Regulation Watch · Business Licensing · The investigation concerns Yogyakarta and Gunungkidul, but the investor-ITAS rules and compliance lesson apply throughout Indonesia, including Bali.
Immigration Cross-Checks Investor ITAS Against Actual Activity
An official immigration enforcement bulletin shows that officers are comparing an investor ITAS holder's recorded role, actual activity, and the real presence of the sponsoring company rather than relying on the permit alone.
- Published
- Official Immigration Yogyakarta enforcement bulletin published on 11 September 2026; no new legal instrument was promulgated.
- Effective
- Not applicable. The bulletin documents current enforcement of existing immigration rules.
- Updated
- 12 September 2026
Who is affected
Foreign shareholders and directors holding an investor ITAS, PT PMA sponsor companies, directors and commissioners, company representatives, virtual-office users, employers, and advisers responsible for immigration, corporate, OSS, and manpower compliance.
Practical impact
Immigration Yogyakarta began with a system-based administrative review of a PT sponsor, followed by field checks of the foreign national's activity and the sponsor's Jakarta address. Officers found that the investor-ITAS holder's actual farming activity did not match the recorded immigration purpose and that the sponsor company could not be identified at its registered address. The official E28A guidance permits investment-related activity, service as a director or commissioner of the company in which the foreign national invests, and oversight of that company's production, but it prohibits work outside the stay permit's scope. An investor ITAS is therefore not a general work authorisation.
This is an enforcement development, not a new regulation. Immigration Yogyakarta published the bulletin on 11 September 2026 after an administrative review on 28 July, a field check on 31 July, and checks of the sponsoring company's Jakarta address from 26 to 28 August. It is material because it shows the evidence officers may compare when testing an investor ITAS against the facts.
The foreign national was recorded as an investor and president director of the sponsoring PT but told officers that he had stopped working for that company and had operated a poultry activity since 2023. Officers also reported that the sponsor could not be identified at its registered address and that the previous virtual-office provider had moved. Immigration concluded that the factual activity did not match the purpose of the investor ITAS and continued its review.
The official E28A guidance is specific. A holder may invest, conduct investment-related business activity, act as a director or commissioner of the company in which the holder invests, and supervise that company's production. The same guidance prohibits work inconsistent with the stay permit. It also requires at least Rp10 billion in shares in the sponsoring company and directs a director or commissioner below that threshold to the work-visa route for the position.
PT PMA sponsors should treat the registered address and the foreign investor's real activity as active compliance data. A valid-looking ITAS does not cure a dormant sponsor, an obsolete address, a role that exists only on paper, an activity outside the sponsor's licensed business, or a missing manpower route. The safest control is a coordinated review of immigration, AHU, OSS, tax, LKPM, address, shareholding, and daily operating evidence before renewal or inspection.
Required action
- Match the foreign national's daily activity to the exact E28A scope, the sponsor company, the company's licensed KBLI activities, the deed position, and any required manpower approval.
- Confirm that the sponsor company is active and identifiable at its registered address, with current AHU, OSS, tax, lease or virtual-office, signage, contact, and operating records.
- Verify the E28A shareholding threshold. Immigration's current guidance requires at least Rp10 billion in shares in the sponsoring company; a director or commissioner below that threshold must use the work-visa route appropriate to the position.
- Keep evidence of genuine investment and company activity, including the deed and AHU profile, shareholding, company bank statements, OSS licences, LKPM, tax filings, payroll or manpower records where applicable, and records showing what the foreign national actually does.
- If the activity, role, sponsor, address, or permit category no longer matches reality, stop the incompatible activity and correct the corporate, licensing, manpower, and immigration position before the next renewal or field inspection.