New Labour Inspection Procedures in Indonesia Under Permenaker 11/2026
What Changed Under Permenaker 11/2026?
Permenaker No. 11 of 2026 introduces a new procedural framework for labour inspections in Indonesia. It took effect on 3 July 2026 and replaced Permenaker No. 33 of 2016, as amended by Permenaker No. 1 of 2020.
The regulation is intended to make labour supervision more transparent, accountable and standardised. It clarifies the authority of labour inspectors and organises supervision into three stages:
- preventive and educational measures;
- non-judicial enforcement action; and
- judicial enforcement where an alleged labour offence requires formal investigation.
Inspection activities may include guidance, workplace inspections, technical testing, investigations and the development of the labour supervision system.
For employers, the regulation does not merely concern an inspector’s visit to the workplace. It creates a structured compliance process through which employment practices, employee records, workplace conditions and compliance with labour legislation may be reviewed and followed by corrective or enforcement measures.
The regulation is intended to make labour supervision more transparent, accountable and standardised. It clarifies the authority of labour inspectors and organises supervision into three stages:
- preventive and educational measures;
- non-judicial enforcement action; and
- judicial enforcement where an alleged labour offence requires formal investigation.
Inspection activities may include guidance, workplace inspections, technical testing, investigations and the development of the labour supervision system.
For employers, the regulation does not merely concern an inspector’s visit to the workplace. It creates a structured compliance process through which employment practices, employee records, workplace conditions and compliance with labour legislation may be reviewed and followed by corrective or enforcement measures.
When Can a Labour Inspection Take Place?
Permenaker 11/2026 recognises four types of labour inspection: initial, periodic, special and repeat inspections.
An initial inspection may be conducted when a company begins physical operations or obtains its licence, resumes operations, changes its registered office or business location, or transfers ownership.
Periodic inspections may generally take place no sooner than three years after the previous inspection, although different rules may apply to certain occupational health and safety matters.
A special inspection may be initiated following:
- a complaint or report;
- media coverage; or
- an instruction from the head of the relevant labour inspection unit.
A repeat inspection may be ordered where the responsible authority has doubts about the earlier findings or where a case review concludes that another inspection is required.
Employers should therefore not assume that an inspection will occur only according to a predictable schedule. A worker complaint, reported workplace incident, public information or significant change in the company’s operations may lead to additional scrutiny.
The inspection must be based on a formal assignment order. Depending on the type of review, inspectors may observe workplace activities, request information or clarification, examine employment documents and verify the company’s online self-inspection results through SIAPkerja.
An initial inspection may be conducted when a company begins physical operations or obtains its licence, resumes operations, changes its registered office or business location, or transfers ownership.
Periodic inspections may generally take place no sooner than three years after the previous inspection, although different rules may apply to certain occupational health and safety matters.
A special inspection may be initiated following:
- a complaint or report;
- media coverage; or
- an instruction from the head of the relevant labour inspection unit.
A repeat inspection may be ordered where the responsible authority has doubts about the earlier findings or where a case review concludes that another inspection is required.
Employers should therefore not assume that an inspection will occur only according to a predictable schedule. A worker complaint, reported workplace incident, public information or significant change in the company’s operations may lead to additional scrutiny.
The inspection must be based on a formal assignment order. Depending on the type of review, inspectors may observe workplace activities, request information or clarification, examine employment documents and verify the company’s online self-inspection results through SIAPkerja.
What Can Labour Inspectors Review?
During an inspection, labour inspectors may examine whether the company complies with applicable employment and occupational health and safety requirements.
Depending on the purpose and scope of the inspection, the review may include:
- employment agreements and company regulations;
- employee records and mandatory workforce reporting;
- wages, overtime, working hours and rest periods;
- social security registration and contributions;
- leave and employee benefit records;
- termination and compensation documents;
- foreign-worker permits and supporting records;
- occupational health and safety procedures; and
- evidence relating to a complaint or suspected violation.
Inspectors may request data or supporting evidence and obtain statements from company representatives, workers or other relevant persons. The regulation provides standard forms for recording statements and the transfer of requested documents or evidence.
Before providing information, the company should verify the inspector’s identity, review the formal assignment order and designate an authorised representative to coordinate the inspection. Documents should be complete, consistent and provided in an organised manner.
