For a foreign director of a PT PMA, ownership alone does not settle what work is permitted. The answer depends on actual duties, immigration permission, applicable manpower rules and the company’s licences. Investor/director functions and routine operational jobs are different legal questions.
Investor, shareholder, director and employee are not the same
- Shareholder: owns equity and exercises shareholder rights.
- Investor: commits capital and may be active or passive.
- Director: manages and represents the company.
- Commissioner: generally supervises and advises directors.
- Employee: works under an employment relationship.
- Foreign worker (TKA): a category governed by Indonesian foreign-employment rules.
One person can occupy several positions, but the legal consequences differ. “Operational work” describes activities such as serving meals or teaching courses; it is not another name for share ownership.
The useful question is which tasks belong to the authorised investor/director role and which require a separate employment or activity assessment.
What does an Investor ITAS actually provide?
An Investor ITAS is limited permission to reside on an investment basis. This article focuses on the ordinary E28A category sponsored by the qualifying company, rather than every investment or Golden Visa category.
Current official guidance requires evidence of at least IDR 10 billion in the applicant’s shareholding in the sponsoring company. It directs directors or commissioners below that threshold to the work-visa route appropriate to their position. This personal shareholding test is distinct from incorporation capital or total project investment.
Investment is the residence basis. However, Investor ITAS work rights include specified corporate activities. Neither “investors cannot work at all” nor “investors can do any job” accurately describes the rules.
What can a foreign investor-director actually do?
The official visa classification permits E28A holders to conduct investment and business activities, negotiate and sign business agreements, perform director or commissioner functions in the invested company and supervise production of goods or services.
Activities consistent with genuine director-level management can include:
- Attending management meetings and setting strategy.
- Reviewing financial performance and approving budgets.
- Negotiating supplier contracts and meeting business partners.
- Dealing with banks and signing authorised corporate documents.
- Supervising managers and discussing compliance with advisers.
Directors manage in the company’s interests and represent it within applicable authority. They must act in good faith and responsibly; fault or negligence can create personal liability. A commissioner has a different job: generally supervision and advice rather than routine operational management.
Where director duties end and operational work begins
There is no simple official checklist classifying every small-business task. The following contrasts identify activities needing closer review, not automatic findings of illegality.
Villa or guesthouse
Approving budgets, negotiating supplies and supervising a manager differ from checking guests in, cleaning rooms, preparing breakfast, carrying luggage, repairing equipment or driving airport transfers.
Restaurant
Approving menus and expenditure differs from cooking, serving customers, bartending or regularly working the till.
Dive business
Managing the company differs from guiding dives, teaching courses, filling tanks or operating boats.
Consultancy
Managing the client relationship differs from personally delivering the professional service being sold.
Frequency, actual responsibilities, employment arrangements and sector requirements matter. Neither occasional assistance nor absence of salary establishes permission by itself.
Investor ITAS vs work-related ITAS
| Issue | Investor ITAS, E28A | Work-related ITAS |
|---|---|---|
| Main basis | Qualifying investment | Employment |
| Sponsor | Qualifying invested company | Employing entity |
| Typical activity | Investment and permitted corporate functions | Specified employment role |
| Shareholding | Current E28A threshold applies | Not inherently required |
| Manpower process | Verify investor/shareholder exemption | RPTKA generally required unless exempt |
| Operational tasks | Must fit authorised activities | Must fit approved job and conditions |
Neither route is universally better. Match the arrangement to the person’s real role.
RPTKA: when are foreign directors exempt?
RPTKA means the employer’s foreign-worker utilisation plan. Its approval addresses employment of foreigners in particular positions; it is separate from immigration residence permission.
PP 34/2021 provides an exemption for directors or commissioners with qualifying shareholdings, or shareholders meeting applicable legal requirements. It does not exempt every director. Permenaker 8/2021 links eligibility to investment-facility criteria and the relevant investment-authority recommendation.
For an exemption assessment, produce the deed, shareholder register, recorded share value, appointment, permit and actual duties. A nonqualifying foreign director generally needs the employer’s RPTKA process and appropriate immigration permission.
