PT PMA Director Job-Duty Test: When Corporate Authority Becomes Work

Test whether a foreign director's real conduct is work

Appointment as a director answers a corporate governance question; it does not automatically answer the manpower and immigration question. Under Government Regulation 34 of 2021 and Minister of Manpower Regulation 8 of 2021 , the company must classify the real position, duties, work locations, duration, employer relationship, and required approvals. Board oversight, signing a reserved document, directing staff every day, selling, and delivering client work are not interchangeable activities. For the director duty test, the immediate acceptance point is to prove the appointment against the documented deed, AHU record, and reserved authority.

Write a duty schedule before choosing the title or visa. Identify recurring operational tasks, decision frequency, customer and employee contact, physical locations, remuneration, delegation, and the Indonesian organization supporting the role. The approved deed, RPTKA or other manpower output, stay permit, employment record, payroll treatment, and actual conduct should tell the same story. If duties change, reassess before the new activity begins. Within the director duty test file, the responsible officer should preserve calendar, job description, locations, and reporting as evidence for the decision to classify the conduct.

Coordinate foreign directorship with sector and immigration rules

A foreign national may be considered for a PT PMA director role subject to the Company Law, the articles, disqualification rules, any sector-specific nationality or qualification condition, and the individual's immigration and work position. Corporate appointment does not by itself authorize entry, stay, or every day-to-day work activity. The company must also be able to give the director practical access to notarial, tax, OSS, banking, employment, and contract processes. For the director duty test, the immediate acceptance point is to approve separately against the documented immigration and permitted activities.

Record the appointment and authority under the Indonesian Company Law , then check the current visa or stay-permit route directly with Indonesia Immigration or relevant advisers. Match the deed, AHU record, OSS contacts, tax profile, bank mandate, employment or service arrangement, compensation, and signature policy. If the director will operate from abroad, set original-document, electronic access, time-zone, emergency, and local execution controls instead of assuming every act can be delegated. Within the director duty test file, the responsible officer should preserve deed, systems, bank, and contracts as evidence for the decision to make control usable.

Build the RPTKA file around the real position and work location

An RPTKA is an employer plan for using foreign manpower, not a generic company quota. The filing should describe the employer, position, period, work locations, qualifications, Indonesian counterpart and training commitments, and other data required for the category. Approval of one position does not authorize a different person, title, site, or operational scope, and a corporate appointment does not by itself settle the manpower analysis. For the director duty test, the immediate acceptance point is to assign an accountable owner against the documented changes, reports, expiry, and exit.

Use the current workflow under Government Regulation 34 of 2021 and Minister of Manpower Regulation 8 of 2021 . Record the submission, approval number, validity, work locations, compensation-fund evidence where applicable, stay-permit dependency, change process, reporting owner, and expiry reminders. If duties or locations change, test whether an amendment is required before the individual begins the revised work rather than relying on an old approval. Within the director duty test file, the responsible officer should preserve position, need, period, and locations as evidence for the decision to describe actual work.

Control the assignment after the foreign employee arrives

Approval is the start of the compliance cycle. The company must keep the employee within the permitted employer, position, locations, and activities; maintain passport and stay-permit records; operate payroll and withholding; fulfill reporting and local-counterpart obligations where applicable; and monitor business travel, remote work, secondments, renewals, role changes, and termination. Access to bank, OSS, tax, customer, or plant systems should match corporate authority and the approved job. For the director duty test, the immediate acceptance point is to supervise actual conduct against the documented permitted role, employer, and work sites.

The continuing employer duties and sanctions framework appears in Government Regulation 34 of 2021 . Keep an assignment register with approval dates, permitted scope, payroll owner, tax analysis, insurance, family status, reporting dates, and exit tasks. When employment ends, revoke company authority and credentials, complete payroll and tax closure, return assets, update the organization chart, and process the relevant immigration or manpower changes rather than allowing an expired role to remain active in corporate systems. Within the director duty test file, the responsible officer should preserve payroll, tax, reports, and renewals as evidence for the decision to calendar each duty.

Coordinate manpower approval with the employee's immigration route

The manpower and immigration workstreams answer different questions. The RPTKA process addresses the employer's approved use of a foreign position, while Immigration decides entry, stay, and permitted status for the individual under the current visa classification. The name, passport, employer, title, work locations, assignment period, sponsor, and intended conduct should therefore agree across both systems; completing only one side does not authorize the employee to start work. For the director duty test, the immediate acceptance point is to use the correct immigration product against the documented passport, qualifications, sponsor, and current visa evidence.

Sequence the position review, applicable RPTKA approval, compensation-fund evidence where required, immigration application, official billing and payment, decision, entry, stay-permit activation, reporting, renewal, changes, and exit under the current framework in Government Regulation 34 of 2021 . Verify the live immigration product and document list at the time of filing rather than recycling an investor or visitor checklist. Preserve every receipt and approval under company control. Within the director duty test file, the responsible officer should preserve entry, stay, changes, renewal, and exit as evidence for the decision to maintain one calendar.

For a foreign director, use the director-specific RPTKA and work-visa test instead of assuming that a corporate title settles the permitted-work analysis.