How a labour inspection now runs: Permenaker 11/2026 (in force 3 July) and its amendment Permenaker 15/2026 (in force 12 October) set written orders with 30- and 14-working-day deadlines and a 14-working-day payment deadline for wage shortfalls

Labor & HRPermenaker 11/2026; Permenaker 15/2026UpdatedUpdated: October 26, 2026

Manpower Minister Regulation (Permenaker) 11/2026 on labour inspection procedures, signed on 29 June and promulgated and in force on 3 July 2026 (State Bulletin 2026 No. 438), replaced Permenaker 33/2016 and its 2020 amendment. Permenaker 15/2026, signed on 8 October and promulgated and in force on 12 October 2026 (State Bulletin 2026 No. 681), amends it. Together they set how labour inspectors work: guidance first, then inspections that end in written orders (Nota Pemeriksaan I and II) which the employer must carry out and report on, and, for shortfalls in overtime pay, minimum wage or work-accident benefits, a calculation and determination of the amount owed, which the employer must pay within 14 working days. Some breaches — a workplace accident causing death or permanent disability, child labour contrary to the rules or in its worst forms, and offences with a criminal element — can go straight to criminal enforcement. We did not publish either regulation when it was issued, so this entry is dated as a late discovery.

Key points

Instruments: Permenaker 11/2026 on labour inspection procedures (ditetapkan 29 June 2026, diundangkan and in force 3 July 2026, State Bulletin 2026 No. 438) revokes Permenaker 33/2016 and Permenaker 1/2020 (Article 55). Permenaker 15/2026 (ditetapkan 8 October 2026, diundangkan and in force 12 October 2026, State Bulletin 2026 No. 681) amends it. Notes, determinations, prohibitions and K3 certificates issued before 3 July stay valid until they expire (Article 52).
Inspector powers (Articles 4–7): inspectors may enter any company or workplace, with or without the employer present, and summon parties for data and evidence; employers, workers, unions, employer organisations, K3 experts and others must supply it, orally or in writing. They may seal equipment, stop work, stop labour placement, withdraw child workers and remove foreign nationals employed in breach of the rules from the workplace, and then bar the employer from employing them. If entry is refused they may ask the police for help.
Three stages (Articles 8–9): preventive guidance, non-judicial action (written orders and determinations of what is owed) and criminal enforcement. Criminal enforcement can start directly for a workplace accident with a death or permanent disability, child labour contrary to the rules or in its worst forms, and other breaches with a criminal element, in coordination with the police; during that, the inspector can still order the workers' rights to be met and calculate work-accident benefits.
Inspections (Articles 17–29): four kinds — first (for a newly established company that starts physical activity or obtains a permit, one that resumes operations, or one that moves its domicile or location or changes owner), periodic (within three years of the previous inspection, except certain K3 objects), special (on a complaint or report, media coverage or an order) and re-inspection. They are carried out by the provincial inspectorate where the workers work, for up to 60 working days, by monitoring, observation, clarification, document study and verification of the company's self-assessment through SIAPkerja.
Written orders (Articles 25–29): no breach gives a notice letter; a breach gives Nota Pemeriksaan I, issued within 7 working days after the report reaches the head of the unit, with a reasonable period of at most 30 working days. If it is not carried out, Nota Pemeriksaan II follows within 3 working days with at most 14 working days. If that is not carried out either, the head of the unit can order investigation by the civil-service investigators, recommend administrative sanctions to the competent official and/or take other action. The employer must carry out each Nota and report with evidence.
Testing of work norms (Articles 30–38, as amended): to set the amount of shortfalls in overtime pay, minimum wage and/or work-accident and occupational-disease benefits. Written data requests give at most 5 working days and can be sent up to three times; after the third unanswered request the inspector may set the amount on the data available. The determination is issued within 120 days (Permenaker 15/2026 extends this to all three types of shortfall) and the employer must carry it out within 14 working days of receipt (15/2026 specifies working days). A worker or the employer who disagrees can ask the Director General, through the provincial head, for a re-determination within 14 working days with reasons and supporting documents; if the file is not completed within 10 working days the determination is final. The ministry re-tests within 90 days, extendable by 30, and the employer must carry out the result within 14 working days.
K3 testing (Articles 39–46A): covers work equipment, materials, methods, workers and the work environment; first, periodic, special (after a move, an accident, heavy damage or process change, or use without testing) and repeat tests, completed within 30 working days. A certificate says the object meets K3 requirements or does not; if it does not, the inspector prohibits or halts the work, and work resumes only once a compliance certificate is issued. Permenaker 15/2026 adds Article 46A: the head of the provincial office can also issue the certificate on a company's application with a test report, verifying within 3 working days (deemed verified if not done), returning incomplete files within 2 working days, allowing 3 working days to complete them and issuing the certificate within 2 working days.

What this means for your Indonesian entity

If you employ staff in Indonesia, this is the procedure behind any labour inspection, so use it as a checklist for how you respond. (1) An inspection can start from a complaint, a media report or a new establishment, and the inspector may enter without you present; decide now who handles inspectors and who supplies documents, because parties must provide data, orally or in writing. (2) A Nota Pemeriksaan carries a deadline: at most 30 working days for the first and 14 for the second. Put them in the calendar, carry out the order and send evidence of compliance, because missing the second deadline can lead to investigation or a recommendation for administrative sanctions. (3) For pay disputes, expect a written determination of overtime, minimum-wage or accident-benefit shortfalls that you must pay within 14 working days, with the same 14 working days to ask the ministry for a re-determination with documents such as employment contracts, proof of payment, attendance records, the test report and the determination; so keep payroll, overtime and attendance records ready. (4) Answer data requests within the five working days they give: after three unanswered requests the inspector may set the amount on the data available. (5) For K3 objects, keep test certificates current; a certificate that an object does not meet K3 requirements stops the work until a compliance certificate is issued. (6) For foreign staff, inspectors can remove a foreign national employed in breach of the rules and bar you from employing them, so check work-permit status. We have not compared the earlier regulation with the new one provision by provision; this is orientation, not advice, and the regulations govern.

Sources

This page summarises publicly available information for orientation. It is not tax, legal, or accounting advice, and regulations change. Verify against the linked primary sources and contact us before acting on anything here.

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