The Minister of Manpower has enacted Minister of Manpower Regulation No. 11 of 2026 on Labour Inspection Procedures (“MOM Regulation 11/2026”) as the new regulatory framework governing labour inspection procedures in Indonesia, which officially came into effect on 3 July 2026. With the enactment of MOM Regulation 11/2026, Minister of Manpower Regulation No. 33 of 2016 on Labour Inspection Procedures, as amended by Minister of Manpower Regulation No. 1 of 2020 (collectively referred to as “MOM Regulation 33/2016”), has been revoked and is no longer in force.
Under the new regulatory framework introduced by MOM Regulation 11/2026, in addition to carrying out conventional inspection duties, Labour Inspectors are now expressly authorised to implement a broader range of direct administrative enforcement measures. Article 7 paragraph (1) of MOM Regulation 11/2026 provides that such measures include the sealing of work equipment, the issuance of temporary work stoppage orders and the prohibition of work processes that do not comply with the prevailing labour laws and regulations, as well as the direct removal of foreign workers who are found to be in violation of the applicable laws and regulations. Furthermore, Article 7 paragraph (2) of MOM Regulation 11/2026 expressly authorises Labour Inspectors to prohibit employers from employing foreign workers who have been designated as problematic foreign workers.
Previously, the authority of Labour Inspectors in relation to foreign workers was more limited, whereby Labour Inspectors were only authorised to order employers or company management to remove foreign workers from the workplace where the required work permit had not yet been obtained.
Digitalisation of Labour Inspection
One of the key changes introduced under MOM Regulation 11/2026 is the Development of the Labour Inspection System as provided under Article 48 of MOM Regulation 11/2026. The system is developed through the review of new labour inspection methods, the digitalisation of labour inspection, labour inspection cooperation and networking, and/or labour inspection innovation. These four initiatives are intended to facilitate and expand the coverage of labour inspection services at companies or workplaces.
The development of the Labour Inspection System is implemented through the introduction of SIAPkerja as a web-based platform, as stipulated under Article 49 paragraph (1) of MOM Regulation 11/2026, enabling companies to conduct self-assessments of their compliance with labour standards.
Under this mechanism, employers or company management, together with employee representatives, are required to complete an electronic checklist, which will subsequently be verified by the Labour Inspector. The relevant verification results will then be submitted to the Head of the competent Labour Inspection Work Unit before being incorporated into a verification report in the prescribed format.
Nevertheless, it should be noted that although companies are now required to conduct self-assessments through SIAPkerja, MOM Regulation 11/2026 expressly provides that such mechanism does not replace the authority or duties of Labour Inspectors to conduct inspections in accordance with the prevailing laws and regulations.
In addition, unlike the previous regulatory framework, which merely provided that inspection reports could be submitted manually or through an online system to be introduced gradually, MOM Regulation 11/2026 now formally integrates SIAPkerja into the National Labour Inspection System.
Inspection Procedures and Timeframe
There are several changes to the inspection procedures compared to those previously stipulated under MOM Regulation 33/2016, as summarised in the table below:
| Aspect | MOM Regulation 11/2026 | MOM Regulation 33/2016 |
| Inspection Work Plan | Labour Inspectors are required to plan and conduct inspections of at least five companies each month. Occupational Safety and Health (OSH) Labour Inspectors are also required to plan and conduct inspections of at least eight OSH compliance testing objects each month. | Removes the minimum monthly inspection target and adopts a work plan-based approach, under which inspection activities must be carried out in accordance with the unit work plan and individual work plans prepared on an annual and monthly basis. |
| Maximum Inspection Period | 60 working days | 3 working days |
| Metode Pemeriksaan Ketenagakerjaan | Monitoring and surveillance;Observation and assessment;Requests for information and clarification;Examination of labour-related documents; andVerification of the company’s self-assessment results conducted through the SIAPkerja platform. | Examination of documents;Inspection of company premises and production processes;On-site inspection; andCollection of statements. |
Changes to Enforcement Measures and Reporting Framework
MOM Regulation 11/2026 updates the labour compliance enforcement mechanism by integrating enforcement measures against non-compliance into the non-judicial law enforcement stage. Under the new framework, this stage not only includes the issuance of an Inspection Memorandum (Nota Pemeriksaan) as a written order to the employer, but also covers the determination of employees’ rights and the imposition of administrative sanctions as part of the enforcement process. Furthermore, where an employer fails to fulfil its obligations under the Second Inspection Memorandum (Nota Pemeriksaan II), the Head of the competent Labour Inspection Work Unit may recommend the imposition of administrative sanctions by the relevant authority or order the commencement of an investigation in accordance with the prevailing laws and regulations.
This approach represents a departure from the previous regulatory framework, which categorised the relevant stage as non-judicial repressive law enforcement and, in practice, primarily focused on the issuance of an Inspection Memorandum (Nota Pemeriksaan) as a warning instrument. Unlike the previous framework, MOM Regulation 11/2026 incorporates administrative enforcement measures as an integral part of the enforcement mechanism, thereby establishing a more structured and comprehensive labour inspection process.
With respect to reporting, the basic reporting framework continues to distinguish between reports prepared by Labour Inspectors and those prepared by the Labour Inspection Work Unit. However, MOM Regulation 11/2026 introduces a significant reform through the digitalisation of the reporting system by integrating the entire reporting process into the SIAPkerja platform. Under the new mechanism, the verification results of the company’s self-assessment must be documented and reported systematically through the platform.
Under the previous regulatory framework, reporting could only be carried out manually or through an online system to be implemented gradually, without the availability of a dedicated digital platform such as SIAPkerja. Following the enactment of MOM Regulation 11/2026, SIAPkerja now serves as the primary system supporting labour reporting, verification, and inspection activities in an integrated manner, with the aim of enhancing the effectiveness of labour inspection while strengthening employers’ compliance with labour laws and regulations.
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