Employers should cooperate with a lawful inspection, but they should also keep a record of the documents submitted, explanations provided and any follow-up requested by the inspector. Where the subject is legally or technically complex, the company should obtain professional advice before making formal written representations.
Depending on the purpose and scope of the inspection, the review may include:
- employment agreements and company regulations;
- employee records and mandatory workforce reporting;
- wages, overtime, working hours and rest periods;
- social security registration and contributions;
- leave and employee benefit records;
- termination and compensation documents;
- foreign-worker permits and supporting records;
- occupational health and safety procedures; and
- evidence relating to a complaint or suspected violation.
Inspectors may request data or supporting evidence and obtain statements from company representatives, workers or other relevant persons. The regulation provides standard forms for recording statements and the transfer of requested documents or evidence.
Before providing information, the company should verify the inspector’s identity, review the formal assignment order and designate an authorised representative to coordinate the inspection. Documents should be complete, consistent and provided in an organised manner.
Employers should cooperate with a lawful inspection, but they should also keep a record of the documents submitted, explanations provided and any follow-up requested by the inspector. Where the subject is legally or technically complex, the company should obtain professional advice before making formal written representations.
What Happens After a Labour Inspection?
After completing an inspection, the labour inspector prepares a report recording the company details, findings, legal analysis, conclusions and recommended follow-up.
If no violation is identified, the company must receive a written notification. If the inspector identifies non-compliance, the company receives Nota Pemeriksaan I — a formal written order describing the findings, applicable legal provisions, required corrective action and compliance deadline.
The employer or company representative must carry out the required corrections and report their completion with supporting evidence. The deadline stated in Nota Pemeriksaan I must be reasonable and may not exceed 30 working days from receipt.
If the company does not comply within that period, the inspector may issue Nota Pemeriksaan II within three working days. This second notice acts as a final warning and may provide up to 14 working days for compliance.
If Nota Pemeriksaan II is still not implemented, the matter may be escalated through:
- an investigation by an authorised labour civil servant investigator;
- a recommendation for administrative sanctions; and/or
- other measures permitted by applicable legislation.
For certain serious alleged violations, judicial enforcement may begin without completing the preventive and non-judicial stages first. Examples include specified fatal or permanently disabling workplace accidents, unlawful child labour and other suspected labour offences involving criminal elements.
Employers should therefore treat every inspection notice as a formal compliance document. Corrective action should be completed within the stated period, supported by clear evidence and reported to the competent labour inspection authority.
If no violation is identified, the company must receive a written notification. If the inspector identifies non-compliance, the company receives Nota Pemeriksaan I — a formal written order describing the findings, applicable legal provisions, required corrective action and compliance deadline.
The employer or company representative must carry out the required corrections and report their completion with supporting evidence. The deadline stated in Nota Pemeriksaan I must be reasonable and may not exceed 30 working days from receipt.
If the company does not comply within that period, the inspector may issue Nota Pemeriksaan II within three working days. This second notice acts as a final warning and may provide up to 14 working days for compliance.
If Nota Pemeriksaan II is still not implemented, the matter may be escalated through:
- an investigation by an authorised labour civil servant investigator;
- a recommendation for administrative sanctions; and/or
- other measures permitted by applicable legislation.
For certain serious alleged violations, judicial enforcement may begin without completing the preventive and non-judicial stages first. Examples include specified fatal or permanently disabling workplace accidents, unlawful child labour and other suspected labour offences involving criminal elements.
Employers should therefore treat every inspection notice as a formal compliance document. Corrective action should be completed within the stated period, supported by clear evidence and reported to the competent labour inspection authority.
How Should Employers Prepare for a Labour Inspection?
Employers should not wait for a complaint or formal inspection notice before reviewing their labour compliance. A practical internal check should cover both employment documentation and actual workplace practices.
Before an inspection, the company should:
- verify that employment agreements, company regulations and internal policies are current and consistent;
- review wages, overtime, working hours, leave and employee benefit records;
- confirm BPJS registration and contribution records;
- check mandatory workforce reporting and any required foreign-worker documentation;
- review occupational health and safety procedures, training records and incident documentation;
- ensure that the company’s information and self-inspection data in SIAPkerja are accurate where applicable;
- designate an authorised representative to communicate with inspectors; and
- organise records so that requested documents can be provided without unnecessary delay.