DKPTKA: compensation is separate from visa fees
DKPTKA is the foreign-worker compensation paid by an employer where applicable. The prescribed rate is USD 100 per position, per person, per month, paid upfront for the approved period. Twelve chargeable months therefore total USD 1,200; this is not the visa fee.
Specified government, diplomatic, international, social, religious and educational categories have exemptions. A commercial villa or café does not qualify merely because it is small. For a qualifying investor-director, confirm whether the person falls outside the ordinary foreign-employment approval and payment route.
Can a foreign director receive a salary?
Yes, remuneration is possible. The E28A classification allows rewards or facilities connected with the investment or corporate position. Company Law provides for directors’ salary and allowances through shareholder resolutions, with permitted delegation to commissioners. Payment must still match the lawful role.
- Salary or director remuneration pays for duties.
- Dividends distribute profits to shareholders.
- Shareholder-loan repayments settle documented debt.
- Expense reimbursements repay substantiated business expenditure.
Have an accountant address payroll, withholding and the recipient’s tax position. Informal withdrawals are not automatically dividends or tax-free reimbursements.
Five Lombok scenarios
These are hypothetical illustrations, not Perwira Visa client cases.
Supervising a Kuta villa manager
A shareholder-director reviews budgets and supervises a local manager. Check qualifying shareholding, appointment, E28A conditions and exemption evidence.
Taking over guest services
The same person starts checking guests in, doing maintenance and driving airport pickups. Review actual occupations, immigration/manpower coverage and transport requirements before continuing.
Serving behind a Senggigi bar
“Only occasionally” does not answer whether customer service fits the permitted role. Obtain activity-specific advice.
Visiting from overseas
A passive investor appoints local management and visits for meetings. Periodic meetings and sustained on-site management are different situations.
Delivering consulting assignments
A consulting-company director personally performs client projects. Review whether this service is covered by the person’s arrangements and company scope.
KBLI, sector restrictions and overseas clients
The company’s KBLI must match its activities and associated OSS licences. Property management does not automatically cover tours; accommodation does not automatically cover transport or consulting. Immigration permission cannot repair a business-licensing mismatch.
Sector and occupation restrictions need separate checks. PP 34/2021 prohibits employing foreigners in positions handling personnel affairs. General staff supervision should not be confused with taking a restricted HR occupation.
Overseas clients do not eliminate these questions. Distinguish a director remotely employed by a foreign company, a PT PMA invoicing overseas customers and an individual personally invoicing clients. E28A is not blanket permission for unrelated remote employment.
Three questions to ask before doing the work yourself
Is this activity part of my lawful corporate role?
Compare the task with the director, commissioner or investor function you are actually authorised to perform.
Does manpower law treat this as foreign employment?
Determine whether the activity needs an RPTKA or another documented exemption.
Is the company licensed to perform this activity?
Confirm KBLI, OSS permissions and any sector-specific or professional requirements.
Frequently asked questions
Can I work in Indonesia if I own a PT PMA?
Ownership alone is insufficient. The role, activity and permissions must align.
Can a foreign director work without a work permit?
Qualifying investor-directors may be RPTKA-exempt; appropriate immigration permission remains necessary.
Does an Investor ITAS allow me to manage my company?
E28A expressly permits qualifying director functions in the invested company.
Can I work at my own villa or restaurant?
Assess the actual duties. Ownership does not automatically cover every operational job.
Can a foreign director receive a salary?
Yes, where properly authorised and consistent with the lawful role, with tax obligations addressed.
Sources
- Bontang Immigration: official visa guidance
- Ministerial Decision M.IP-08.GR.01.01 of 2025: Visa Classification
- Company Law 40/2007
- Government Regulation 34/2021 on Foreign Worker Utilisation
- Manpower Regulation 8/2021
- Finance Ministry Regulation 168/2023
- OSS: official business-licensing system and guidance
Regulatory information checked: 6 October 2026. General educational guidance, not an individual legal assessment. Match the paperwork to the work you intend to do.