Company Regulations in Indonesia: When a Handbook Must Be Filed
Company regulations in Indonesia are required once you employ ten people. What goes in them, who ratifies them, and the renewal date.
References (6)
- UU No. 13 Tahun 2003 on Manpower — Article 108(1), company regulations at ten employees and effective on ratification; Article 108(2), the exemption where a collective labour agreement exists. Article 109, drawn up by the employer; Article 110, the employees' representatives; Article 111, the contents, the bar on falling below the law and the two-year term. Article 112, ratification within 30 working days, and deemed ratification; Article 113, a change during the term. Article 114, telling staff and giving them the text; Articles 116, 123, 129 and 132, the collective labour agreement
- UU No. 6 Tahun 2023 — Article 81, which amends the Manpower Law in 71 points. Point 69 replaces Article 188, the fine; point 70 replaces Article 190, the administrative sanctions list. Articles 108 to 135 are not among the provisions it amends; Article 77(4) on working hours and Article 154A(1)(k) on warning letters are among those it does
- Permenaker No. 28 Tahun 2014 — Article 2(2), the six contents; Article 2(5), no lower than the law; Article 3, one document per company and one for each company in a group. Article 4, the representatives' views and that they cannot be disputed; Article 6, seven working days; Articles 7 and 8, who ratifies and the two documents filed. Article 8(5) and Article 10(2), the office's own clocks; Article 12, a change during the term; Article 13(1), renewal filed 30 working days before expiry. Articles 30 and 31, registering a collective labour agreement; Article 33, the online service
- UU No. 1 Tahun 2026 on adjusting criminal penalties, in force 2 January 2026 (Pasal IX) — Pasal I(1), special minimum penalties outside the Criminal Code deleted; Lampiran I No. 175, Article 188 of the Manpower Law now a fine of up to category V. UU No. 1 Tahun 2023 (the Criminal Code), Article 79(1), the fine categories
- PP No. 35 Tahun 2021 — Article 14(1), a fixed-term contract registered online within three working days of signing
- Constitutional Court decision No. 168/PUU-XXI/2023, 31 October 2024 — none of its operative points concerns Articles 108 to 135
Indonesian manpower law names three documents in which an employer sets terms of work: the employment contract, the company regulations (peraturan perusahaan) and the collective labour agreement (for example Article 77(4), as amended by UU 6/2023). An employee handbook is not one of them. Company regulations in Indonesia become compulsory once you employ ten people (Manpower Law, UU 13/2003, Article 108(1)). At that point the handbook you have already written stops being a choice about good practice. It becomes a document with a filing and a renewal date on it.
A new manpower law is in force
This page states the law as it stood on 5 November 2026. Since 28 October 2026, a new manpower law, UU 27/2026, has replaced the Manpower Law, UU 13/2003. The regulations made under the old law stay in force where they do not conflict with the new one (its Article 310). We are revising this page; our guide to the new manpower law sets out what it asks of employers. If a decision depends on it, ask us first.
Who needs company regulations in Indonesia
You already have a collective agreement
Then this does not reach you at all. The obligation falls away entirely for a company that already has a collective labour agreement, whatever its headcount (Article 108(2)).
Ten or more staff, no collective agreement
The law asks for a written set, and one set covers everybody — fixed-term and permanent people alike, with no distinction drawn between them (Article 108(1); Permenaker 28/2014, Article 3(1)).
Fewer than ten staff
The law does not require company regulations (Article 108(1)).
What company regulations are
A rulebook a company writes for itself is not, by itself, company regulations. Indonesia requires more. The employer draws the document up and answers for it (Article 109), having regard to the views of the employees’ representatives (Article 110). It takes effect only once the manpower office ratifies it (Article 108(1)).
One company has one set, and it applies across its branches (Permenaker 28/2014, Article 3(1)–(2)). Where a group has more than one Indonesian company, each company makes its own (Article 3(6)). Every employee has to be told what is in it, have it explained, and be given the text (Article 114).
The Manpower Law backs the duty with a fine (Article 188, as replaced by UU 6/2023; its ceiling was reset by UU 1/2026, in force from 2 January 2026). It is not among the breaches that Article 190 answers with administrative sanctions such as a suspension of business activity.
What goes in them
Five items come from the Law and a sixth from the implementing regulation. These are the minimum contents:
- the employer’s rights and duties
- the employees’ rights and duties
- the terms of work — the rights and duties legislation has not already settled
- the company’s rules of conduct
- how long the regulations run
- anything that gives further effect to legislation
(Article 111(1); Permenaker 28/2014, Article 2(2).)
Beyond those, the company chooses what to add, provided nothing falls below the law. This is one of the three documents in which working hours are set, and one of the three the warning-letter procedure rests on (Articles 77(4) and 154A(1)(k), as amended by UU 6/2023).
