PT PMA Shareholder Role and E28A Eligibility: Ownership Is Not Work Permission

Match the investor's shares and role to the current E28A route

The current E28A investor visa page describes a one- or two-year stay route sponsored by the Indonesian company and requires evidence of at least IDR 10 billion in shares in the sponsor company. It also warns that an applicant holding less than that amount who serves as a director or commissioner should use the working visa route appropriate to the position. The deed, AHU record, shareholder register, sponsor data, and actual conduct therefore need to tell the same story. For the shareholder visa analysis, the immediate acceptance point is to match current corporate records against the documented at least IDR 10 billion in sponsor-company shares.

Eligibility should be checked immediately before application because immigration classifications, evidence, fees, and system fields can change. Distinguish the PT PMA's total investment plan and paid-up capital from the individual applicant's shareholding evidence. Confirm the legal owner, nominal value, currency treatment, capital status, corporate role, sponsor authority, permitted investor activities, and whether the person will also perform operational work that needs a different permission. Within the shareholder visa analysis file, the responsible officer should preserve investor activity versus operational work as evidence for the decision to use the correct permission.

Separate ownership rights from management authority

A shareholder owns shares and exercises rights through corporate decisions; a director represents and manages the company within the deed, shareholder resolutions, and Indonesia Company Law . One person may hold both roles, but the legal capacities remain separate. A share certificate or capital contribution does not itself create bank-signing power, authority to bind the company, or permission to perform day-to-day work in Indonesia. For the shareholder visa analysis, the immediate acceptance point is to represent the company within authority against the documented deed, AHU record, and signing mandate.

Record each decision in the correct capacity. Shareholder matters should have the required resolution and voting evidence; director actions should be supported by the current deed, AHU record, board authority, contract, bank mandate, and any required immigration or manpower permission. Mixing the roles can make a payment, employment action, related-party agreement, or account instruction difficult to approve and later difficult to audit. Within the shareholder visa analysis file, the responsible officer should preserve separate records for each legal capacity as evidence for the decision to prevent authority ambiguity.

Where the deed and funding record were created on different dates, run an investor KITAS capital-evidence mismatch review before uploading immigration evidence.

Classify the intended activity before selecting a visa route

Indonesia immigration routes are activity-specific. The current C2 visit visa page describes business meetings, purchasing, negotiation, agreement signing, and inspections, while prohibiting the holder from selling goods or services or receiving wages or compensation in Indonesia. The E28A investor route has its own sponsor, shareholding, evidence, validity, and activity conditions. A company title cannot convert operational work into a visit activity. For the shareholder visa analysis, the immediate acceptance point is to complete manpower and stay approvals against the documented operational duties, employer, title, and locations.

Prepare a conduct memo that lists what the foreign founder will actually do, where, for whom, how often, and whether the activity produces or manages the Indonesian business. Then match that conduct to the current immigration classification and, where work is involved, the manpower process. Recheck the official route immediately before filing because classifications, document lists, fees, and system procedures can change independently of the company deed. Within the shareholder visa analysis file, the responsible officer should preserve meetings, negotiation, signing, or inspection facts as evidence for the decision to confirm the visit route permits them.

Complete the corporate baseline for the visa route

The corporate baseline for an investor visa package should be established before immigration filing. The deed, AHU approval, shareholder register, beneficial-owner data, OSS record, sponsor account, and applicant role must support the same ownership and governance story. A pending or inaccurate amendment can affect the immigration evidence. For the shareholder visa analysis, the immediate acceptance point is to match applicant and share value against the documented deed and shareholder register.

Review the company-law framework in the Indonesian Company Law , the current investment and capital requirements in BKPM Regulation 5 of 2025 , and the applicable immigration product page. Keep corporate capital, individual share ownership, investment commitments, and visa thresholds distinct. If the applicant also performs work beyond the investor or board activities permitted by the visa, obtain specific immigration advice. Within the shareholder visa analysis file, the responsible officer should preserve approved company and immigration account as evidence for the decision to confirm authorized filing.

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 shareholder visa analysis, the immediate acceptance point is to calendar each duty against the documented payroll, tax, reports, and renewals.

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 shareholder visa analysis file, the responsible officer should preserve approvals, access, assets, and records as evidence for the decision to close every dependency.