The company should also identify discrepancies between written policies and actual workplace practices. An employment agreement may appear compliant, for example, while payroll records, overtime arrangements or day-to-day procedures show a different position.
If potential non-compliance is identified, the company should document the issue, determine the corrective action required and retain evidence that the correction has been implemented. Material issues involving wages, termination, foreign workers, workplace accidents or occupational safety should be reviewed with qualified Indonesian employment or legal professionals.
A documented internal compliance review can help the employer respond consistently, demonstrate cooperation and reduce the risk that an avoidable record-keeping issue develops into a formal enforcement matter.
Before an inspection, the company should:
- verify that employment agreements, company regulations and internal policies are current and consistent;
- review wages, overtime, working hours, leave and employee benefit records;
- confirm BPJS registration and contribution records;
- check mandatory workforce reporting and any required foreign-worker documentation;
- review occupational health and safety procedures, training records and incident documentation;
- ensure that the company’s information and self-inspection data in SIAPkerja are accurate where applicable;
- designate an authorised representative to communicate with inspectors; and
- organise records so that requested documents can be provided without unnecessary delay.
The company should also identify discrepancies between written policies and actual workplace practices. An employment agreement may appear compliant, for example, while payroll records, overtime arrangements or day-to-day procedures show a different position.
If potential non-compliance is identified, the company should document the issue, determine the corrective action required and retain evidence that the correction has been implemented. Material issues involving wages, termination, foreign workers, workplace accidents or occupational safety should be reviewed with qualified Indonesian employment or legal professionals.
A documented internal compliance review can help the employer respond consistently, demonstrate cooperation and reduce the risk that an avoidable record-keeping issue develops into a formal enforcement matter.
Frequently Asked Questions
Must an Employer Receive Advance Notice Before a Labour Inspection?
Not necessarily. The procedure depends on the type and circumstances of the inspection.
A labour inspection must be supported by a formal assignment order, but employers should not assume that every inspection will be announced substantially in advance. Special inspections may arise from a complaint, media report or instruction from the competent labour inspection authority.
When inspectors arrive, the company should verify their official identification and assignment order, identify the scope of the inspection and appoint an authorised representative to coordinate the company’s response.
A labour inspection must be supported by a formal assignment order, but employers should not assume that every inspection will be announced substantially in advance. Special inspections may arise from a complaint, media report or instruction from the competent labour inspection authority.
When inspectors arrive, the company should verify their official identification and assignment order, identify the scope of the inspection and appoint an authorised representative to coordinate the company’s response.
How Long Does an Employer Have to Correct a Violation?
The deadline stated in Nota Pemeriksaan I must be reasonable and may not exceed 30 working days from the employer’s receipt of the notice.
If the company does not complete the required corrective action within that period, the inspector may issue Nota Pemeriksaan II within three working days. This final warning may provide the employer with up to 14 additional working days to comply.
The exact deadline should be confirmed from the notice itself. The company should complete the corrections, retain supporting evidence and report its compliance to the relevant labour inspection authority within the stated period.
If the company does not complete the required corrective action within that period, the inspector may issue Nota Pemeriksaan II within three working days. This final warning may provide the employer with up to 14 additional working days to comply.
The exact deadline should be confirmed from the notice itself. The company should complete the corrections, retain supporting evidence and report its compliance to the relevant labour inspection authority within the stated period.
Can a Labour Inspection Be Triggered by an Employee Complaint?
Yes. A complaint or report may provide the basis for a special labour inspection. A special inspection may also arise from media coverage or an instruction issued by the head of the competent labour inspection unit.
Employers should therefore maintain accurate employment records and an internal process for handling workplace complaints. Resolving concerns early and documenting the company’s response may help prevent unresolved employment issues from developing into formal disputes or enforcement matters.
Employers should therefore maintain accurate employment records and an internal process for handling workplace complaints. Resolving concerns early and documenting the company’s response may help prevent unresolved employment issues from developing into formal disputes or enforcement matters.
Can Labour Inspectors Request Company and Employee Documents?
Yes. Depending on the purpose and scope of the inspection, labour inspectors may request employment records, company information, supporting documents and explanations from company representatives, workers or other relevant persons.
