Most foreign executives operating in Indonesia know, in the abstract, that immigration authorities have the power to prevent people from leaving or entering the country. What few have mapped in concrete detail is how that power is structured, what triggers it, and at what point a compliance failure in one area of their business can produce an immigration consequence in another. That mapping matters now more than it did before December 2025.

On 16 December 2025, Permenimipas No. 13 of 2025 on the Implementation of Exit Bans and Entry Prohibitions came into force, replacing the prior ministerial regulation and establishing the operational procedures under the strengthened framework of Law No. 63 of 2024 on Immigration. A further administrative update, Permenimipas No. 1 of 2026, was promulgated on 24 April 2026 to align two definitional terms with the ministry’s reorganized structure. Neither regulation changes who can be subject to these measures. Together, they represent the complete and currently operative framework governing every travel restriction and entry prohibition that Indonesia’s immigration authorities can impose.

Two Instruments, Clearly Defined

Permenimipas 13/2025 operates through two legally distinct instruments. Their definitions in Article 1 establish the boundaries precisely.

  • Pencegahan (exit ban) is a temporary prohibition against a person, whether an Indonesian national or a foreign national, leaving Indonesian territory. The basis may be an immigration reason or any other reason established by law.
  • Penangkalan (entry prohibition) is a prohibition against a foreign national entering Indonesian territory, based on immigration reasons. It is applied at all checkpoints through the SIMKIM (Sistem Informasi Manajemen Keimigrasian, or Immigration Management Information System) database.

The two instruments operate independently. A person can be subject to an exit ban without any entry prohibition, and vice versa. A foreign national already inside Indonesia can face an exit ban preventing departure at the same time as an entry prohibition prevents re-entry if they do leave.

Who Has Authority to Impose an Exit Ban

Article 3 of Permenimipas 13/2025 distributes exit ban authority across multiple government agencies, each acting within their own statutory mandate. The Minister of Immigration and Penitentiary holds primary authority and responsibility for immigration-based exit bans, but the Minister acts on the basis of decisions, orders, or requests from:

  • The Minister of Finance and the Attorney General, each within their respective jurisdictions
  • The Chief of the National Police (Kepala Kepolisian Negara Republik Indonesia)
  • The Chair of the Corruption Eradication Commission (Komisi Pemberantasan Korupsi or KPK)
  • The Head of the National Narcotics Agency (Badan Narkotika Nasional or BNN)
  • Heads of other ministries or agencies that hold statutory exit ban authority under specific laws

Each of those agencies is individually responsible for the exit ban decisions they initiate. The data they submit must be complete, accurate, and consistent. If it is not, the Directorate General of Immigration may reject the request and communicate the specific grounds for rejection.

The practical consequence of this multi-agency structure is that an exit ban can be imposed on a foreign national or a company director for reasons that have nothing to do with their immigration status. An executive under investigation for tax matters at the request of the Ministry of Finance, a company director named in a KPK corruption inquiry, or an individual caught in a BNN narcotics investigation can all find their exit from Indonesia restricted without any immigration violation being alleged. This is the connection that most compliance reviews miss: the payroll, tax, and regulatory compliance record of the company is not separate from the immigration risk profile of its individual executives.

Duration of Exit Bans

Article 4 sets the maximum duration at six months per period, renewable for a further six months. If no renewal decision is submitted before the current period expires, the exit ban terminates by operation of law. The renewal request must reach the Directorate General no later than three days before the existing period ends, per Article 13(5). A request submitted after that window causes the exit ban to lapse automatically, with no grace period.

The Emergency Exit Ban Mechanism

Article 9 of Permenimipas 13/2025 formalizes a procedure that significantly narrows the window between a decision to restrict travel and its physical execution at a departure checkpoint.

In urgent, pressing, or sudden circumstances, an authorized official may submit a direct request to the immigration officer at a checkpoint (Tempat Pemeriksaan Imigrasi, or immigration inspection point) to impose an exit ban immediately, without waiting for the standard application process. The request can be submitted electronically or non-electronically, and must include the subject’s name, gender, nationality, date of birth, photo, and the reason for the emergency measure.

Once the emergency request is accepted at the checkpoint, the subject’s details are entered into the immigration database and the restriction becomes active across all checkpoints simultaneously. The requesting authority then has twenty days to submit formal follow-up documentation through the official application system. If that follow-up is not submitted within twenty days, per Articles 9(6) and 9(7), the emergency exit ban terminates by operation of law and cannot be resubmitted.

For a foreign executive planning international travel during a period when their company or personal affairs are under scrutiny by any of the agencies with exit ban authority, this mechanism means the restriction can be applied at the departure gate before any formal administrative process has been completed.

Article 12 adds a further operational consequence: once a person appears on the exit ban list, the immigration officer is required to confiscate their travel document. For Indonesian nationals with diplomatic or service passports, the Minister of Foreign Affairs holds responsibility for the confiscation. The travel document is not returned until the exit ban is lifted.

Entry Prohibitions: The Three-Tier Structure

The entry prohibition framework in Permenimipas 13/2025 is considerably more detailed than many practitioners realize. Article 18 does not set a single maximum duration but instead establishes three distinct tiers based on the ground for the prohibition.

