Indonesia Amends Labour Inspection Procedures Under Minister of Manpower Regulation No. 15 of 2026
The amendment introduces working-day deadlines, expands the scope of entitlement determinations, and creates a new route for provincial OSH certificates.
Minister of Manpower Regulation No. 15 of 2026 (“MOMR 15/2026”) amends Minister of Manpower Regulation No. 11 of 2026 on Labour Inspection Procedures (“MOMR 11/2026”). It was enacted on 8 October 2026, promulgated on 12 October 2026 in State Gazette No. 681 of 2026, and took effect on the date of promulgation.
MOMR 15/2026 amends five articles and introduces a new Article 46A on the issuance of occupational safety and health (“OSH”) certificates by Provincial Offices. Other provisions of MOMR 11/2026 remain in force.
Key changes
Wider scope for entitlement determinations
Provincial Office Labour Inspectors may determine shortfalls in all relevant entitlements, including overtime pay, minimum wage, and work-accident and/or occupational-disease benefits. The determination period remains a maximum of 120 days. These determinations may also be subject to re-determination.
Deadlines now counted in working days
Employers must implement determinations and re-determinations within 14 working days of receipt.
Broader access to re-determination
Re-determination may be sought for determinations under Article 31(11) and for all labour-norm testing under Article 31(1). Applications must be submitted to the Director General through the Head of the Provincial Office within 14 working days of receiving the determination, with reasons stated.
A new route for provincial OSH certificates
Under new Article 46A, a company may apply to the Head of the Provincial Office for an OSH certificate. The application must include the testing report. The process sets out these deadlines:
- Verification: within 3 working days.
- Return letter if the application is incomplete: within 2 working days.
- Company’s deadline to complete the application: within 3 working days.
- Certificate issuance: within 2 working days after verification.
If verification is not carried out within 3 working days, the application is deemed verified and the certificate must be issued.
Other amendments
The wording in Articles 17(2) and 31(10) is revised without changing its substance. Article 34(5), which governed the form of a determination, is deleted.
What employers should note
MOMR 15/2026 does not introduce new sanctions. The consequences under MOMR 11/2026 continue to apply, including:
- Labour Inspectors’ determinations are non-judicial measures to fulfil workers’ entitlements and must be implemented within the prescribed deadline.
- If requested data is not provided after the third request letter, a Labour Inspector may determine the shortfall based on the available data.
- If a re-determination application is not completed within 10 working days, it is inadmissible, and the Provincial Office’s determination becomes final and binding.
- Failure to comply with Inspection Note II may lead to an investigation by labour civil servant investigators and/or a recommendation for administrative sanctions.
MOMR 15/2026 contains no transitional provisions. Inspection Notes, determinations, and OSH certificates issued before MOMR 11/2026 remain valid until they expire.
Practical steps for companies
Companies should consider updating internal procedures and compliance calendars so that implementation deadlines are counted in working days. They should also keep employment agreements, proof of payment, and attendance records in order, as these are minimum requirements for a re-determination application.
For OSH certificates, companies may consider applying through the Head of the Provincial Office. Employers should also respond to Labour Inspectors’ requests for information within 5 working days to reduce the risk of a determination based only on one-sided data.