IMPACT – HIGH

What is the change? The Directorate General of Immigration has announced that immigration authorities will no longer accept submissions by third parties, such as immigration agents working on behalf of companies.

What does the change mean? The order will require that companies file applications themselves with the immigration authorities, as they will not be able to use third-party assistance. Filings with the Ministry of Manpower or other agencies in the work permit process are not affected.

The order was issued Nov. 7 without notice. Employers and immigration agents are in discussions with the directorate about the negative impact of the rule. As such, implementation currently varies among the regional authorities, and most authorities are following local policies to continue to allow third-party assistance for the time being.

  • Implementation time frame: Immediate and ongoing. Regional authorities are providing temporary grace periods.
  • Visas/permits affected: Work permits.
  • Who is affected: Employers and foreign nationals submitting applications to local immigration authorities.
  • Impact on processing times: Companies should plan for longer timelines, as they will need to create their own online accounts on the immigration portal before filing applications.
  • Business impact: Companies should be prepared to appoint their own representative to conduct filings and other matters with immigration authorities.
  • Next steps: Employers will need to open their own account in the Dirjen immigration system, the central online portal, before filing applications and in order to complete the telex visa process used by immigration authorities to preapprove issuance of an entry visa by an Indonesian consulate. B·A·L can assist in creating the account.

B·A·L Analysis: The business community and immigration agents continue to engage with the directorate for alternatives to an absolute ban on third-party representation. B·A·L will update clients on any changes or developments from these discussions.

This alert has been provided by the BAL Global Practice group and our network provider located in Indonesia. For additional information, please contact your BAL attorney.

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