Work KITAS vs Investor KITAS in Indonesia: E23, E25 and E28A Explained

A foreign founder should not choose an Indonesian KITAS by title alone. The correct route depends on what the person will actually do, who sponsors the stay, whether the person holds qualifying shares, and whether the role creates employer obligations under manpower law. A Work KITAS route is generally tied to an employer and a defined position. An Investor KITAS E28A is tied to qualifying investment and activities in the invested company.

For a foreign executive, the practical comparison is no longer simply “Work KITAS versus Investor KITAS.” Indonesia’s current visa list separates general employment under E23 from company-role indexes under E25, including E25A for commissioners and E25B for directors, while E28A is the qualifying investor route. The index, sponsor record, RPTKA position and corporate appointment must tell the same story.

The answer-first rule is straightforward: use an investor route only when the applicant genuinely satisfies E28A and will act within that investor or company-governance scope. Use the appropriate work route when the person will be employed in a defined role, lacks the E28A shareholding threshold, or will perform operational or technical work that should be authorised as employment. A founder can be a shareholder and still need a work route if the facts do not fit E28A.

Decision principle: Start with the real Indonesian role, then map it to the current visa index, manpower approval and PT PMA records. Do not create a paper shareholding, job title or appointment merely to obtain a preferred KITAS.

Work KITAS and Investor KITAS at a glance

Issue	Work route: E23/E25	Investor route: E28A
Core basis	Employment or a specified company position with an Indonesian sponsor.	Qualifying investment and activities in the company invested in.
Typical applicant	Foreign specialist, manager, director, commissioner or other approved role, using the index matching the current classification.	Foreign shareholder who satisfies the E28A shareholding and sponsor requirements.
Sponsor	The employing or appointing Indonesian entity; the approved position and sponsor are material.	The Indonesian company in which the applicant holds the qualifying shares.
Shareholding	Not the main immigration basis. A shareholder can still use a work route.	Official E28A guidance requires at least IDR 10 billion of shares in the guarantor company, recorded with the Ministry of Investment/BKPM.
Manpower layer	Usually requires employer-side manpower compliance, including Pengesahan RPTKA and DKPTKA unless a lawful exemption applies.	Not a blanket work authorisation. The permitted investor/director/commissioner activities and any separate work obligations must be tested against the facts.
Role scope	Tied to the authorised sponsor, position and work location or activity reflected in the approvals.	Tied to investment, company establishment, business activity, and permitted director/commissioner or production-supervision activity in the invested company.
Cost drivers	Immigration PNBP, DKPTKA where applicable, manpower preparation, translations and professional handling.	Official E28A PNBP currently totals IDR 7 million for one year or IDR 9.5 million for two years, plus corporate readiness and professional handling.
Change risk	Sponsor, title, job description, work location or employment termination may require action.	Share transfer, dilution below the threshold, sponsor changes or a role outside E28A can affect continued suitability.

 

First, use the current terminology

“KITAS” is still widely used in business conversation, but the legal file distinguishes the visa used to enter for a limited-stay purpose from the ITAS granted under the immigration process. “Work KITAS” is a useful commercial label, not one universal visa index. The official immigration list now includes E23 for work and an E25 family for company commissioners and executives. For example, E25A is listed for a company commissioner and E25B for a company director.

The official Indonesian visa list should be checked at the filing date because the exact index depends on the role. The current classification follows the 2025 simplification framework under Ministerial Decision M.IP-08.GR.01.01 of 2025. This matters for SEO content because older pages can rank while still describing a superseded index or a generic “312 visa.”

Another terminology trap is IMTA. Older service pages often describe a separate IMTA work permit. Indonesia’s current manpower framework uses Pengesahan RPTKA—the approval of the Foreign Manpower Utilisation Plan—under Government Regulation No. 34 of 2021 and Minister of Manpower Regulation No. 8 of 2021. A current checklist should use the approval and portal terminology that applies at submission, not copy an older marketing label.

