Based on Ministry of Manpower Regulation Number 40 of 2012, there are any 19 positions are forbidden for expatriates in Indonesia.

As the implementation of Article 46 Law Number 13 of 2013 regarding Manpower, the Minister of Manpower issued Regulation Number 40 of 2012 regarding Certain Positions Which are Forbidden for Foreign Manpower (“Regulation 40”). Regulation 40 specifies 19 positions which are forbidden for expatriates as mentioned below.

  1. Personnel Director;
  2. Industrial Relation Manager;
  3. Human Resource Manager;
  4. Personnel Development Supervisor;
  5. Personnel Recruitment Supervisor;
  6. Personnel Placement Supervisor;
  7. Employee Career Development Supervisor;
  8. Personnel Declare Administrator;
  9. Chief Executive Officer;
  10. Personnel and Careers Specialist;
  11. Personnel Specialist;
  12. Career Advisor;
  13. Job Advisor;
  14. Job Advisor and Counseling;
  15. Employee Mediator;
  16. Job Training Administrator;
  17. Job Interviewer;
  18. Job Analyst;
  19. Occupational Safety Specialist.

Specifically regulated in Regulation of Ministry of Manpower Number 35 of 2015 regarding Amendment on Regulation Number 16 of 2015 regarding Procedures to Employ Foreign Manpower,  the position of commissioner in the local company which 100% of its shares owned by Indonesian, is strictly forbidden for expatriates.

Apart from the above mentioned regulations, the Minister of Manpower also has issued 19 decrees in the period of 2011-2015 which specify the available positions for expatriates in 19 categories. Those categories are construction; education; processing industry of chemical materials and products made by chemical materials; wholesale and retail trade and refit and maintenance of car and motorcycle; transportation and warehousing of air transport; art, entertainment, and recreation;

Processing industry of food and beverages; water supply, trash management and recycle, waste disposal and cleansing, and trash disposal and cleansing; processing industry of textile; processing industry of garment; processing industry of food; processing industry of metallic products and its equipments; agriculture, forestry and fishery; human resources supply, travel agent and other supporting businesses, domestic manpower placement; processing industry of furniture; processing industry of footwear; accommodation supply, food and beverages supply; processing industry of cigarette and cigar; processing industry of sugar.

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