The company should verify the inspector’s identification and formal assignment order before providing the requested information. It should also keep a clear record of every document submitted and designate an authorised representative to coordinate the response.
Documents should not be altered, concealed or created retrospectively. If a requested record is unavailable or requires clarification, the company should explain the position accurately and obtain professional advice where necessary.
The company should verify the inspector’s identification and formal assignment order before providing the requested information. It should also keep a clear record of every document submitted and designate an authorised representative to coordinate the response.
Documents should not be altered, concealed or created retrospectively. If a requested record is unavailable or requires clarification, the company should explain the position accurately and obtain professional advice where necessary.
What Role Does SIAPkerja Have in Labour Inspections?
Permenaker 11/2026 incorporates SIAPkerja into the labour supervision process. Inspectors may use the system to review and verify information submitted through the company’s online self-inspection process.
Employers should ensure that information entered in SIAPkerja is accurate, current and consistent with their employment records and actual workplace practices. An inconsistency between online information and supporting documents may require clarification during an inspection.
The exact reporting and self-inspection requirements applicable to a particular employer should be confirmed according to the company’s activities, workforce and location.
Employers should ensure that information entered in SIAPkerja is accurate, current and consistent with their employment records and actual workplace practices. An inconsistency between online information and supporting documents may require clarification during an inspection.
The exact reporting and self-inspection requirements applicable to a particular employer should be confirmed according to the company’s activities, workforce and location.
What Happens If an Employer Ignores an Inspection Notice?
Failure to comply with Nota Pemeriksaan I may result in the issue of Nota Pemeriksaan II as a final warning. If the company still fails to implement the required corrective action, the matter may be referred for investigation, a recommendation for administrative sanctions or other measures permitted by applicable legislation.
The consequences will depend on the nature of the violation and the legal provisions involved. For certain suspected offences, particularly those involving serious workplace accidents, unlawful child labour or other criminal elements, judicial enforcement may begin without completing every earlier supervisory stage.
An employer should therefore respond to each notice within the stated deadline, complete the required corrections and provide supporting evidence to the competent authority.
The consequences will depend on the nature of the violation and the legal provisions involved. For certain suspected offences, particularly those involving serious workplace accidents, unlawful child labour or other criminal elements, judicial enforcement may begin without completing every earlier supervisory stage.
An employer should therefore respond to each notice within the stated deadline, complete the required corrections and provide supporting evidence to the competent authority.
Should a Company Conduct an Internal Labour Compliance Review?
Yes. A periodic internal review can help the company identify inconsistencies before they become the subject of a complaint or formal inspection.
The review should compare written employment documents with actual practices relating to wages, overtime, working hours, leave, BPJS, foreign workers, workplace safety and termination procedures. It should also confirm that mandatory reports and online company information remain accurate.
Where material non-compliance is identified, the employer should obtain company-specific advice, implement the necessary corrections and retain evidence of the action taken.
The review should compare written employment documents with actual practices relating to wages, overtime, working hours, leave, BPJS, foreign workers, workplace safety and termination procedures. It should also confirm that mandatory reports and online company information remain accurate.
Where material non-compliance is identified, the employer should obtain company-specific advice, implement the necessary corrections and retain evidence of the action taken.
Related Insights
Labour inspections form part of the wider compliance framework for companies operating in Indonesia. PT and PT PMA employers should also ensure that their corporate reporting, tax representation and tax treatment remain consistent with current regulations.
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Prepare Your Company for a Labour Inspection
Permenaker 11/2026 makes labour inspections more structured, but effective preparation begins before an inspector arrives.
Business Consulting Bali can help companies review employment documentation, internal compliance records and operational practices, identify inconsistencies and coordinate the corrective steps that may require support from qualified Indonesian employment, tax or legal professionals.
If your company employs staff in Indonesia, a preventive compliance review can help management understand its current position and respond to a future inspection in an organised and well-documented manner.
Business Consulting Bali can help companies review employment documentation, internal compliance records and operational practices, identify inconsistencies and coordinate the corrective steps that may require support from qualified Indonesian employment, tax or legal professionals.
If your company employs staff in Indonesia, a preventive compliance review can help management understand its current position and respond to a future inspection in an organised and well-documented manner.
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