How the Work KITAS route works

1. Confirm that the sponsor can lawfully employ the role

A PT PMA is not automatically ready to sponsor every foreign position. The company should confirm its business activities, licences, organisation, capital and operating facts. The proposed foreign role should make commercial sense for the KBLI activities and stage of the company. Immigration and manpower records should not present a senior title where the company’s corporate and operational file shows something materially different.

The employment arrangement must also respect positions open or closed to foreign workers, competency and experience requirements, localisation obligations, and any sector-specific rules. These are not solved by selecting a convenient visa index. The index is the last label in a chain of legal analysis, not the first.

2. Prepare and obtain the manpower approval

For most foreign workers, the employer prepares an RPTKA application describing the position, employment period, location, qualifications and Indonesian counterpart or knowledge-transfer arrangements where required. The approved RPTKA should match the employment contract and immigration application. A mismatch—such as “marketing director” in one system and “business consultant” in another—creates unnecessary review risk.

Minister of Manpower Regulation No. 8 of 2021 also recognises specific RPTKA exemptions, including defined director or commissioner cases connected to qualifying share ownership or shareholder decisions. An exemption is not a general statement that all foreign directors are outside manpower law. The appointment, ownership and supporting recommendation or evidence must fit the regulatory condition. Obtain a case-specific view before relying on the exemption.

3. Pay DKPTKA when applicable

DKPTKA is the compensation fund associated with employing foreign manpower. Under the current manpower regulation, the amount is generally US$100 per position per person per month, paid for the approved period where applicable. This is not the immigration visa fee and should not be folded into a single unexplained “KITAS price.” A transparent budget separates DKPTKA, immigration PNBP, translations, medical or insurance items if required, and professional service fees.

4. File the correct work visa and ITAS route

After the manpower basis is in place, the sponsor files the immigration application under the role-appropriate current index. E23 is the general work category, while E25 variants identify company leadership positions. The immigration file commonly draws on the sponsor, passport, position, manpower approval and supporting records. Exact fields and evidence can vary by index, sector and current system configuration.

Official immigration sources describe work ITAS periods that can include 180 days, one year or two years, depending on the category and approval. Commercial pages that still say every Work KITAS is six or twelve months are therefore incomplete. Do not promise a duration until the position, index and approval are confirmed.

5. Keep post-issuance records aligned

Issuance is not the end of compliance. The company should keep the foreign worker’s actual duties, location, payroll, tax, insurance and reporting consistent with the authorised role. A corporate title can change through a shareholder resolution or deed, but the immigration and manpower consequences must be addressed as part of the same project. A foreign director should not continue working under an obsolete sponsor or position while a corporate update is pending.

How the Investor KITAS E28A route differs

E28A is designed for a foreign investor in an Indonesian company. The current official E28A page requires evidence of at least IDR 10 billion of the applicant’s shares in the guarantor company, recorded with the Ministry of Investment/BKPM. It also requires company establishment evidence, recent company current-account records, personal financial evidence, a CV, itinerary and other listed materials.

The permitted purpose includes investment, establishing a company, business activity, serving as a director or commissioner in the invested company, and supervising production activity. That language does not convert E28A into a portable permission to work for any business. The investor route should remain anchored to the sponsoring company, qualifying shares and the activities described by Immigration.

For a document-by-document eligibility screen, use MLS’s dedicated E28A guide after publication and review the current official E28A service page. For help aligning the company and immigration application, see MLS’s Investor KITAS and PT PMA service. The decision should be made before changing shares or issuing a corporate appointment solely for immigration purposes.

Which route fits common founder scenarios?

