Capital evidence alignment
Investor KITAS Capital Evidence Mismatches Before Application
PT PMA investment value, paid-up capital, individual share ownership and the bank trail are different numbers that must not be substituted for one another.
An Investor KITAS application can fail or create later risk when four different capital concepts are treated as one: the PT PMA's planned investment, the company's issued and paid-up capital, the applicant's registered share ownership, and the money actually evidenced through corporate and personal records. Under current BKPM rules, a PT PMA generally has investment above IDR 10 billion per applicable calculation basis and minimum issued and paid-up capital of IDR 2.5 billion per company, subject to sector and activity rules. Current E28A information separately asks for evidence that the applicant owns at least IDR 10 billion in shares in the sponsoring company. One number does not prove the others. Before filing, reconcile the deed, AHU profile, shareholder register, OSS investment plan, subscription approvals, corporate bank evidence and any personal financial evidence required by immigration.
Key takeaways
- Build a four-column reconciliation instead of presenting one capital number everywhere.
- Use the effective deed and AHU data for registered ownership, not an unsigned term sheet.
- Do not treat the PT PMA's IDR 2.5 billion paid-up capital as proof that one investor owns IDR 10 billion in shares.
- Trace subscriptions and permitted uses of company funds through a corporate bank record.
- Recheck the immigration category if the applicant does not meet the current personal share threshold.
Do not interchange these four capital figures
Each figure answers a different legal or evidentiary question. Record the source document, valuation date and responsible reviewer for every amount.
PT PMA investment
Generally above IDR 10 billion
BKPM applies activity- and location-based calculation rules and stated exceptions.
Paid-up capital
At least IDR 2.5 billion
The current general minimum is per PT PMA, unless another rule applies.
E28A applicant shares
At least IDR 10 billion
Official immigration information states the applicant's share evidence threshold in the sponsor.
Personal funds
USD 2,000 evidence
Current E28A materials also request recent personal means-of-living evidence.
Evidence basis: BKPM Regulation No. 5 of 2025 · Directorate General of Immigration E28A investor visa information
Separate the capital figures
Reconcile investment value, paid-up capital, applicant shares and personal funds before choosing the visa route.
A founder can be a genuine investor and still select the wrong immigration route. For example, a company may satisfy its general paid-up capital baseline while the individual applicant's registered shares remain below the E28A threshold. Conversely, a high nominal share value does not establish that the PT PMA's OSS investment plan, sector eligibility and funding evidence are accurate.
The reconciliation should sit beside the company's paid-up capital evidence file and use effective corporate records. Avoid backdated subscriptions, circular transfers and temporary ownership arrangements designed only to obtain a visa; they introduce corporate, banking, accounting and immigration inconsistencies.
Reconcile the four numbers before choosing E28A
Write each amount in rupiah, identify what it represents and attach its controlling record. The table should expose—not hide—legitimate differences.
Investment value
The warning sign appears when the OSS plan uses IDR 10 billion as a flat company-wide number without applying the current activity calculation basis. Verify it with KBLI, project locations, fixed-asset and working-capital plan and BKPM Regulation No. 5 of 2025. The responsible person should recalculate each applicable project and document any exception; otherwise, the investment plan is structurally understated or allocated incorrectly.
Company paid-up capital
Treat the deed states IDR 2.5 billion but the ledger and bank trail do not show how the subscription was satisfied as a decision gate, not an administrative detail. Keep deed, shareholder approval, bank statement, general ledger and subscription evidence in the transaction file, then reconcile the accounting entry with lawful funding evidence. This reduces the chance that the company cannot substantiate its stated capital.
Applicant's shares
A reliable check starts with share count, nominal value, latest deed, AHU profile and shareholder register. It should resolve whether the application relies on total company capital rather than the applicant's registered holding. Where the records do not reconcile, calculate the applicant's own effective holding; proceeding without that step can mean the personal E28A threshold is not actually met.
Personal means
corporate funds are presented as the applicant's personal living-cost evidence The evidence that matters is recent personal bank evidence and official document requirements. provide the requested evidence from the correct account holder If that control is skipped, the document does not answer the immigration requirement.
Trace ownership and funding through effective records
Immigration, bank and corporate reviewers may examine the same transaction from different angles. Build one chronological file from approval through payment and use.
Unsigned ownership change
Treat a transfer or capital increase is mentioned in a term sheet but has not become effective as a decision gate, not an administrative detail. Keep executed deed, required corporate approval, AHU result and updated shareholder register in the transaction file, then file only on the legally effective ownership. This reduces the chance that the visa narrative gets ahead of the company record.
Circular or temporary funding
A reliable check starts with bank trail, board-approved use, invoice, asset or operating evidence and ledger. It should resolve whether money enters the company and immediately returns without a documented permitted purpose. Where the records do not reconcile, investigate and correct the funding treatment before filing; proceeding without that step can mean the capital evidence appears artificial or inconsistent.
