Indonesia Company Registration and Investor Visas: Two Eligibility Checks to Complete

Check 1: Is the proposed company investment eligible?

Begin with the company’s actual revenue activities, proposed location and foreign ownership. For an intended foreign investment company, commonly called a PT PMA, the first question is whether that activity and ownership combination is permitted. The investor’s wish to obtain residence does not answer this question.

Presidential Regulation 10/2021 , read with its 2021 amendment , distinguishes open investment fields, activities reserved for or requiring partnership with cooperatives and smaller businesses, and fields with specific conditions. Record the applicable business classification, ownership condition and sector rule for each proposed activity. Do not infer unrestricted foreign ownership from a broad business description.

For ordinary new PT PMA planning, Article 26 of Investment and Downstreaming Minister/BKPM Regulation 5/2025 generally requires investment exceeding IDR 10 billion, excluding land and buildings, per five-digit KBLI business field per project location. The company’s issued/paid-up capital minimum is separately IDR 2.5 billion per limited liability company, unless another regulation provides otherwise. Sector and location exceptions change the investment calculation, including rules for wholesale, food and beverage services, construction, production lines, certain land-intensive activities and special economic zones. Verify the applicable unit before calculating.

Create a short company decision note with three conclusions: the proposed foreign ownership is permitted; the investment calculation uses the correct activity and location unit; and the capital structure can support the proposed funding. An unresolved point remains an open condition rather than a presumed pass. Capital and investment are business funding concepts, not registration charges.

The underlying company formation requirements in Indonesia concern establishing and recording the entity. Keep that legal entity work separate from checking whether its particular operating licences are sufficient. A company deed, legal entity approval and an OSS Business Identification Number, or NIB, should not be treated as interchangeable evidence of permission for every proposed activity.

An eligible company proposal does not establish a shareholder’s immigration eligibility. Close this first check with the activity, ownership and funding assumptions written down, so the personal check can use the same proposed company rather than a different version of the plan.

Check 2: Does this person fit the selected investor visa?

For a shareholder using the ordinary E28A investor route, the Directorate General of Immigration’s E28A requirements , checked on October 28, 2026, require evidence of at least IDR 10 billion in shares in the registered sponsoring company. This is the applicant’s own shareholding , not the company’s project investment or all shareholders’ combined holdings. Immigration directs an applicant below that amount who also serves as a director or commissioner to seek a work visa corresponding to that position.

The same official E28A page identifies investment and business-related activities, board roles in the invested company and supervision of its production as permitted activities. It does not give unrestricted permission for every job. Describe what you will actually do, then check the activity against the selected visa and any applicable employment requirements; a corporate job title alone leaves that question incomplete.

Where a founder will also hold office, the distinction between shareholder status and E28A activity limits matters when assessing duties. Write a practical role statement: whose business you will act for, the decisions you will make and whether you will perform operational services. That statement makes an activity mismatch visible before a filing is prepared.

For the company-linked evidence, Immigration also lists legal entity establishment approval and two months of company bank statements. Its published exception lets a company established less than two months earlier provide those statements to Immigration within 90 days after the ITAS is issued. Treat that narrowly as a statement-timing exception; it does not waive the shareholding test.

Use one personal assessment for each intended applicant. Name the person and sponsor, identify the proposed visa index, attach the ownership evidence, describe the intended activities and flag missing general application documents. Personal identity, travel documents and sponsorship conditions still require review even where the ownership amount qualifies. A threshold comparison is an eligibility screen, not a visa approval.

The two results now answer different questions. Keep them separate when choosing the next action: a company issue belongs in the corporate plan, while a personal mismatch belongs in the individual’s immigration assessment.

Use the two-check outcome grid to choose the first repair

Assign a result to each check before committing to a combined company and residence arrangement. In this planning grid, “supported” means the stated eligibility assumptions have evidence; it does not mean an authority has approved a future application. Treat an unknown or contradictory item as unresolved.

