Yes. A genuine foreign director can actively manage and supervise the Indonesian company in which they hold the relevant corporate position and immigration or manpower basis.
No. The word Director on a deed does not authorise every job, every location or every connected company.
The practical answer depends on five things aligning:
Corporate appointment
+ shareholding
+ RPTKA approval or valid exemption
+ visa and ITAS
+ employer, work location and actual activity
The real question is not whether the foreigner is present every day.
It is:
Are they directing the company, or are they occupying another recurring operational job under a director title?
Boundary of this note
This note explains the distinction. It does not select a visa or manpower route for a particular person. The live deed, shareholding, manpower file, visa, ITAS, employer and actual work need to be reviewed together.
Two common but incomplete answers
The first is:
You are an investor. You cannot do anything inside the business.
That is too broad. Indonesian company law gives directors a real management function, and the immigration system has specific routes for company directors and qualifying investors.
The second is:
You are a director. You can do anything.
That is also too broad. Manpower and immigration rules still care about the position, employer, work locations and activity actually performed.
A useful answer needs to distinguish ownership, corporate authority and personal work authorisation.
Five roles that should not be confused
| Role | What it gives | What it does not give by itself |
|---|---|---|
| Shareholder | Economic and voting rights as an investor. | It does not automatically make the person a director or employee. |
| Beneficial owner | Recognition of ultimate control or economic benefit. | It does not create a corporate appointment or work permission. |
| Director | Corporate authority to manage and represent the company within its purpose and articles. | It does not authorise every occupation in every related company. |
| Commissioner | Supervision and advice to the board of directors. | It is not the same as executive management. |
| Employee or foreign worker | A role performed under the relevant employer and manpower structure. | It must still match the permitted position, visa, ITAS and location. |
A person can hold more than one of these roles. The file should show which one supports each activity.
What a genuine director can do
A real director is not confined to signing one resolution each quarter.
Recognisable director activity can include:
- approving the business plan and budget;
- setting pricing and commercial strategy;
- appointing and directing senior managers;
- reviewing occupancy, revenue and operating performance;
- approving major procurement and supplier appointments;
- negotiating material contracts;
- setting controls and policies;
- inspecting property and service standards;
- deciding how the company responds to a serious incident;
- supervising delivery of the company's goods or services;
- representing the company with banks, partners and authorities within the corporate mandate.
Daily involvement is not automatically a problem. A founder-led business can have an active director.
The question is whether the recurring work still looks like direction and supervision.
Where another job begins
Consider the continuum:
The boundary is fact-sensitive. Indonesian rules do not provide a simple number of hours that turns management into another job.
The strongest clues are repetition, responsibility and how the business would describe the role if the person were not the owner.
Example A: recognisable director activity
The director arrives at the property twice a week.
They review the GM's performance, approve a new pricing policy, inspect service standards, negotiate a laundry contract, review a serious guest complaint and decide whether to replace the operations manager.
That is readily intelligible as direction and supervision.
Example B: a different recurring occupation
The “director” works the reception desk every day, answers all booking messages, performs check-in and check-out, sells transport, prepares staff rosters, drives guests and personally runs the villa-manager shift.
The issue is not that a director may never greet a guest or solve an urgent problem.
The issue is that the recurring occupation now looks like another job.
A director title does not automatically cover that job if the manpower and immigration file does not.
E25B and E28A answer different questions
The current immigration list includes:
- E25B, a work-visa category for a company director;
- E28A, an investor category that can allow a qualifying investor to undertake business and investment activities, serve as director or commissioner in the company in which they invested, and supervise production of its goods or services.
These labels are not interchangeable.
The appropriate route depends on:
- the person's shareholding;
- the deed appointment;
- the manpower position;
- whether an RPTKA approval or exemption applies;
- the intended work;
- the employer and locations.
“Investor KITAS” is not a complete legal analysis.
KITAS is not the work description
KITAS remains common everyday language. The formal stay permit is ITAS.
More importantly, a stay permit does not describe every activity the person may perform.
A coherent file should align:
A mismatch at one layer can matter even when the other documents exist.
The employer matters
This point becomes critical in the PT PMA and local PT structure.
Assume:
- the foreign founder is director and shareholder of PT PMA A;
- PT local B appears on the OTA;
- B contracts with guests and receives the money;
- B holds the accommodation-operating role;
- A invoices B for management services.
The founder personally gives daily instructions to B's team, controls B's reservations and prices, approves B's refunds and acts as B's villa manager.
The director appointment in A does not automatically authorise work for B.
The companies are separate legal persons.
The management agreement can explain why A provides a service to B. It does not automatically transfer the foreign individual's personal work authority from A to B.
The right questions are:
- Is the foreign director genuinely directing A's management service?
- Does A employ the people and operate the systems through which the service is delivered?
- Is the individual actually acting as B's manager or employee in practice?
