The PT PMA is registered. The code survives the moratorium. Now the founder asks the question that quietly decides whether the company can actually function: who is allowed to work in it? You, the foreign owner, want to manage it. You want to bring in a foreign chef, a foreign developer, a foreign creative director. And you assume that owning the company entitles you to staff it as you please.
It does not. Foreign workers — TKA (Tenaga Kerja Asing) — are governed by a separate regime that sits on top of your company registration, and it answers to a different logic: every foreigner in the company must occupy a position an Indonesian could not readily fill, and every foreign hire must be justified, sponsored, and paired with local employment.
The instrument: RPTKA
The gateway document is the RPTKA (Rencana Penggunaan Tenaga Kerja Asing) — the Foreign Worker Utilisation Plan. Before a foreigner can lawfully work, the company must obtain an approved RPTKA from the manpower authority, declaring:
- the positions to be held by foreigners,
- how many foreign workers, and for how long,
- the Indonesian counterparts assigned to each foreign role, and
- the company's plan to transfer skills to local staff over time.
The RPTKA is the company's licence to employ foreigners at all. The individual's work-and-stay permit (the KITAS work permit) flows from an approved RPTKA — not the other way around. No approved plan, no lawful foreign worker, including the owner if the owner intends to draw a salary and work in an operational role.
The rule beneath the rule: positions, not people
The system is built on a simple principle that trips up founders: foreigners may hold certain positions, not any position. Roles that an Indonesian workforce can readily supply are reserved for locals. Certain positions — notably in human resources and several others — are closed to foreigners by design. The justification a company must make is always the same shape: this role genuinely requires a foreigner, and we are training Indonesians alongside.
This is why "I'll just put my whole team on KITAS" rarely works. The manpower regime expects a foreign-owned company to be a net employer of Indonesians, with foreigners concentrated in genuinely specialised or directing roles. A tech PMA on 62199 can justify foreign engineers and a foreign CTO far more easily than it can justify a foreign office manager; a hospitality PMA on 55204 can justify a foreign executive chef or GM more easily than foreign front-desk staff.
"Can I be the foreign worker?" — owner ≠ worker
The most common personal version of the question: as the foreign owner-director, can you work in your own company? Owning shares and holding a director seat is one thing; performing a salaried operational job is another. If you intend to actively work and be paid as an employee or working director, you generally need to be covered by the company's RPTKA and hold the corresponding work permit. A purely passive shareholder or a non-working commissioner sits in a different category. The distinction — between owning the company and working in it — is exactly the one the manpower rules police.
What to plan for
- Budget the RPTKA before the hire. Foreign staffing is a planned, approved process, not a hiring decision you make after the fact.
- Map positions, not headcount. Decide which roles genuinely require a foreigner and which the system expects you to fill locally — and check whether any of your intended roles are closed to foreigners outright.
- Pair every foreign role with a local plan. Skill-transfer and Indonesian counterparts are not box-ticking; they are the basis on which the plan is granted and renewed.
- Clarify your own status early. If you'll work in the business, plan your own permit as a TKA, not just as a shareholder.
The TKA regime is the reason a perfectly registrable company can still stall: the codes let you exist, but the manpower rules decide who can operate. Plan the people question with the same seriousness as the code question.
Confirm your company's KBLI code is registrable in Bali on the Bali Zero KBLI Navigator at balizero.com — then build the foreign-staffing plan (RPTKA and permitted positions) around it, so the company you can register is also a company you can lawfully run.
Bali Zero
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