Five Years

A five-year entry prohibition applies in cases of:

  • Deportation from Indonesian territory as a result of an administrative immigration enforcement action
  • Overstay without payment of the applicable surcharge under the non-tax state revenue regulations of the Ministry of Immigration and Penitentiary
  • Other reasons as determined by the Minister

Ten Years

A ten-year entry prohibition applies in cases of:

  • Known or suspected involvement in organized transnational crime
  • Suspected conduct contrary to Indonesian public order, decency, religion, or social custom
  • Criminal conviction with a sentence of up to five years imprisonment
  • Other reasons as determined by the Minister

Lifetime

A lifetime entry prohibition can be imposed for:

  • Showing hostility toward the Indonesian government or committing acts that damage the reputation of the Indonesian nation and state
  • Using a forged or falsified passport to obtain a visa or residence permit
  • Reasons of national security or state sovereignty
  • Terrorism, radicalism, or infectious disease
  • Mental disorder, sexual crimes or violence, narcotics involvement, human trafficking, or people smuggling
  • Attempting to evade the execution of a sentence in the subject’s home country
  • Criminal conviction with a sentence exceeding five years imprisonment
  • Other reasons as determined by the Minister

The breadth of the lifetime category is notable. It covers conduct that extends well beyond what most foreign nationals associate with immigration enforcement. A conviction in any jurisdiction, a finding of involvement with narcotics at any level, or a formal determination by Indonesian authorities of hostility toward the government are each sufficient grounds for a permanent entry prohibition. The “other reasons as determined by the Minister” provision in all three tiers adds a residual discretionary element that is unreviewable in advance.

How Entry Prohibitions Are Initiated and Executed

Article 17 specifies four sources from which an entry prohibition request can originate: immigration officials within the Directorate General’s structure, heads of other ministries or agencies, foreign state representatives, and the International Court of Justice. The grounds applicable to requests from ministries and agencies are separately specified in Article 17(5) and include national security, terrorism, infectious disease, radicalism, mental disorder, sexual crimes, narcotics, human trafficking, and people smuggling.

Once a request is received and the Directorate General confirms it is complete and accurate, the Directorate General issues the entry prohibition decision on behalf of the Minister and enters the subject’s identity into the SIMKIM database. The restriction then applies at every immigration checkpoint in Indonesia simultaneously. If the digital entry into SIMKIM cannot be completed immediately, the list is distributed manually to all technical implementation units and Indonesian diplomatic posts abroad until the digital update is made.

An entry prohibition imposed on immigration grounds, such as following a deportation, can be lifted through a formal sponsorship mechanism under Article 26. A guarantor, either an individual or a corporation, can submit a written request for revocation to the Directorate General, accompanied by a stamped declaration and guarantee letter, identification of both the guarantor and the subject, and, for corporate guarantors, the company’s deed of incorporation and supporting data. This sponsorship route is only available for entry prohibitions imposed on immigration grounds, not for those imposed on national security, criminal, or public order grounds.

The Compliance Intersection That Foreign Companies Cannot Ignore

The operational architecture of Permenimipas 13/2025 creates a direct and documented link between a company’s regulatory compliance position and the travel freedom of its directors and expatriate personnel.

A company with unresolved tax assessments from the Directorate General of Taxes (Direktorat Jenderal Pajak or DJP) creates the conditions under which the Ministry of Finance may request an exit ban against the company’s responsible directors. A company whose activities have attracted attention from the KPK creates the conditions for a KPK-ordered exit ban. A PT PMA with gaps in social security enrollment through the National Social Security Administration (Badan Penyelenggara Jaminan Sosial or BPJS) or outstanding administrative violations may see those gaps escalate through the relevant ministry before reaching the immigration channel.

None of these pathways require the individual being restricted to have personally committed any immigration violation. The restriction is a consequence of the company’s compliance position, administered through its directors.

The work permit compliance framework that sits alongside this, covering the Foreign Worker Utilization Plan (Rencana Penggunaan Tenaga Kerja Asing or RPTKA), the Limited Stay Permit (Kartu Izin Tinggal Terbatas or KITAS), and the conditions that must be met for foreign personnel to hold valid work authorizations, intersects with the entry prohibition mechanism at the deportation point. A foreign national who is deported faces a minimum five-year entry prohibition under Article 18(a). For companies whose foreign personnel have any irregular documentation or overstay exposure, the deportation-to-entry-prohibition pathway is a concrete risk, not a theoretical one. The documentation requirements and compliance conditions for foreign work permits are addressed in the guide to Indonesia work permit requirements for 2026, which covers the pre-conditions that prevent a foreign executive’s departure from becoming a deportation event.

For directors and executives whose companies are managing active compliance gaps across DJP, BPJS, or other regulatory areas, the annual tax reporting compliance framework for Indonesia is the starting point for understanding where those gaps sit in relation to the agencies that hold exit ban authority.

XPND’s immigration compliance team advises on the full intersection between corporate regulatory compliance and individual immigration risk, including the conditions under which exit ban requests are most likely to be initiated and what remediation steps are available at each stage of the process.

Reach out to XPND’s immigration team to map your company’s current compliance position against the exit ban and entry prohibition risk framework before an unresolved regulatory issue creates a travel restriction that was not anticipated.