Regulation of the Minister for the Protection of Indonesian Migrant Workers Number 4 of 2026 Governing Verification of Partners, Placement Agreements, and Placement Agencies for Indonesian Migrant Workers

Introduction

On April 24, 2026, the Ministry of Protection of Indonesian Migrant Workers/Board for the Protection of Indonesian Migrant Workers issued Regulation of the Minister of Protection of Indonesian Migrant Workers/Board for the Protection of Indonesian Migrant Workers Number 4 of 2026 on Placement Cooperation Agreements, Agency Agreements, Business Partner Requirements, and Verification of Business Partners, Employers, or Principals, and Indonesian Migrant Worker Request Letters (“Regulation 4/2026”). Regulation 4/2026 regulates cooperation between Indonesian Migrant Worker Placement Companies and business partners or employers abroad, including the integrated document verification mechanism and requirements for employers in the destination country.

Based on its recitals, Regulation 4/2026 was formulated to strengthen the protection of Indonesian Migrant Workers (Pekerja Migran Indonesia, “PMI”) and ensure that business partners, employers, and principals comply with obligations to protect workers' rights in accordance with legal provisions. Furthermore, Regulation 4/2026 implements Article 95 paragraph (2) of Government Regulation Number 59 of 2021 on the Implementation of the Protection of Indonesian Migrant Workers, including to prevent practices detrimental to PMI and ensure the compliance of parties employing PMI.

Key Provisions

Obligations and Time Limits for Placement and Agency Agreements

Regulation 4/2026 requires Indonesian Migrant Worker Placement Companies (Perusahaan Penempatan Pekerja Migran Indonesia, “P3MI”) to have a Placement Cooperation Agreement with Business Partners or Employers. For the placement of commercial and fishing vessel crews, P3MI is also required to have an Agency Agreement with the Employer or Principal. Article 2 paragraph (4) stipulates that the agreement must at least contain:

1. The identities of the parties;

2. The type of work;

3. Wages;

4. Rights and obligations;

5. Placement financing;

6. The time period; and

7. The dispute settlement mechanism.

Article 2 paragraph (6) limits the validity period of the agreement to a maximum of 5 (five) years. In addition, Article 3 requires the agreement to be drafted in Indonesian and English, and the official language of the destination country of placement may be added.

Mechanism and Criteria for Document Endorsement by Authorities

Article 4 stipulates that every placement agreement must obtain an endorsement from the Authorized Official. Article 5 stipulates that the application for endorsement is submitted directly or through the electronic system of the Computerized System for the Protection of Indonesian Migrant Workers (Sistem Komputerisasi Pelindungan Pekerja Migran Indonesia, “Sisko P2MI”) to the Representative of the Republic of Indonesia or the Indonesian Economic and Trade Office (Kantor Dagang dan Ekonomi Indonesia, “KDEI”). Article 12 stipulates that the Authorized Official conducts verification through the following actions:

1. Examining the completeness of documents;

2. Tracing information on the websites of authorities in the destination country;

3. Coordinating with relevant agencies;

4. Conducting field verifications; and

5. Assessing the settlement of previous worker cases.

Article 15 stipulates that the endorsement process shall be completed no later than 7 (seven) working days from the receipt of the application by the authority.

Registration Obligations and Fulfillment of Administrative Documents by Employers

Regulation 4/2026 requires every Business Partner, Employer, or Principal to register to be included in the list of verified entities at the Representative of the Republic of Indonesia or KDEI as stipulated in Article 16. According to Article 6, Business Partners must attach:

1. A copy of the recruitment business license;

2. A company profile;

3. A letter of appointment for the person in charge; and

4. A statement letter on the veracity of the documents.

Based on Article 8, government agency Employers are required to attach a letter of assignment or power of attorney as the person in charge along with a copy of their employee identity. Meanwhile, for public or private corporate Employers, Article 9 stipulates that the documents to be attached include:

1. A business license or other equivalent document;

2. A company profile;

3. A letter of appointment for the management assigned as the person in charge; and

4. A copy of the employee identity of the person in charge along with a certificate from the competent authority relating to criminal acts or banking violations.

Meanwhile, Article 10 stipulates that individual Employers must submit:

1. Identity;

2. Taxpayer identity valid in the destination country/region of placement;

3. A certificate from the competent authority relating to criminal acts or banking violations; and

4. A statement letter of willingness to provide insurance or social security, facilitate the opening of a bank account, pay wages, and provide decent housing.