The document also sits next to rules the employer does not set — who may be hired, and how people are treated at work. Our guide to equal employment opportunity in Indonesia covers those.
The rule the whole document turns on
Company regulations may improve on the law, and may never fall below it. Where a provision is worse than the legislation, the legislation applies (elucidation to Article 111(2); Permenaker 28/2014, Article 2(5)).
Consulted, not negotiated
Where there is a union, its officers are the employees’ representatives; where there is not, the staff elect representatives themselves (Article 110(2)–(3)). If a union exists but does not have most of the workforce in membership, the employer hears from representatives of the non-members as well (Permenaker 28/2014, Article 4(5)).
Those representatives may give their views, and they may decline to give any (Article 4(2)). Either way the views cannot be made the subject of a dispute (Article 4(6)). The employer decides what the document says.
Changing the document before its term ends is different: it needs actual agreement. The Law requires the representatives’ agreement for that (Article 113(1)), the implementing regulation says so in terms where the change leaves people worse off (Permenaker 28/2014, Article 12(1)), and the changed text is ratified again (Article 113(2)).
From draft to renewal
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The draft is written
The employer draws the document up. It is the employer’s own instrument rather than an agreement with anybody (Article 109). The signed text is what gets filed (Permenaker 28/2014, Article 8(2)).
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Views are sought
The draft goes to the employees’ representatives. If nothing comes back within seven working days, the filing may go ahead, with proof that they were asked attached to it (Permenaker 28/2014, Article 6).
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Filed with the manpower office
The application carries two documents: the signed text, and proof that views were sought (Article 8(1)–(2)). It goes to the office for the area the company operates in, through the Ministry’s online service, brought in office by office (Articles 7(1) and 33(1)–(2)).
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The office reads it
It checks that the filing is complete and that nothing in the document falls below the law. The substance check takes at most six working days (Article 8(3)–(5)).
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Ratified, and only then binding
Ratification has to be given within thirty working days of the text being received (Article 112(1)). If the document meets the requirements and that window passes without a decision, it is deemed ratified (Article 112(2)).
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Renewed, at least every two years
A set runs for at most two years and is renewed when the term ends (Article 111(3)). The renewal is filed at least thirty working days before the current set expires (Permenaker 28/2014, Article 13(1)).
How a collective agreement differs
The third instrument is the collective labour agreement, or PKB (perjanjian kerja bersama). It can only be made with a registered trade union (Article 116(1)), so where there is no union the question does not arise. Where a collective agreement is in place, the duty to have company regulations does not apply (Article 108(2)).
| Company regulations | Collective labour agreement | |
|---|---|---|
| Who draws it up | The employer, alone (Article 109) | Negotiated with a registered trade union (Article 116(1)–(2)) |
| The employees’ part | Representatives give views, which cannot be disputed (Permenaker Article 4(6)) | The union is a party and signs it (Article 124(1)(d)) |
| Takes effect | On ratification (Article 108(1)) | On signature, unless it says otherwise (Article 132(1)) |
| The office’s act | Ratifies it — pengesahan (Article 112) | Registers it — pendaftaran — and notes any clause contrary to the law that the parties keep (Article 132(2); Permenaker Article 31(5)–(7)) |
| Term | Up to two years, then renewed (Article 111(3)) | Up to two years, extendable once by up to a year (Article 123(1)–(2); Permenaker Article 29(2)) |
| Relationship | Cannot replace a collective agreement while a union exists (Article 129(1)) | The duty to make company regulations does not apply (Article 108(2)) |
If you employ fewer than ten
Below ten employees nothing requires company regulations. Indonesia asks instead for the following, whatever the size of the business:
- a contract for each employee, written or oral except that a fixed-term contract must be written (Article 51(1); Article 57(1), as replaced by UU 6/2023), and where it is written it carries at least nine stated items (Article 54(1))
- a letter of appointment, where somebody permanent was taken on orally (Article 63)
- a wage structure and scale, which every employer must have (Article 92(1), as amended by UU 6/2023)
A handbook on top of that is good practice, and nothing about it is filed with the manpower office. Separately, the employer records each fixed-term contract with the Ministry online within three working days of signing (PP 35/2021, Article 14(1)).
What this means for you
Count the people you employ. Below ten, a handbook is a choice and a good one. At ten, the same material becomes a signed document with a ratification behind it and a date on it — and the date worth marking in the calendar falls thirty working days before the term runs out (two years at most).
If you already have a handbook, it is the starting point rather than wasted work; what it needs is to be put into the form the manpower office ratifies. Our HR consulting team reads what you have first, then drafts the company regulations and files them for approval. Which contract each role sits on is the layer underneath, and our note on employment contracts in Indonesia covers that.