Scenario	Likely direction	What to verify
Founder holds at least IDR 10 billion of shares and is appointed director of that PT PMA	E28A may fit	Confirm official ownership record, appointment, activity scope and corporate consistency. Do not assume that every technical or third-party activity is covered.
Founder is a director but holds less than the E28A threshold	Consider E25B work route	Review the director index, RPTKA or exemption analysis, appointment and sponsor readiness.
Foreign executive has no shares	Work route	Select the current index for the actual role; obtain employer-side manpower approval and budget DKPTKA where applicable.
Qualifying investor also performs a separate technical role	Fact-specific; work route may be needed	Separate governance and investor activity from operational employment. Match the application to the real weekly duties.
Shareholder wants to work for two Indonesian companies	Do not assume one status covers both	Analyse each sponsor, appointment, job and source of remuneration. Additional or revised authorisation may be needed.
Director sells or dilutes shares below IDR 10 billion	Reassess E28A promptly	Coordinate the share transfer with immigration and manpower planning; do not wait until renewal.

 

Cost comparison: separate government charges from service fees

A reliable quote should show what is fixed by regulation and what depends on the case. For E28A, the official Immigration page currently lists total government charges of IDR 7 million for one year and IDR 9.5 million for two years. Those figures are tied to the current E28A service and should be rechecked before payment.

A Work KITAS budget is more variable. It can include the limited-stay visa and ITAS components under the current immigration tariff, a re-entry permit, verification categories, and DKPTKA of US$100 per approved month where applicable. Corporate or manpower amendments, sworn translations, insurance, relocation and professional fees are separate variables. Government PNBP is governed by the current tariff framework, including Government Regulation No. 45 of 2024; however, the applicable total depends on duration and index.

The cheapest route is not necessarily the compliant route. An investor application that fails the shareholding or activity test can be more expensive than a properly prepared work route. Conversely, a qualifying founder may avoid employer-side steps that do not apply to E28A. Compare total compliance over the planned stay, not just the first invoice.

A practical application sequence

1. Map the real role. Write down the applicant’s weekly duties, authority, reporting line, remuneration, Indonesian work location and relationship to the sponsor.

2. Check the company. Confirm deed, AHU data, NIB, licences, tax identity, address, shareholders, management and beneficial-owner information.

3. Choose the route. For employment, identify the current E23 or E25 index and test RPTKA/DKPTKA. For E28A, verify the IDR 10 billion shareholding and investor activity.

4. Reconcile evidence. Ensure names, passport details, job title, share values and corporate dates agree across employment, corporate, OSS/BKPM and immigration records.

5. File in the correct order. Complete required manpower steps before the work visa filing; for E28A, complete company readiness before presenting the investor application.

6. Plan entry and activation. Follow the current eVisa and immigration instructions, allowing time for travel, payment and system verification.

7. Maintain the status. Track passport validity, stay-permit expiry, RPTKA period, shareholding, sponsor changes and corporate amendments.

Timelines quoted by a portal or provider are service targets, not approval guarantees. A clean case can still be affected by system maintenance, verification questions, travel timing or a need to correct the sponsor’s records.

Changes that should trigger a legal review

• A share sale, capital increase or dilution that changes the E28A holder’s recorded ownership value.

• Appointment or removal as director, commissioner or executive, including a change in title or authority.

• A new Indonesian employer, sponsor, work location, secondment or group-company role.

• A shift from strategic governance to hands-on technical, sales, consulting or client-delivery work.

• A material KBLI, licence, office-address or business-model change in the sponsoring PT PMA.

• Employment termination, unpaid leave, long absence, passport replacement or planned permanent departure.

These events often span several systems. The shareholder resolution or deed is only one layer; AHU, OSS/BKPM, manpower, immigration, tax and banking records may need coordinated updates. Sequence the actions so that one change does not leave another record misleading.

Common mistakes to avoid

Using a job title as the entire eligibility analysis

“Director” can point to E25B or, for a qualifying shareholder in the invested company, E28A. The answer depends on shareholding, activity, appointment and manpower facts. A title alone cannot select the route.

Repeating the old IMTA checklist

A page may rank well and still be outdated. Use Pengesahan RPTKA terminology under the current manpower framework and verify the live portal requirements. Old references are useful only to understand history, not to build today’s filing order.

Treating E28A as a general work permit

The investor route has a defined company and activity basis. Client work, employment by another entity or a technical role outside the investor scope should be analysed separately.

