A foreign investor setting up a PT PMA in Indonesia recently discovered a gap that many encounter too late. Their company was fully incorporated with paid-up capital of IDR 2.5 billion, compliant with BKPM Regulation No. 5 of 2025, and all licenses were in order. When they approached an immigration consultant to apply for an Investor KITAS, they learned for the first time that their personal shareholding of IDR 3 billion, while sufficient at the corporate level, fell short of the IDR 10 billion minimum required for the E28A permit. The restructuring that followed added four months to their timeline and required a notarial amendment to their company deed before the immigration process could begin.
This gap between the corporate capital threshold and the immigration threshold is the most common planning failure for foreign investors entering Indonesia. The two thresholds are governed by entirely separate regulatory frameworks and assessed by different government bodies. Understanding both, and how they interact, is essential before any incorporation or investment decision is finalized.
This guide covers the eligibility requirements, document checklist, step-by-step application process, the Director versus Commissioner distinction, and the scenarios most likely to result in rejection.
What the Investor KITAS Is and Who It Is For
The Investor KITAS, formally known as the Kartu Izin Tinggal Terbatas (Temporary Stay Permit) index E28A, is a stay permit issued to foreign nationals who hold a substantial personal equity position in an Indonesian foreign investment company (Perseroan Terbatas Penanaman Modal Asing or PT PMA) and actively participate in the company’s management as a Director or Commissioner.
It is governed by Minister of Law and Human Rights (Peraturan Menteri Hukum dan Hak Asasi Manusia or Permenkumham) No. 22 of 2023 on Visas and Residence Permits, as amended by Permenkumham No. 11 of 2024 and partially revised by Permenkumham No. 3 of 2025. These regulations sit entirely within the immigration framework and are administered by the Directorate General of Immigration (Direktorat Jenderal Imigrasi or Ditjen Imigrasi), not by the Investment Coordinating Board (Badan Koordinasi Penanaman Modal or BKPM).
The permit is designed for investors who are physically present in Indonesia to run their business, not for passive shareholders living abroad. This operational intent is reflected in the eligibility criteria, the role requirements, and the document verification process.
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The Capital Threshold: What Determines Eligibility
Two separate thresholds apply when a foreign investor establishes a PT PMA and intends to live in Indonesia. The minimum paid-up capital to incorporate a PT PMA under BKPM Regulation No. 5 of 2025 is IDR 2.5 billion. The minimum personal shareholding required to qualify for an Investor KITAS under Permenkumham No. 11 of 2024 is IDR 10 billion, registered directly under the applicant’s individual name.
These two figures are governed by separate regulatory frameworks and assessed by different government bodies. A company fully compliant at the corporate level may still have a shareholder who does not qualify for the Investor KITAS if their individual equity position has not reached IDR 10 billion. The personal shareholding cannot be held through a nominee, a holding vehicle, or a third party.
For a detailed explanation of how the IDR 10 billion threshold interacts with DKP TKA exemptions, the E28 visa category structure, and the lock-up period requirements, XPND has covered this in a dedicated guide on Investor KITAS exemption from DKP TKA fees and minimum shareholding requirements.
Director vs Commissioner: What Each Role Permits
The Investor KITAS index E28A can be held by both Directors and Commissioners of a PT PMA, but the two roles carry different rights under the permit.
A Director who holds an Investor KITAS is permitted to perform work activities within the company. This includes signing contracts, directing operational staff, managing day-to-day business, conducting meetings, and representing the company in its commercial activities. Directors under an Investor KITAS do not require a separate Work Permit (Izin Mempekerjakan Tenaga Kerja Asing or IMTA), which distinguishes this permit from the Working KITAS pathway.
A Commissioner who holds an Investor KITAS is permitted to reside in Indonesia and participate in supervisory and governance activities. Commissioners under an Investor KITAS are not permitted to perform operational or employment-like activities within the company. If a Commissioner also intends to work within the company, they require an additional Work Permit and a Working KITAS to cover those activities, in addition to meeting the separate IDR 10 billion shareholding requirement.
