Choosing the right KITAS for company director positions in Indonesia is no longer simply a matter of deciding between an investor permit and a work permit. The correct route depends on the director’s shareholding, registered corporate position, intended activities, and the workforce requirements that apply to the individual.
Under Indonesia’s current visa classification, foreign company directors generally need to assess two routes: the E28A Investor KITAS and the E25B Company Director Work Visa. Using a mismatched permit can create immigration and employment compliance risks for the director.
Key Takeaways
- Indonesia’s current visa classification specifically provides E28A for qualifying investors and E25B for foreign company directors working in Indonesia.
- An E28A applicant must hold at least IDR 10 billion in shares in the sponsoring company; directors or commissioners below this threshold should use the appropriate work-visa route.
- If a director or commissioner holds less than the E28A shareholding threshold, immigration instructs the applicant to use a work visa according to their position.
- Assess RPTKA requirements separately because certain directors, commissioners, and shareholders may qualify for an exemption under Government Regulation No. 34/2021.
KITAS for company directors at a glance
| Factor | E28A Investor KITAS | E25B Director Work Visa |
| Best suited for | Qualifying investor who also serves as a director or commissioner | Foreign national appointed as Company Director or Executive Board Member |
| Shareholding | Minimum IDR 10 billion in shares in the sponsoring company | E28A shareholding threshold does not apply |
| Main basis | Qualifying investment and corporate position | Work appointment as director |
| RPTKA | Assess whether a shareholder/director exemption applies | May be required unless an exemption applies |
| Key consideration | Shareholding and activities must support investor status | Corporate position and activities must match the director work route |
Why choosing the right director KITAS is important
A foreign director’s position in the PT PMA deed doesn’t automatically determine the correct immigration route.
Recent enforcement shows why these matters are important. In 2026, Yogyakarta Immigration reported multiple cases involving suspected misuse of foreign-investment arrangements, including the deportation of an Investor ITAS holder whose actual activities did not match his documented investor status.
Under the current classification, E25B applies to company directors, while E28A applies to investors who meet the required shareholding and corporate criteria.
PT PMA companies should therefore confirm whether the individual qualifies as an investor-director or should use the work route before filing.
Choosing between E28A and E25B KITAS for company directors
The right route depends mainly on the director’s shareholding, corporate position, and the basis of their assignment in Indonesia.
When E28A applies
E28A can apply when the foreign director is also a qualifying investor in the sponsoring company.
The applicant must hold at least IDR 10 billion in shares in the company. E28A also allows the holder to serve as a director or commissioner and supervise the production of goods or services in the company where they invest.
This route may therefore suit a foreign national who is genuinely both an investor and company director.
When E25B applies
E25B is the role-specific work visa for a Company Director or Executive Board Member.
It may apply when the foreign director does not qualify for E28A, including where the individual is not a shareholder or does not meet the E28A shareholding threshold.
Companies should also distinguish E25B from E25C, which applies specifically to a Deputy Director or Deputy Executive Board Member.
Does a foreign director need an RPTKA?
The answer depends on the appointment structure. Government Regulation No. 34/2021 generally requires employers using foreign workers to obtain approval for their Foreign Worker Utilisation Plan (RPTKA).
However, the rules exempt certain directors or commissioners with qualifying share ownership and shareholders, under applicable regulations.
This means companies should not assume that every E25B director requires the same workforce arrangement, nor that being called a director automatically removes RPTKA requirements.
The company’s immigration and workforce position should be assessed together based on:
- The director’s shareholding
- Their registered corporate position
- Their employment arrangement
- The activities they will perform
- Any applicable RPTKA exemption
Common director KITAS issues to address before applying
Most problems arise when the visa route does not fully match the director’s corporate position, shareholding, or actual activities. Before filing, companies should address these points:
- Wrong visa route: E28A depends on qualifying investment, while E25B applies to company directors under the work route.
- Position mismatch: The registered position should match the visa category being used.
- Shareholding issue: Confirm whether the director meets the E28A investment threshold.
- Workforce gap: Determine whether RPTKA or an applicable exemption applies.
- Document mismatch: Keep corporate, immigration, and workforce records consistent.
- Corporate changes: Reassess the KITAS after changes in shareholding, directorship, sponsor, or responsibilities.
If these elements don’t align, the company may face application delays, immigration investigations, permit cancellation, deportation, or complications with future immigration applications.
What happens if the director uses the wrong KITAS?