Foreign-currency mismatch
share and investment values are converted using unexplained rates or dates The evidence that matters is transaction date, bank conversion, deed currency basis and documented calculation. use one defensible rupiah calculation and disclose the date If that control is skipped, different files produce different ownership values.
Paid-up funds used without evidence
The warning sign appears when company capital finances operations but invoices and approvals are missing. Verify it with budget, vendor invoice, payroll, asset register and payment approval. The responsible person should retain purpose and accounting evidence for each material use; otherwise, a permitted business use cannot be distinguished from an unexplained withdrawal.
Trace the subscription and ownership
Review effective deeds, AHU data, bank movements and accounting entries for one consistent chronology.
Choose the route that matches the applicant after reconciliation
Do not modify genuine ownership merely to preserve a preferred visa label. Select the category based on the final effective facts and intended activities.
Below E28A share threshold
A reliable check starts with effective ownership calculation and official immigration category information. It should resolve whether the director or commissioner owns less than the current official threshold. Where the records do not reconcile, assess the appropriate work-visa route; proceeding without that step can mean an investor application is built on an unmet condition.
Passive investor activity
the applicant will monitor investment but not perform unrelated operational work The evidence that matters is travel plan, governance schedule and permitted-activity analysis. document the limited activity accurately If that control is skipped, a broad job description creates unnecessary work-status exposure.
Mixed investor and technical role
The warning sign appears when the founder will supervise investment and personally deliver technical services. Verify it with weekly duty map, client deliverables, qualifications and sponsor analysis. The responsible person should obtain a category and manpower assessment for the productive role; otherwise, the application describes only half of the actual conduct.
Corporate change still pending
Treat the qualifying share issue or transfer has not completed AHU and bank steps as a decision gate, not an administrative detail. Keep closing checklist and effective-condition evidence in the transaction file, then finish and verify the corporate transaction before filing. This reduces the chance that the application depends on future facts.
Official capital and E28A evidence thresholds
BKPM and immigration rules answer different questions. The capital regulation governs PT PMA investment and company capital, while the E28A page governs the individual visa applicant's category evidence.
- BKPM Regulation No. 5 of 2025 : The current OSS procedure regulation includes the general PT PMA investment threshold, the IDR 2.5 billion minimum issued and paid-up capital rule, OSS procedures and administrative consequences. Sector-specific exceptions and calculation bases still have to be checked.
- Directorate General of Immigration E28A investor visa information : The official visa category explains permitted investor activities, required corporate evidence and the shareholding evidence threshold. A director or commissioner below the stated shareholding threshold is directed to the appropriate work-visa route.
- Law No. 40 of 2007 on Limited Liability Companies : The Company Law, as amended, defines the roles and accountability of shareholders, directors and commissioners. Authority should be traced to the deed, shareholder or board decisions and valid delegations.
- Directorate General of Immigration limited-stay permit information : Immigration status is a separate approval layer. Incorporation, a corporate office appointment and a business licence do not automatically create a right to reside or work in Indonesia.
Sector rules and special investment calculation bases can change the PT PMA analysis. Immigration may request additional evidence and retains decision authority. Verify the official pages immediately before the corporate transaction and again before the visa filing.
File only from a signed capital reconciliation certificate
The certificate should show the PT PMA investment value by activity and location, company paid-up capital, each shareholder's registered holding, the E28A applicant's calculated shares, personal financial evidence and the supporting document for every figure. A director, finance reviewer and immigration adviser should sign off within their respective scope.
Any unexplained gap becomes a pre-filing condition. If the genuine facts do not support E28A, change the route rather than the facts. That choice preserves the integrity of the corporate, banking and immigration record.
Select the route from genuine facts
Determine whether E28A or a work route fits the applicant's effective ownership and real activities.
Frequently asked questions
Is IDR 2.5 billion paid-up capital enough for an Investor KITAS?
Not by itself. That is the current general company paid-up capital baseline. Current E28A information separately asks for evidence that the individual applicant owns at least IDR 10 billion in shares in the sponsor.
Is the IDR 10 billion PT PMA investment rule the same as the visa share threshold?
No. The PT PMA investment value follows BKPM calculation rules, while the E28A threshold concerns the applicant's registered share ownership. They may both mention IDR 10 billion but prove different facts.
Can paid-up capital be used for company operations?
BKPM Regulation No. 5 of 2025 allows stated exceptions to the 12-month non-transfer commitment for assets, building construction and company operations. Keep corporate purpose, payment and accounting evidence.
What if the investor's shares are below the E28A threshold?
Current official information directs a director or commissioner below the stated threshold to the appropriate work-visa route. Review the person's actual duties and manpower requirements.
Should shares be increased only to obtain E28A?
Any capital increase must be genuine, commercially approved, legally effective, funded and reflected consistently across corporate, bank, accounting and OSS records. Do not create temporary or misleading ownership.