Changing the cap table without immigration planning

A dilution, share transfer or capital restructuring can alter E28A eligibility. Review the stay status before signing and closing corporate documents, not after the database update.

Buying a bundle without a cost breakdown

Ask the provider to separate DKPTKA, immigration PNBP, corporate amendments, translation or administrative disbursements, and professional fees. This makes renewal costs and change scenarios easier to manage.

Founder and employer checklist

• The applicant’s actual duties and Indonesian reporting line are written clearly.

• The proposed E23/E25/E28A index matches the current official visa list.

• For E28A, the applicant’s qualifying shares are at least IDR 10 billion and recorded with BKPM/Ministry of Investment.

• For a work route, RPTKA applicability or exemption has been documented; DKPTKA is budgeted where required.

• Corporate appointment, employment agreement, AHU record and immigration description use consistent names and titles.

• The PT PMA’s NIB and sector licences support the actual business employing or appointing the foreign national.

• Government charges are separated from professional fees and optional services.

• Share transfers, sponsor changes and passport or role changes have a documented notification plan.

Frequently asked questions

Can an Investor KITAS holder work in Indonesia?

E28A allows defined investment, company-establishment, business, director or commissioner, and production-supervision activities in the invested company. It should not be described as an unrestricted work permit. Review the person’s real activities and the sponsor relationship; a separate work route may be necessary for an employment role outside that scope.

Does a Work KITAS always use E23?

No. E23 is the general work visa category, but the current official list includes E25 variants for company leadership positions, such as E25A for commissioners and E25B for directors. Choose the index from the current list for the actual position.

Is IMTA still the correct work-permit term?

Current manpower rules use Pengesahan RPTKA as the employer approval framework. Some providers still use “IMTA” as familiar shorthand, but a current application and article should follow the terminology and process under Government Regulation No. 34 of 2021 and Minister of Manpower Regulation No. 8 of 2021.

Do foreign directors always need an RPTKA?

Do not assume either answer. The manpower regulation contains defined exemptions for certain director or commissioner cases connected to ownership or shareholder decisions, subject to evidence and conditions. A non-qualifying director or a role outside the exemption may still require the work-authorisation process.

Can one KITAS cover work for two companies?

Not automatically. Both work and investor routes are tied to a sponsor, role or qualifying investment. A second company position should be reviewed independently for immigration, manpower, corporate and tax consequences.

Which route is cheaper?

E28A has published official totals of IDR 7 million for one year or IDR 9.5 million for two years. A work route may also include DKPTKA of US$100 per month where applicable, plus variable immigration components. Cost is secondary to eligibility: the legally correct route is the only useful comparison.

Can family members join the principal KITAS holder?

Dependent-family options may be available, but they are separate applications and do not automatically grant employment rights. Confirm the relationship evidence, sponsor, validity period and current dependent category before filing.

Choose the route before changing the company

The highest-risk cases are often created backwards: a founder first changes the cap table or job title, then asks which KITAS will accept the new structure. A better sequence is to define the role, test immigration and manpower eligibility, check foreign-ownership and corporate rules, and only then implement necessary company changes.

Master Legal Solution can review the PT PMA, intended role, ownership record and filing sequence as one project. For a coordinated assessment, visit the Investor KITAS and PT PMA Indonesia service page. The review should distinguish binding rules, current portal practice and case-specific evidence; no adviser should promise approval or an absolute timeline.

Authoritative references

• Directorate General of Immigration — current Indonesian visa list

• Directorate General of Immigration — E23 Visa Kerja

• Directorate General of Immigration — E25B Company Director Work Visa

• Directorate General of Immigration — E28A Investor Visa

• Ministerial Decision M.IP-08.GR.01.01 of 2025 on Visa Classification

• Government Regulation No. 34 of 2021 on Foreign Manpower

• Minister of Manpower Regulation No. 8 of 2021

• Government Regulation No. 45 of 2024 on Immigration PNBP

Legal and procedural information checked 28 September 2026. Immigration and manpower portals can change implementation details. Verify the current service page, index, fees and sponsor requirements before filing.