign workers, workplace safety and termination procedures. It should also confirm that mandatory reports and online company information remain accurate.
Where material non-compliance is identified, the employer should obtain company-specific advice, implement the necessary corrections and retain evidence of the action taken.
The review should compare written employment documents with actual practices relating to wages, overtime, working hours, leave, BPJS, foreign workers, workplace safety and termination procedures. It should also confirm that mandatory reports and online company information remain accurate.
Where material non-compliance is identified, the employer should obtain company-specific advice, implement the necessary corrections and retain evidence of the action taken.
Related Insights
Labour inspections form part of the wider compliance framework for companies operating in Indonesia. PT and PT PMA employers should also ensure that their corporate reporting, tax representation and tax treatment remain consistent with current regulations.
Explore related insights:
Explore related insights:
Prepare Your Company for a Labour Inspection
Permenaker 11/2026, as amended by Permenaker 15/2026, provides the procedural framework for labour inspections and related determinations of worker entitlements. Effective preparation begins before an inspector arrives: employment records should be organised, payment calculations supported by evidence and responsibility for responding to official documents clearly assigned.
Business Consulting Bali can help companies review employment documentation, internal compliance records and operational practices, identify inconsistencies and coordinate the corrective steps that may require support from qualified Indonesian employment, tax or legal professionals.
If your company employs staff in Indonesia, a preventive compliance review can help management understand its current position and respond to a future inspection in an organised and well-documented manner.
Business Consulting Bali can help companies review employment documentation, internal compliance records and operational practices, identify inconsistencies and coordinate the corrective steps that may require support from qualified Indonesian employment, tax or legal professionals.
If your company employs staff in Indonesia, a preventive compliance review can help management understand its current position and respond to a future inspection in an organised and well-documented manner.
Professional Contract Drafting • Contract Review • Risk Prevention