The Right KITAS for Company Directors in Indonesia

The Right KITAS for Company Directors in Indonesia

  • InCorp Editorial Team
  • 29 July 2026
  • 6 minutes reading time

A KITAS for a company director is not only an immigration document. A foreign director who holds the wrong KITAS type in Indonesia risks work permit violations, permit cancellation, and deportation under Government Regulation No. 34/2021 on the Use of Foreign Workers and the Immigration Law (UU No. 6/2011). 

The main question for most PT PMA companies is whether a foreign director qualifies for an Investor KITAS or requires a Working KITAS.  

The answer depends on the director’s shareholding, role in the company, daily responsibilities, and whether the person is acting mainly as an investor, an active executive, or an employee of the Indonesian entity.

Key Takeaways

  • A foreign director’s KITAS type must reflect their actual activities, shareholding, and compensation, not their job title. 
  • An Investor KITAS (E28A) requires a minimum personal shareholding of IDR 10 billion, registered in the applicant’s name in the company deed. 
  • Working KITAS (E23) is required when the director is employed, paid, or operationally managing the Indonesian entity. 
  • A working KITAS may require RPTKA approval before the visa application can proceed, so companies should plan the timeline carefully. 
  • Using Investor KITAS to avoid work authorization can create compliance issues under GR No. 34/2021. 
  • Mismatches may be detected through company, visa, and OSS records, creating risks for both the director and the company. 

Investor KITAS vs Working KITAS: Key Differences 

For foreign directors, the two main visa options are the Investor KITAS (Index E28 A) and the Working KITAS (Index E23). The correct assessment depends on what the director actually does in Indonesia under GR No. 34/2021, not solely on their title in the company’s organizational chart. 

Factor Investor KITAS (E28A) Working KITAS (E23) 
Eligibility basis Foreign shareholder as director/commissioner Director employed or operationally active in Indonesian entity 
Minimum shareholding IDR 10 billion (Permenkumham No. 22/2023) None required 
Work permit (RPTKA/IMTA) Not required for board-level and investor activities Required before visa application 
DKP-TKA levy (formerly DPKK) Not applicable USD 100/month, paid by employer upfront for full permit duration 
Permit validity 1 or 2 years, renewable 6–12 months, renewable (2-year validity requires specific justification) 
Tax registration Subject to Indonesian tax residency rules based on length of stay Registered as employee taxpayer; employer withholds PPh 26 
Sponsor entity PT PMA PT PMA as employing entity 

Does a Foreign Director Need a Work Permit in Indonesia? 

Yes, if the director actively manages, represents, or operates the company in Indonesia. A business visa or visa on arrival doesn’t authorize employment, contract signing, employee supervision, or regular executive activity.  

Under Government Regulation No. 34/2021 on the Use of Foreign Workers, any foreigner performing work functions for an Indonesian entity must hold the appropriate work authorization. 

What PT PMA Directors Should Review Before Applying for KITAS 

Before filing, the company should document honest answers to the following: 

  • Will the director act only as a shareholder and board member, or actively manage operations? 
  • Will they sign contracts, invoices, bank documents, or employment agreements? 
  • Will they supervise local employees or departments? 
  • Will they represent the company before clients, vendors, banks, or government agencies? 
  • Will they receive salary, allowances, or employment-related compensation? 
  • Do they hold sufficient shares to meet the Investor KITAS threshold? 
  • Will they need to be listed in the workforce approval (RPTKA) as a foreign worker? 

These answers determine the correct KITAS route. They also determine the company’s broader compliance, such as PT PMA corporate documents, OSS licensing, NPWP registration, and bank account authorization, all of which are linked to the director’s legal status in Indonesia. 

KITAS for Company Director: Process, Timeline, and Cost Factors 

The process for obtaining a KITAS for company director roles depends on the selected route. Investor KITAS and Working KITAS follow different documentation and approval processes, especially regarding workforce authorization. 

Stage Investor KITAS (E28A) Working KITAS (E23) 
Pre-application Verify IDR 10 billion personal shareholding Obtain RPTKA + IMTA from the Ministry of Manpower 
Key documents Shareholder certificate, company deed, NPWP, domicile letter Employment contract, RPTKA/IMTA approval, company documents 
Processing time 2–4 weeks 4–8 weeks 
Biometric In-person appointment required (effective May 2025) In-person appointment required (effective May 2025) 

The Working KITAS route requires RPTKA (Rencana Penggunaan Tenaga Kerja Asing) approval from the Ministry of Manpower before the visa application can proceed, which adds time and documentation requirements that companies should account for. 

KITAS Mistakes Company Directors Should Avoid 

A KITAS mismatch can create real compliance issues. Immigration authorities may cross-check OSS records, tax data, and company filings. If a foreign director’s activities do not match their permit type, the company and director may face: 

  • Immigration sanctions under UU No. 6/2011 
  • Work permit violations under GR No. 34/2021 
  • Administrative fines for the sponsoring PT PMA 
  • Permit cancellation and mandatory departure 
  • Deportation and entry bans 
  • Compliance records affecting all future Indonesian visa and permit applications 

The sponsoring company also carries compliance responsibility. For this reason, KITAS selection should be treated as a legal and business compliance decision, not only an administrative step. 

InCorp Indonesia (an Ascentium Company) can help companies review the right KITAS route, sponsor arrangement, and supporting documents before the application process begins. Talk to our team -> 

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Obtain the Right KITAS for the Company Director with InCorp 

A KITAS for a company director should match the director’s role, shareholding status, and activities in Indonesia. Choosing the right route helps avoid delays, permit issues, and compliance risks. 

InCorp Indonesia (an Ascentium Company) can support companies with: 

  • Investor KITAS for foreign shareholders serving as directors or commissioners 
  • Working KITAS for foreign directors actively working in Indonesia 
  • Work permit support for employment-based director roles 
  • Document review to align company records, sponsor details, and application requirements 
  • Application assistance from preparation to submission 

Fill out the form below to find the right KITAS route for your company director. 

Frequently Asked Questions

What is the difference between an Investor KITAS and a Working KITAS for a foreign director in Indonesia? 

Investor KITAS is for foreign shareholders who serve as directors or commissioners of an Indonesian company with qualifying share ownership. A working KITAS, or the relevant work visa route, is for directors who are employed by, paid by, or actively managing the Indonesian entity.

Does a foreign director in a PT PMA need an RPTKA?

Only if the director applies through an employment-based work route, investor KITAS holders generally do not need RPTKA if their activities are limited to investor or board-level functions. 

Can a foreign director use a business visa instead of a KITAS in Indonesia?

No. A business visa does not allow regular work, operational management, or executive activities in Indonesia. Directors performing these activities need the appropriate KITAS.

What shareholding is needed for Investor KITAS eligibility?

For the E28A Investor Visa, the foreign director generally needs to hold at least IDR 10 billion in shares in the sponsoring company.  

What happens if a foreign director uses the wrong KITAS type? 

Using the wrong KITAS can lead to immigration sanctions, work permit issues, administrative fines, permit cancellation, deportation, and difficulty obtaining future visas. The sponsoring company may also face compliance responsibility. 

Verified by

Hotdo Nauli

Senior Legal & Delivery Manager at InCorp Indonesia

Hotdo heads the Legal and Delivery team at InCorp Indonesia, managing Product Registration, Legal Advisory, and Business Licensing. With over 8 years of experience, she focuses on compliance and integrity,... Read more

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