Regulation Watch · Business Licensing · Indonesia, including Bali
Labour Inspections Now Have Digital Checks, Claim Deadlines and Provincial K3 Certificates
Permenaker 11/2026 introduced digital checks and fixed inspection-response limits; Permenaker 15/2026 now adds 120-day timelines for wage and workplace-injury benefit determinations, 14-working-day employer compliance and redetermination periods, and a time-bound provincial route for company-requested K3 certificates.
- Published
- Permenaker 11/2026 was established on 29 June 2026 and promulgated on 3 July 2026. Its amendment, Permenaker 15/2026, was established on 8 October 2026 and promulgated on 12 October 2026 in State Bulletin 2026 No. 681.
- Effective
- Permenaker 11/2026 took effect on 3 July 2026. Permenaker 15/2026 took effect on 12 October 2026, its date of promulgation.
- Updated
- 13 October 2026
Who is affected
All employers and workplaces, including PT PMA companies, foreign directors and management, businesses employing expatriates, developers, contractors, hotels, villas, restaurants, clinics, factories, labour-placement businesses, HR teams, and occupational safety and health personnel.
Practical impact
Labour inspections may be initial, periodic, special, or repeat and may run for up to 60 working days. Inspectors can use monitoring or surveillance, observation, document examination, online or offline clarification, and verification of company self-inspection through SIAPkerja. Permenaker 15/2026 routes inspections and labour-standard testing through the provincial inspectorate where the worker works and requires provincial inspectors to determine deficiencies in overtime pay, minimum wages and workplace-accident or occupational-disease benefits within 120 days. An employer must implement a provincial determination within 14 working days after receipt. A worker, employer or company manager that contests it has 14 working days after receipt to request a Ministry redetermination through the provincial office; the resulting redetermination must also be implemented within 14 working days. Companies may also request provincial K3 certificates through a short verification, cure and issue process.
Late discovery: Permenaker 11/2026 was issued on 29 June, promulgated on 3 July, and became effective on promulgation. It replaces Permenaker 33/2016 and its 2020 amendment. It remains actionable because the procedures now govern every new labour inspection and impose short, evidence-backed response periods once an inspector identifies a violation.
The regulation formalises a broader inspection toolkit. Inspectors may monitor or conduct surveillance, observe work, examine documents, seek clarification online or offline, and verify the company's self-inspection in SIAPkerja. Special inspections need not wait for a routine cycle: they may be triggered by a public complaint or report, media coverage, or an order from inspection leadership.
If an inspection finds a violation, Note I must identify the legal basis, required correction, possible sanction, and a reasonable completion period of no more than 30 working days from receipt. The company must both carry out the correction and report it with supporting evidence. If Note I is not satisfied, Note II must be issued within three working days and gives no more than 14 working days from receipt before the matter can escalate to investigation, an administrative-sanction recommendation, or other lawful action.
The operational exposure is especially serious for expatriate employment and K3. Inspectors may remove a foreign worker from a work location that does not comply with the law and prohibit the employer from employing that person there. A K3 object or process that fails the applicable safety requirements can be prohibited or stopped and may resume only after the company complies and obtains the required certificate. There is no one-time filing date, so businesses should treat document accuracy and inspection-response readiness as continuing obligations.
Material amendment — 12 October 2026: Permenaker 15/2026 extends the provincial 120-day determination track to overtime, minimum-wage and workplace-accident or occupational-disease benefit deficiencies. The determination must be sent within five working days after issuance. Employers must implement a provincial determination within 14 working days after receipt; a worker, employer or company manager has the same 14-working-day period to request a Ministry redetermination through the provincial office, and the employer must implement the resulting redetermination within 14 working days.
Permenaker 15/2026 also adds Article 46A, allowing a company to request a provincial K3 certificate based on a compliant test report. The inspector has three working days to verify the filing. An incomplete application must be returned within two working days and cured within three working days after receipt; a complete application must be issued within two working days after verification. If the initial verification is not performed on time, the application is deemed verified and the certificate must be issued. Updated official forms include provincial determinations, Ministry redeterminations and a dedicated workplace-accident or occupational-disease benefit redetermination.
Required action
- Run an inspection-readiness review covering WLKP and SIAPkerja data, employment contracts, company regulations or collective agreements, payroll, minimum wage, overtime, BPJS, outsourcing, expatriate employment and RPTKA compliance, and occupational safety and health requirements.
- Reconcile corporate, workforce, and workplace data held in SIAPkerja and other labour-administration records, then keep the underlying documents ready for electronic or in-person examination.
- Appoint an inspection-response team that can receive notices, coordinate corrective work, preserve evidence, and report completion to the inspector before the stated deadline.
- Calendar an Inspection Note I immediately on receipt: its correction period may be shorter but cannot exceed 30 working days. If Note II is issued, its correction period cannot exceed 14 working days from receipt.
- Log every written request for data or information and answer accurately within the stated period. Under the procedure, each request may allow no more than five working days and may be issued up to three times; after a third non-response, inspectors may determine the worker-rights deficiency from the evidence available.
- Escalate a provincial determination on the day it is received. Calendar the 14-working-day employer implementation deadline and, if the company disputes the result, the separate 14-working-day period to submit a reasoned redetermination request through the provincial office with complete evidence.
- For a company-requested provincial K3 certificate, attach the prescribed test report, monitor the three-working-day verification period, cure an incomplete filing within three working days after return and retain proof of every submission and receipt.
- Do not use or operate a K3 object or process that has been prohibited or stopped after failing the applicable safety requirements until compliance is evidenced by the required K3 certificate.