Using an incorrect KITAS that does not match the director’s actual activities or shareholding can lead to legal penalties, including fines, permit cancellations, or deportation, highlighting the need for accurate route selection.
Potential consequences include:
- Application delays: Inconsistent information can slow down visa or stay permit processing.
- Immigration investigation: Authorities may review whether the director’s actual activities match the approved permit.
- Permit cancellation: Authorities may revoke a stay permit if the holder is found to be using the wrong immigration basis.
- Deportation risk: Serious immigration violations can result in removal from Indonesia.
- Future application issues: Previous non-compliance may complicate future visa or stay permit applications.
- Compliance exposure: Misaligned immigration, corporate, and workforce records can also create issues for the sponsoring company.
The safer approach is to confirm the correct KITAS route before the director begins activities in Indonesia.
Ascentium Indonesia offers expert assessment to support your company in choosing the correct visa route, helping you feel reassured and supported in maintaining compliance before filing. Talk to our team ->
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Ascentium Indonesia Can Secure the Right KITAS for Your Company Director
Determining the right director KITAS involves more than submitting an immigration application. The director’s visa, shareholding, corporate position, sponsor documentation, and workforce requirements must be aligned.
InCorp Indonesia (an Ascentium Company) supports foreign companies and PT PMA with:
- Investor KITAS assessment and applications
- E25B and other appropriate work-visa arrangements
- RPTKA and foreign-worker compliance assessment
- Corporate and immigration document alignment
- Application support from preparation through submission
Unsure whether your company director should use E28A, E25B, or another route? Talk to our immigration experts before filing. Fill out the form below for a free consultation. *
*T&C apply.
Frequently Asked Questions
What KITAS should a foreign company director use in Indonesia?
A qualifying shareholder-director may use the E28A Investor KITAS. A foreign director who doesn't meet E28A requirements may need the E25B Company Director Work Visa. Ascentium Indonesia can assess the appropriate route before filing.
What is the minimum shareholding for an Investor KITAS?
E28A currently requires at least IDR 10 billion in shares in the sponsoring company.
Can a director with less than IDR 10 billion in shares apply for E28A?
No. Current Immigration guidance states that a director or commissioner below the IDR 10 billion shareholding threshold should apply for a work visa corresponding to the position.
What is E25B in Indonesia?
E25B is the current work visa classification specifically for a Company Director or Executive Board Member.
Can an Investor KITAS holder act as a company director?
Yes. E28A expressly allows a qualifying investor to serve as a director or commissioner in the company where the investment is made.
Can an E28A director supervise company operations?
E28A permits the holder to supervise the production of goods or services at the company in which they invest, subject to the visa-permitted scope.
Does every foreign director need an RPTKA?
Not necessarily. Government Regulation No. 34/2021 provides RPTKA exemptions for certain directors, commissioners, and shareholders. The company should confirm whether the exemption applies to the individual case.
How long is an Investor KITAS valid?
E28A currently offers a one-year or two-year stay period and can be extended subject to the applicable requirements.
Should a director change KITAS after their shareholding changes?
Potentially. If the new ownership position no longer supports the existing visa category, the company should reassess the immigration route before the director continues operating under the same arrangement.
Can Ascentium Indonesia handle a director KITAS application?
Yes. Ascentium Indonesia can assess E28A or E25B eligibility, review company and applicant documents, coordinate applicable workforce requirements, and support the immigration application from preparation through submission.
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Disclaimer
The information is provided by PT. Cekindo Business International (“InCorp Indonesia/ we”) for general purpose only and we make no representations or warranties of any kind.
We do not act as an authorized government or non-government provider for official documents and services, which is issued by the Government of the Republic of Indonesia or its appointed officials. We do not promote any official government document or services of the Government of the Republic of Indonesia, including but not limited to, business identifiers, health and welfare assistance programs and benefits, unclaimed tax rebate, electronic travel visa and authorization, passports in this website.
Verified by
Hotdo Nauli
Senior Legal & Delivery Manager at InCorp Indonesia
Hotdo heads the Legal and Delivery team at InCorp Indonesia, managing Product Registration, Legal Advisory, and Business Licensing. With over 8 years of experience, she focuses on compliance and integrity, ensuring all client operations align with Indonesian laws and regulatory standards, including contract reviews and sector-specific licenses. She is also a licensed advocate and a member of the Indonesian Advocates Association (PERADI).