Additional Requirements for Marine Sector Agency Agreements

For the marine sector, Article 11 stipulates more specific endorsement requirements for Agency Agreements. P3MI must attach the following documents:

1. A letter of appointment that has been endorsed by the Representative of the Republic of Indonesia or KDEI;

2. A certificate of registration with the competent institution or agency in their respective countries which must be endorsed by the Representative of the Republic of Indonesia or KDEI;

3. A collective labor agreement;

4. A power of attorney to act on behalf of the Principal which has been endorsed; and

5. A copy of the draft Sea Employment Agreement.

Submission, Verification, and Expiration of Worker Request Letters (Job Orders)

The Indonesian Migrant Worker Request Letter must be endorsed and submitted simultaneously with the draft Cooperation Agreement as stipulated in Article 17. In such submission, the Business Partner, Employer, or Principal must attach the required documents, which include, among others:

1. The draft Employment Agreement (or Sea Employment Agreement); and

2. Documents on the utilization of foreign workers in accordance with the provisions of laws and regulations in the destination country/region of placement.

Article 18 stipulates that the authority verifies:

1. The conformity of the request quota with local permits;

2. The offered employment sector; and

3. The conformity of working hours and wages with the laws of the destination country.

The validity period of the Indonesian Migrant Worker Request Letter is limited to a maximum of 15 (fifteen) months upon being granted the status of "Terverifikasi/Verified", as stipulated in Article 20. The endorsement process shall be completed within a maximum period of 7 (seven) working days from the receipt of the application, or a maximum of 14 (fourteen) working days if the application is submitted simultaneously with the application for endorsement of the Placement Cooperation Agreement or Agency Agreement, in accordance with Article 22.

Blacklist Sanctions and Periodic Publication

The Authorized Official conducts monitoring and evaluation of the Business Partner, Employer, or Principal as stipulated in Article 24. Article 25 stipulates that Business Partners or Employers in the destination country may be designated as problematic Business Partners or Employers if proven to:

1. Commit a criminal act;

2. Violate legal provisions; or

3. Fail to fulfill protection obligations toward PMI in distress.

Designation as a problematic Business Partner or Employer does not eliminate the obligation to settle legal obligations towards workers. The Representative of the Republic of Indonesia or KDEI is obliged to announce and update the list of verified entities and problematic Business Partners or Employers to the public every 3 (three) months, as stipulated in Article 27.

Compliance with the Standardized Format in the Annexes

Regulation 4/2026 requires businesses to use the standardized manuscript format as set forth in the Annexes. Businesses must use the templates for:

1. Letter of Appointment of Management as the Person in Charge for Business Partners (Part A) and Public/Private Corporate Bodies (Part E);

2. Statement Letter on the Veracity of Documents (Part B) and Statement of Not Being Sentenced to Imprisonment (Part C);

3. Indonesian Migrant Worker Request Letter or Job Order (Part F), including a table format detailing salary, recruitment duration, taxes, insurance, and leave obligations; and

4. Document Completeness Verification Checklist (Part G).

Transitional Provisions

Regulation 4/2026 stipulates that Placement Cooperation Agreements and Agency Agreements that have been endorsed prior to April 24, 2026 shall remain valid until expiry of the agreement term, as stipulated in Article 29 letter a. In addition, Indonesian Migrant Worker Request Letters or Job Orders that have been issued and verified prior to April 24, 2026 shall remain valid until their validity period expires, as stipulated in Article 29 letter b, therefore P3MI is not required to resubmit documents that are still valid.

Closing

Regulation 4/2026 stipulates that P3MI must have a Placement Cooperation Agreement or Agency Agreement with a maximum validity period of 5 (five) years, drafted in Indonesian and English, and endorsed by the authority. It further requires the registration of Business Partners, Employers, or Principals to be included in the list of verified entities by attaching administrative documents in accordance with the provisions. In the placement process, the Indonesian Migrant Worker Request Letter or Job Order is verified by the authority for a maximum of 7 (seven) working days, or a maximum of 14 (fourteen) working days if submitted alongside the draft agreement, and is valid for a maximum of 15 (fifteen) months upon being granted the status of "Terverifikasi/Verified". The Regulation also provides for continuous monitoring and evaluation as well as the periodic publication of the list of problematic Business Partners or Employers every 3 (three) months. Furthermore, it sets forth the use of the standardized format in the Annexes which must be followed by businesses. For the transitional period, agreements and Job Orders that have been endorsed prior to April 24, 2026 shall remain valid until their validity period expires, so that P3MI may continue the placement process without resubmitting documents that are still valid.