MANPOWER INSPECTION

In June 2026, the Government of the Republic of Indonesia, through the Minister of Manpower of the Republic of Indonesia (“MOM”), issued the Regulation of the MOM No. 11 of 2026 regarding the Procedures for Manpower Inspection (“RM 11/2026”).

RM 11/2026 was promulgated and became effective on 3 July 2026. Simultaneously, it revoked the Regulation of the MOM No. 33 of 2016 regarding the Procedures for Manpower Inspection, as amended by Regulation of the MOM No. 1 of 2020.

RM 11/2026 aims to strengthen a transparent, accountable, and standardized manpower inspection system, while also reinforcing the role of manpower inspectors in enforcing manpower laws

Several important provisions stipulated under RM 11/2026 include the following:

1.      Expanded Authority of Manpower Inspectors

RM 11/2026 expands and clarifies the powers of manpower inspectors. In carrying out inspections, manpower inspectors may:

a. enter a company or workplace without being accompanied by the relevant employer or management;

b. request data, documents, evidence, and information relating to compliance with manpower regulations;

c. summon relevant parties to provide explanations; and

d. take necessary enforcement measures.

If a manpower inspector is denied access to a workplace, he/she may request assistance from the Indonesian National Police.

RM 11/2026 also expressly authorizes manpower inspectors to take certain measures, including:

i. sealing work equipment to prevent its operation;

ii. prohibiting or suspending work processes; and

iii. removing child workers from the workplace.

2.      Inspection Stages and Criminal Enforcement

RM 11/2026 provides that manpower inspection is conducted through 3 (three) stages:

a. preventive and educational measures (guidance);

b. non-judicial action (issuance of inspection notices and/or determination of manpower’s entitlements); and

c. repressive judicial action (enforcement of criminal sanctions).

However, manpower inspectors may proceed directly to criminal sanctions’ enforcement without first completing the preceding stages in cases involving:

i. serious occupational accidents resulting in death or permanent disability;

ii. unlawful employment of children; or

iii. other manpower violations involving criminal elements.

3.     New Compliance Self-Assessment through SIAPkerja

In performing various functions in the manpower sector, particularly the manpower inspection function, the Ministry of Manpower operates an information system known as the Manpower Services Information System and Application (Sistem Informasi dan Aplikasi Pelayanan Ketenagakerjaan – “SIAPkerja”).

All companies are required to complete an electronic compliance checklist through SIAPkerja. The self-assessment results will be verified by manpower inspectors and may be used as part of the manpower inspection process. However, it is important to note that, completion of the self-assessment does not prevent manpower inspectors from conducting manpower inspections directly at the company’s premises.

4.      Inspection Outputs

RM 11/2026 provides that manpower inspections may result in the following outcomes:

A.     Preventive and Educational Measures

Manpower inspectors may provide guidance, technical advice, supervision, or other compliance-related assistance to help companies meet manpower standards.

B.     Non-Judicial Enforcement Measures

Where non-compliance is identified, manpower inspectors may issue:

i. inspection notices, requiring the company to remedy violations; and/or

ii. determinations of manpower’s entitlements, specifying payments or other entitlements that must be fulfilled by the employer.

C.     Repressive Judicial Action

For certain violations, manpower inspectors may pursue criminal sanctions’ enforcement measures in accordance with applicable laws and regulations.

Conclusions and Takeaways

RM 11/2026 strengthens Indonesia’s manpower inspection regime by expanding the authority of manpower inspectors and introducing a new compliance self-assessment mechanism through SIAPkerja. RM 11/2026 also reinforces the manpower inspection framework by providing a clearer enforcement process and allowing manpower inspectors to proceed directly to criminal enforcement in certain cases, including serious occupational accidents, the unlawful employment of children, and other manpower violations involving criminal elements.

This Client Alert is provided for general informational purposes only and does not constitute legal advice. Please contact us should you require further information or assistance regarding manpower inspections or related matters.

LINK PDF: Client-Alert-regarding-Manpower-Inspection3.pdf