Client Newsflash

Updated List of Restricted Positions for Expatriates

On December 31, 2019, the Minister of Manpower (“MOM”) enacted Decree No. 349 of 2019 on Certain Positions Restricted for Expatriates (“Decree 349”).  Decree 349 revokes and replaces Decree No. 40 of 2012 dated February 29, 2012 concerning the same matter (“Decree 40”). Decree 349 sets out 18 positions restricted for expatriates while Decree 40 listed 19 positions. The single difference between both decrees is that Decree 349 removes the Chief Executive Officer position from the restricted positions list. Therefore, 18 positions listed under Decree 349 is the same as the remaining positions listed under Decree 40.

Note that Decree 349 is not the implementation of Article 42(5) of Law No. 13 of 2003 dated March 25, 2003 on Manpower that provides positions that are available for expatriates. The compilation of the positions available for expatriates are set out under Decree No. 228 of 2019 dated August 27, 2019 on Certain Positions Available to Expatriates (“Decree 228”).

In addition to reference to the International Standard Classification of Occupations (“ISCO”), Decree 349 refers to the Indonesian Standard Classification of Occupations (Klasifikasi Baku Jabatan Indonesia or “KBJI”). The updated list of restricted positions for expatriates set out in Decree 349 is as follows:

No. ISCO/KBJI Code Position
1 1210 Personnel Director
2 1232 Industrial Relations Manager
3 1232 Human Resources Manager
4 1232 Personnel Development Supervisor
5 1232 Personnel Recruitment Supervisor
6 1232 Personnel Placement Supervisor
7 1232 Employee Career Development Administrator
8 4190 Personnel Declare Administrator
9 2412 Personnel and Careers Specialist
10 2412 Personnel Specialist
11 2412 Career Advisor
12 2412 Job Advisor
13 2412 Job Advisor and Counseling
14 2412 Employee Mediator
15 4190 Job Training Administrator
16 2412 Job Interviewer
17 2412 Job Analyst
18 2412 Occupational Safety Specialist

February 17, 2020

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