- Which company benefits from the daily work?
- Which employer and locations appear in the manpower and immigration file?
A concrete two-company example
Coherent version
PT PMA A employs a revenue manager, finance manager and operations director.
The foreign director supervises that team, approves A's management policies, reviews property performance and attends a monthly operating meeting with B's Indonesian directors.
PT local B employs the villa staff, controls the guest contract, pays the team, handles check-in and carries the customer obligation. B's Indonesian GM gives daily instructions on site.
The foreign director may inspect and challenge performance, but the people, systems and authority show that A provides a management service and B operates the accommodation.
Contradictory version
A has no management team.
The foreign director personally logs into B's OTA, sets every price, answers guests, gives instructions to housekeepers, approves leave, handles refunds and disciplines B's staff.
The only evidence of A's service is an invoice.
In that version, the personal activity may look less like directing A and more like working inside B.
Multiple-company roles need their own basis
Indonesian rules contemplate some situations where a foreign worker can work for more than one employer in the same position, including certain director or commissioner arrangements.
That is not a general permission to work across a group.
Each role needs support from:
- the corporate appointment;
- the relevant employer relationship;
- the manpower framework;
- the visa and ITAS;
- the recorded work locations;
- the actual function.
Common ownership or a management contract does not merge two employers into one.
Commissioner is not another word for director
A commissioner supervises and advises the directors.
A director manages the company.
A foreign person appointed only as commissioner should not assume that the title authorises ordinary executive management.
The same substance test applies. What does the person actually do, for which company, and under which authority?
HR remains a restricted area
Foreign workers do not have an unrestricted right to occupy personnel or human-resources positions.
A director can approve an organisation design, appoint senior leaders and set policy.
That is different from functioning as the company's recurring HR officer, administering employee files or occupying another restricted personnel role.
The title on the email signature does not change the function.
What an inspector can see on site
A paper file matters. So do operating facts.
An inspector can ask:
- who gives instructions to the team;
- whose WhatsApp account runs the staff group;
- who approves rosters and leave;
- who controls the OTA and PMS;
- who handles guest complaints;
- which company employs the person;
- where the person works;
- what position appears in the file;
- whether the stated investment and corporate role have substance.
A deed is weak protection when the daily business shows another occupation.
A practical activity matrix
| Activity | Usually recognisable as director-level | Requires closer review | Often looks like another recurring job |
|---|---|---|---|
| Approve annual budget | Yes | ||
| Set pricing policy | Yes | ||
| Direct the GM | Yes | ||
| Inspect standards | Yes | When it becomes daily line supervision | |
| Negotiate major contract | Yes | ||
| Resolve exceptional guest incident | Yes | If this becomes the ordinary service role | |
| Answer reservation messages daily | Yes | ||
| Perform check-in and check-out as routine | Yes | ||
| Build staff rosters every week | Depends on authorised executive scope | Often | |
| Drive guests | Yes | ||
| Sell tours at the property | Yes | ||
| Perform recurring HR administration | Restricted area requiring specific caution |
This is not a statutory whitelist. It is a practical way to identify when a director title may be covering another job.
What a foreign owner should verify in writing
- What exact position appears in the deed?
- Is the person shareholder, director, commissioner or more than one?
- What share value and percentage are personally registered?
- What is the legal basis for any RPTKA exemption?
- Which visa index is held?
- What activities does that route expressly support?
- What ITAS has been issued?
- Which company appears as employer or sponsor?
- What position is approved where RPTKA applies?
- Which work locations are recorded?
- Is the person active in a second company?
- What corporate appointment supports that second role?
- What manpower and immigration basis supports it?
- Which recurring operational tasks are performed?
- Which company benefits from those tasks?
- Who signs instructions to the staff?
- Who controls the systems used each day?
- Do the company KBLI and the individual's function fit together?
- What reporting and DKPTKA obligations apply?
- What would an inspector see during an ordinary week?
The decision in plain language
A foreign director can work actively inside their own Indonesian business when the corporate, manpower and immigration structure supports the role.
The director can set strategy, supervise management, inspect standards, make material decisions and respond to serious operating issues.
The title does not authorise every line-level job or automatically extend to a separate local PT.
The rule to keep is:
The deed, visa, manpower basis, employer, locations and ordinary week should all describe the same job.
Sources and direct verification links
- Law 40/2007 on Limited Liability Companies
- Immigration: E25B company-director work visa
- Immigration: E28A investor visa
- PP 34/2021 on the use of foreign workers
- Permenaker 8/2021 implementing PP 34/2021
- Immigration Bali: 2026 Dharma Dewata patrol and accommodation-provider duties
- Law 25/2007 on Investment
- Official OSS KBLI 55901, accommodation-management services
The live visa, ITAS, RPTKA or exemption file, employer, position and work location control a real individual's answer. A company deed or familiar word “KITAS” is not enough by itself.