This distinction matters most for founders who hold both a directorship and a commissariat position in their company. The immigration authority assesses the primary role stated in the company deed when processing the application. Misalignment between the declared role and actual activity is one of the more common reasons Investor KITAS applications face scrutiny.
For a broader comparison of all KITAS types including Work KITAS and how it differs from Investor KITAS, XPND’s guide on types of KITAS in Indonesia covers each classification with its eligibility criteria.
Eligibility Requirements
To qualify for an Investor KITAS index E28A under the current regulatory framework, an applicant must meet all of the following:
Personal shareholding. A minimum of IDR 10 billion registered directly under the applicant’s personal name in the PT PMA’s company deed and shareholder register. This must be verifiable through the immigration authority’s cross-reference with OSS RBA system data.
Corporate role. The applicant must be listed as a Director or Commissioner in the most current notarial deed of the sponsoring PT PMA.
Active company status. The sponsoring PT PMA must hold a valid Business Identification Number (Nomor Induk Berusaha or NIB) issued through OSS RBA, all applicable business licenses for its KBLI classification, and must be active and compliant in its LKPM (Laporan Kegiatan Penanaman Modal or Investment Activity Report) submissions.
Valid passport. Minimum six months validity from the application date.
Health insurance. Valid health insurance coverage in Indonesia for the full duration of the requested permit validity.
Clean immigration record. No prior overstay, deportation, or immigration violation in Indonesia.
BKPM recommendation. A formal recommendation from BKPM through the OSS RBA system is required before the immigration authority processes the Limited Stay Visa (Visa Izin Tinggal Terbatas or VITAS).
Document Checklist
The following documents are required for an Investor KITAS application. All foreign-language documents must be accompanied by a certified Indonesian translation.
Personal documents:
- Valid passport with minimum six months remaining validity
- Recent passport-sized photographs with white background
- Curriculum vitae or professional profile
- Health insurance policy valid in Indonesia
Company documents:
- Most current notarial deed showing the applicant as Director or Commissioner and reflecting the IDR 10 billion personal shareholding
- Company shareholder register (Daftar Pemegang Saham) notarized and current
- NIB from OSS RBA
- All applicable business licenses (Izin Usaha) for the company’s KBLI classification
- Most recent LKPM submission confirmation
- Company Tax Identification Number (Nomor Pokok Wajib Pajak or NPWP)
- Domicile letter or virtual office agreement as proof of registered company address
Immigration documents:
- BKPM recommendation letter issued through OSS RBA
- Sponsor letter from the PT PMA
- Power of attorney if applying through a representative
Step-by-Step Application Process
The Investor KITAS application follows a defined sequence involving three separate systems: OSS RBA for the BKPM recommendation, the e-Visa portal for visa processing, and the local immigration office for permit issuance.
Step 1: Corporate structure verification
Before any application is submitted, the shareholding structure must be verified against the IDR 10 billion threshold. This means reviewing the most current notarial deed, confirming that the personal shareholding is registered under the applicant’s name, and ensuring the company’s OSS RBA data is consistent with the deed. Any discrepancy between the deed and the OSS data creates a verification failure that will halt the application.
Step 2: BKPM recommendation through OSS RBA
The sponsoring PT PMA submits a recommendation request through the OSS RBA system. This step generates a formal BKPM recommendation letter that identifies the applicant as a foreign investor authorized to apply for an Investor KITAS. The OSS RBA submission requires the company’s NIB, the applicant’s passport details, and the shareholding documentation. Processing typically takes three to seven working days.
Step 3: Limited Stay Visa (VITAS) application
With the BKPM recommendation in hand, the applicant applies for a VITAS through the Directorate General of Immigration’s e-Visa portal at evisa.imigrasi.go.id. The VITAS is a single-entry visa that allows the applicant to enter Indonesia for the purpose of converting to a KITAS. For applicants applying from abroad, this step is completed online before arrival. For applicants already in Indonesia on a valid stay permit, the VITAS can be applied for onshore under certain conditions.
