The two-layer test

The first layer is immigration. The coded E23 page currently displays no detailed public data. A separate official employment visa FAQ lists options of up to 180 days, one year or two years, but shows no visa code. It must not be mapped automatically to E23. The exact work category may be E23, E25 or another current code. The FAQ allows activities related to the approved employment and warns against work that does not match the stay permission.

The second layer is employment law. Government Regulation 34/2021 (PP 34/2021) and Minister of Manpower Regulation 8/2021 (Permenaker 8/2021) govern authorized employers using foreign workers in Indonesia within the statutory categories. The Ministry's register still marks both instruments as in force on 13 July 2026.

That is why calling the temporary stay permit, commonly known as KITAS, "the work permit" creates risk. The temporary stay permit (ITAS) describes immigration status. The approved employment facts also matter.

The employer's foreign-worker plan (RPTKA)

The plan for using a foreign worker (RPTKA) identifies the position and period approved for an employer. Under Minister of Manpower Regulation 8/2021, an employer using a foreign worker generally needs an approved RPTKA unless a defined exception applies.

The application records information such as:

  • the authorized employer using the foreign worker in Indonesia;
  • the position and duration;
  • the work location;
  • the identity of the foreign worker;
  • the Indonesian counterpart responsible for knowledge transfer, where required.

The regulation says the foreign worker must have education aligned with the position, competence or at least five years of relevant experience, and must transfer expertise to an Indonesian counterpart, subject to the stated framework.

The safe sequence

The official sources are not perfectly aligned on sequence. The eVisa FAQ asks for a commitment to provide a Ministry of Manpower Notification within 90 days after arrival. Permenaker 8/2021 describes RPTKA approval as the recommendation used for the work visa and stay permit process.

The safe conclusion is not "arrive and regularize later". It is:

  1. Define the real employer, role, work location and term.
  2. Confirm whether RPTKA approval or a defined exception applies.
  3. Complete the Manpower and Immigration sequence required by the exact category.
  4. Begin work only when the permissions required for that activity are effective.

Where the public pages conflict, the employer should confirm the current portal sequence before the employee travels or starts work.

Duration and cost are not one number

The employment FAQ currently displays immigration options and official charges for up to 180 days, one year and two years. These immigration charges are not the whole employer cost.

Minister of Manpower Regulation 8/2021 also provides for the compensation fund for the use of foreign workers (DKPTKA), generally USD 100 per position, worker and month, paid by the employer, with defined institutional exemptions. It is a regulatory payment, not an agency fee.

LayerWhat it controlsWhat to verify
Immigration visaEntry for the employment purposeCorrect category and use-by date
Temporary stay permit (ITAS) and re-entry permissionStay and re-entryValidity matching the assignment
Foreign-worker plan approval (RPTKA)Employer's use of the workerPosition, term, location and worker
Employment contractActual duties and compensationConsistency with approved role
Foreign-worker compensation fund (DKPTKA)Regulatory paymentAmount, period and any valid exemption

Which positions are open or restricted

Indonesia does not operate a simple rule that every non-HR job is open to a foreign national. The Ministry maintains a sectoral list of positions that may be occupied by foreign workers in Minister of Manpower Decision 228/2019 (Kepmenaker 228/2019), still marked in force when the sources were checked.

It also maintains a list of 18 prohibited positions in Minister of Manpower Decision 349/2019 (Kepmenaker 349/2019). The prohibited list is concentrated in human resources, recruitment, industrial relations, job analysis, personnel development and certain work-safety functions.

The official list contains these titles: Personnel Director; Industrial Relations Manager; Human Resources Manager; Personnel Development Supervisor; Personnel Recruitment Supervisor; Personnel Placement Supervisor; Employee Career Development Supervisor; Personnel Declare Administrator; Personnel and Careers Specialist; Personnel Specialist; Career Advisor; Job Advisor; Job Advisor and Counseling; Employee Mediator; Job Training Administrator; Job Interviewer; Job Analyst; and Occupational Safety Specialist.

Photographer is not on that national prohibited list. It is also absent from the standard sectoral list in Kepmenaker 228/2019, but the same instrument provides a route for the competent authority to approve an unlisted position when the employer requires it. Absence from the standard list is therefore not proof of an absolute ban. Commercial filming may also involve a C14 or D14 filming category and separate permits. The safe conclusion is that the exact role, sector, employer, RPTKA route and filming authorization must be checked. The common claim that a foreign production-company owner may manage local photographers but can never hold a camera is not supported by these two national position lists.

A job title invented for a visa file is not a solution. Authorities can compare the approved title with the duties performed.

What changes in a villa business

Activities need to be mapped honestly. Strategic oversight, board decisions, daily property management, guest reception, sales, maintenance supervision and staff management are not interchangeable labels.

A foreign founder who spends every day directing staff, checking guests in and selling services should not assume that share ownership or an investor stay status automatically covers those activities. The correct route depends on the corporate position, shareholding, actual work and any applicable Manpower exception.

Common high-risk shortcuts

  • Entering on a visit visa and beginning work because the employer says the file is "in process".
  • Holding an ITAS but working for another entity, in another role or at another location without checking the approval.
  • Using an investor title for duties that are really a local operational job.
  • Treating an agency receipt as proof that government approval exists.
  • Referring only to the former foreign-worker permit (IMTA) or old C312 visa code without asking which current category and approval appear in the file.

What this changes for a property project

For an investor-operated villa, document the boundary between shareholder governance, development oversight and daily hospitality work before choosing a status. The operating model should be designed with Indonesian employment and management capacity, not retrofitted after opening.

Scope: This is general information, not legal, immigration, tax or employment advice. Check the official page for your passport and activity before paying or travelling.

Government sources

Source dates: page updated on . Next source check planned for .

Related decisions

Visa and residence deskIndonesia visas and work permits in 2026: the practical Bali guideArrival deskBali electronic visa on arrival: All Indonesia and autogatesInvestor statusIndonesia investor visa E28A: permitted activities and work limits
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This is not an employment-permit service.

If the work question sits inside a villa development or operating mandate, we can map the operating roles the project needs and identify where independent immigration and employment advice must be obtained.

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