Give each unresolved item an owner and a concrete output. For example, an ownership restriction needs a documented activity-specific conclusion; an inconsistent share figure needs reconciled company records. “Agent checking” is not a result unless the eventual evidence and decision are identified.

Prioritize a defect that would change the whole proposal before a missing administrative attachment. There is little value in perfecting an application pack for a sponsor or role that will be replaced. By contrast, a missing attachment for an otherwise coherent arrangement can be assigned for collection without pretending it has already been supplied.

Recheck both results after a material change. A revised share allocation may fix one founder’s screen while changing another’s. A new business activity may reopen the company assessment even when all personal documents remain current. Date the grid and keep the assumptions beside it.

Reconcile three money figures without substituting one for another

Prepare a three-line evidence note alongside the outcome grid. Give each figure its own unit, source document and date. This is a working comparison aid, not an additional statutory form. Its purpose is to prevent a plausible-looking amount from being used in a test it does not answer.

Consider a hypothetical two-founder calculation . A company has IDR 12 billion in recorded shares, divided equally between two foreign founders. Each founder holds IDR 6 billion. Even if the company’s investment and access assessment is otherwise supported, its combined capital figure cannot establish that either individual meets the E28A shareholding amount. The two personal checks fail that amount comparison independently.

Now suppose the records show IDR 20 billion divided equally. Each person reaches IDR 10 billion arithmetically, but that does not settle sponsor registration, document consistency, intended activities or the company’s own investment test. The calculation illustrates the unit of assessment; it is not an approval example or advice to increase capital.

Use the currently recorded share amount rather than a business valuation or an anticipated capital increase. If a transfer or subscription is proposed, distinguish the post-transaction plan from the records that exist today. Do not mark the personal check supported until the evidence relied on for that conclusion actually reflects the transaction.

Where the records disagree, preserve the versions and identify the specific discrepancy: person, share amount, company identity or effective date. Resolve the underlying record through the appropriate corporate or portal process before using it as immigration evidence. Changing a number only in a visa worksheet does not resolve the conflict.

Keep E28A separate from other investor categories

An investor visa is a category-specific route, not a generic benefit attached to any investment. Select the intended category before deciding which evidence is missing. Otherwise, a founder may collect documents for the ordinary shareholder route while expecting the rights or duration of a different investor programme.

The official Immigration visa classification information distinguishes E28A from E28B for individual investors establishing a company, E28C for investors not establishing a company, and E28D for the branch or subsidiary establishment context of an overseas company. Those routes have their own investment commitments and evidence. They are not automatic substitutes when an E28A shareholding condition is missed.

For example, Immigration’s E28B conditions describe five- or ten-year options involving substantially different investment commitments and overseas company audit evidence. Evaluate that route as a separate eligibility question rather than relabelling an ordinary small company investment. The correct category follows the investor’s actual arrangement.

If the individual does not fit the intended investor route, identify the real purpose of the stay and duties before considering another category. Keep any permitted visit activity distinct from ongoing work. Where a work route is required, resolve the corresponding role and applicable employment permissions separately; do not assume the company’s incorporation has supplied them.

Before relying on a combined service proposal, ask for separate deliverables for the company assessment and each applicant’s route. An acceptable proposal identifies unresolved conditions, who must supply the evidence and which government decisions remain outstanding. A single bundled description such as “company plus investor stay” is insufficient to show that both checks have been completed.

Approve the company and investor visa plan on matching evidence

Proceed with preparation when the company proposal is supported and each person has a documented route consistent with their shares, sponsor and intended activities. Keep a dated outcome grid and the three-figure evidence note with the instructions sent to the corporate and immigration teams. These tools establish what is being assessed and which assumptions must stay aligned.

Pause a residence-dependent commitment when either check remains unresolved. Repair the specific defect, then reassess the linked result if ownership, activity, location or role changes. The completion point for this eligibility exercise is a coherent, evidenced plan with open conditions assigned; official registration, licensing and immigration permissions must still be obtained through their respective processes.