INDONESIA · INVESTOR OWNERSHIP EVIDENCE
Investor KITAS Shareholding Requirements: Which Ownership Evidence Is Needed?
Match the applicant’s holding to the guarantor’s records before preparing an E28A filing.
For Indonesia’s E28A Investor KITAS route, you need evidence of your qualifying shareholding in the guarantor company, not simply evidence that the company has capital. The published E28A conditions require shares of at least IDR 10 billion or equivalent recorded with the investment authority. First establish who legally holds those shares; a foreign parent’s ownership chain does not automatically establish the individual applicant’s eligibility.
Key takeaways
- IDR 10 billion is the published E28A shareholding criterion; a percentage needs a documented value and company context.
- Ownership proof, the establishment decree and company current-account records perform different evidentiary jobs.
- A new-company exception for bank statements does not establish an exception to the ownership requirement.
- An overseas parent as shareholder creates an indirect-ownership question; avoid treating its shares as yours.
- Resolve discrepancies in names, allocations and record versions before the sponsor submits the file.
Which holding qualifies for the E28A route?
The qualifying amount belongs to the foreign applicant's shareholding in the sponsoring company. The Directorate General of Immigration's E28A requirements , checked on October 22, 2026, require evidence of at least IDR 10 billion or equivalent in that guarantor company, registered with the investment authority. A percentage alone does not establish that amount: the value represented by the applicant's shares must be identifiable.
The company's total capital does not establish every shareholder's eligibility. If company records show total share capital of IDR 20 billion, an applicant's documented 20% holding represents IDR 4 billion on that same basis. This is an arithmetic illustration, not an immigration valuation decision. Do not use a business sale price or a founder's estimate of company value to bridge a shortfall in the recorded holding.
Keep the permission question separate. E28A permits director or commissioner activities in the company in which the applicant invests. The official E28A page directs a director or commissioner whose shares fall below the threshold to apply for a working visa appropriate to the position. Meeting the ownership test also does not create permission for every operational job. Resolve the role boundary between investor and working permission before treating an ownership file as a complete immigration solution.
Check whose holding supports the application
Bring the proposed applicant’s ownership record and intended company role to an initial eligibility discussion.
Build a person-to-company ownership evidence file
Start with proof that connects the named applicant, the qualifying holding and the same guarantor company. The official eVisa document requirements identify share-ownership evidence, the ministry decree legalizing the company's establishment, and the company's last two months of current-account records. The public list does not prescribe one universally sufficient document called an investor share certificate.
The matrix below separates the published requirement from preparation evidence you can use to reconcile it. The supporting records are editorial preparation recommendations; they are not a claim that every item is a mandatory upload or that any one item guarantees acceptance.
| Question to resolve | Evidence to assemble | Decision before filing |
|---|---|---|
| Does this person own the shares? | Ownership proof identifying the applicant; compare passport details with the current shareholder records and relevant deed. | A company name or an agent's statement alone leaves the applicant's ownership unproved. |
| What holding is recorded? | Share quantity, recorded value and current allocation, reconciled to the investment-authority record supporting the application. | Explain differences in figures or units before claiming the threshold is met. |
| Is this the guarantor company? | The company's establishment decree, legal name and identifiers matched to the ownership evidence and sponsor details. | A holding in another group entity needs a route assessment; do not substitute it silently. |
| Are the records current? | Relevant amendment or transfer documents, current shareholder information and the version used for the visa submission. | An old founding deed cannot explain a later ownership change by itself. |
| Are financial records included? | The current-account statements required by the route, with the company identified as account holder. | Use them for the financial requirement; do not treat the balance as a shareholder register. |
For a newly incorporated foreign investment company, or PT PMA, obtain the establishment outputs before reconciling the investor file. The company registration process in Indonesia supplies the underlying entity context; incorporation and the applicant's immigration qualification remain separate questions.
Save a short reconciliation note naming each source document, its date and the field it supports. If a passport spelling differs from the shareholder record, show the documentary explanation rather than changing the spelling only in the visa form. One applicant, one holding, one guarantor is the practical test connecting the records.
What capital and payment records cannot prove alone
A company bank transfer, a capital total and an investment plan answer different questions. A transfer may help trace a contribution, but it does not by itself identify the final share allocation. A company-wide paid-up capital figure describes the company, while an investment plan describes intended investment. Neither alone establishes the applicant's qualifying shareholding.
There is also a specific timing exception for the bank evidence. Bontang Immigration's official E28A guidance says that where the company was established less than two months earlier, the company statements may be delivered to immigration no later than 90 days after ITAS issuance. That exception concerns the statements; it does not state that qualifying ownership can be deferred.
Mark missing statements and missing ownership proof separately in your file. Otherwise, a financial-document exception can be mistaken for permission to apply before the ownership basis exists.
Separate a payment gap from an ownership gap
Identify which record is missing, outdated or inconsistent before preparing more financial evidence.
When the shareholder is a foreign parent company
Ownership through a foreign parent needs a different analysis from personal ownership in the guarantor. If an overseas company is listed as the PT PMA shareholder and you own shares in that overseas company, the ownership chain explains your economic connection. It does not automatically prove that you personally hold the E28A qualifying shares in the Indonesian guarantor.
For this scenario, place the Indonesian shareholder record beside the foreign parent's ownership records and a simple group chart. Mark the legal owner at each level. Treat these as route-assessment materials, not a substitute for the published E28A evidence. The E28A eVisa criteria do not expressly establish that an indirect beneficial interest satisfies the applicant's holding requirement.
Use a two-part reconciliation: identify the shareholder and allocation in the ownership records, then explain relevant financial movements with transaction references and dates. A payment from a parent company, shareholder loan or third-party remitter should not be relabelled as the applicant's personal shares merely because it funded the business. This is a document-review method, not an additional statutory capital threshold. Record which evidence is available now and which dated follow-up obligation actually applies.
Immigration separately publishes E28D for establishing a branch or subsidiary , with its own foreign-company investment commitments. That is a separate route to assess, not an automatic alternative for anyone employed by a parent company. Before rearranging shares solely for a visa, obtain an assessment of the actual applicant, corporate structure, proposed position and applicable route.
Clear the ownership exceptions before E28A submission
Send the sponsor a file that makes the qualifying owner, amount and guarantor traceable, with unresolved discrepancies called out. Retain the dated records actually used for submission, rather than a folder containing several unexplained versions.
Pause the E28A filing if the applicant's holding is below the requirement, the investment record does not support the claimed holding, or only a corporate parent's interest can be demonstrated. The official E28A route conditions are the starting point for resolving the gap. Escalate the ownership or permission question before submission; additional bank statements cannot resolve a different legal owner.
Prepare the file for a route review
Use the reconciled holding, sponsor identity and proposed duties to define the next immigration assessment.
Frequently asked questions
Does the public E28A list name one mandatory share-certificate format?
No single universal share-certificate format is prescribed in the public requirements reviewed. The evidence must establish the qualifying holding; confirm the current upload field and any case-specific clarification before submission.
Should I remove a superseded deed from the review file?
Keep historical documents where they explain a transfer or amendment, but identify the current position clearly. A reviewer should not have to guess which document describes the ownership being claimed.
Can a director appointment replace the missing ownership amount?
A company position does not establish the required shareholding. The published route conditions direct below-threshold directors or commissioners to an appropriate working visa.
Is this ownership file the entire visa application?
No. E28A also has personal and other application requirements, including passport, photograph, living-expense evidence, CV and itinerary. The ownership reconciliation addresses the shareholding question within that application.