Step 4: Entry and KITAS conversion
Upon arrival in Indonesia using the VITAS, the applicant must report to the local immigration office within 30 days to complete the KITAS conversion. This step involves biometric registration (fingerprints and photograph), submission of the physical document package, and payment of the applicable immigration fees. The immigration office issues a receipt and processes the KITAS, which is collected once ready.
Step 5: Multiple Re-Entry Permit (MERP)
After the KITAS is issued, the holder must apply for a Multiple Re-Entry Permit (MERP) if they intend to travel outside Indonesia and re-enter during the permit’s validity period. A KITAS without an active MERP functions as a single-exit permit, meaning departure from Indonesia without an MERP cancels the permit’s validity.
Processing timeline
From the start of the BKPM recommendation step to KITAS issuance typically takes four to eight weeks for a straightforward application. Applications involving shareholding gaps that require deed amendments or OSS data corrections can extend this timeline by one to three months. Companies that are not current on LKPM filings face delays at the BKPM recommendation stage and must resolve outstanding reports before the recommendation can be issued.
Validity and Renewal
An Investor KITAS index E28A can be issued with a validity period of one year or two years. The two-year option reduces the frequency of renewal processing and is generally more cost-effective over time.
The permit is renewable, and the renewal process follows the same sequence as the initial application with a reduced document set since the company structure is already on record. Renewals are processed through the e-Visa portal and the local immigration office.
After holding an Investor KITAS consecutively for the minimum qualifying period with the same sponsor, the holder becomes eligible to apply for an Investor KITAP. For a full explanation of the KITAP conversion process, timeline, and shareholding requirements, refer to XPND’s guide on KITAS and KITAP requirements and how to upgrade.
The Most Common Reasons Applications Are Delayed or Rejected
Shareholding below IDR 10 billion at the time of application
This is the most frequent issue and the one with the most significant downstream impact. Correcting it requires a notarial deed amendment, updated OSS data, and restarting the BKPM recommendation process.
OSS data inconsistency
The shareholding figures in the company deed do not match what the OSS RBA system shows for the company. This cross-verification failure is caught at the BKPM recommendation stage. Resolving it requires a data update through OSS and confirmation from the Ministry of Law’s SABH system, which adds time.
Outdated LKPM filings
Companies that are behind on quarterly LKPM submissions cannot obtain a BKPM recommendation for an Investor KITAS application. All outstanding reports must be submitted and confirmed before the recommendation process can proceed.
Role mismatch
The role declared in the company deed does not match what the applicant is actually performing. This typically surfaces during the immigration interview or document review and triggers a request for clarification.
Company license issues
The sponsoring PT PMA has expired or incomplete business licenses. The immigration authority verifies active license status as part of the BKPM recommendation check.
How XPND Supports the Investor KITAS Process
The Investor KITAS application sits at the intersection of corporate law, investment regulations, and immigration compliance. Errors in any one area propagate across all three, which is why XPND’s approach begins with an assessment of the shareholding structure before any application steps are taken.
At XPND, our immigration team reviews the applicant’s corporate position, verifies that the OSS RBA data aligns with the notarial deed, confirms LKPM compliance, and structures the BKPM recommendation submission before anything is filed with the immigration authority. For investors whose shareholding is currently below IDR 10 billion, we assess the restructuring options and coordinate the deed amendment and OSS update process so the immigration application starts from a position that will pass verification.
Most delays and rejections in Investor KITAS applications are not caused by the immigration process itself. They are caused by issues that should have been identified and resolved before the first document was submitted. The shareholding gap, the OSS data inconsistency, the outstanding LKPM, the role mismatch between the deed and the intended activity: all of these are knowable in advance. XPND’s engagement begins at that stage, not at the submission stage.
Investors who want to understand where they currently stand before committing to a timeline can reach out to the XPND team at info@xpnd.co.id for an initial assessment.
