Indonesia Increases Scrutiny of Indonesian Language Training for Foreign Workers, With Mandatory Language Testing on the Horizon
Updated: 1 hour ago
JAKARTA, 10 November 2026 – Indonesia’s Ministry of Manpower (MoM) has begun placing greater emphasis on employers’ compliance with the Indonesian language education and training obligation for foreign workers, signalling closer scrutiny of an existing requirement even though the formal work permit application procedure has not changed. Under the current framework, employers must facilitate Indonesian language education and training for foreign workers, either independently or in cooperation with an approved educational institution or Indonesian language training institution. The obligation is set out in Article 7(2) of Minister of Manpower Regulation No. 8 of 2021 (Permenaker 8/2021), which implements Government Regulation No. 34 of 2021 (PP 34/2021) on the Use of Foreign Workers; the consolidated text is available through the MoM’s official JDIH regulatory database, and Article 30 of PP 34/2021 confirms that training may be delivered by the employer itself or through cooperation with an education or language training institution.
The Legal Obligation and the Exemption Categories
The training obligation applies to all foreign workers employed in Indonesia, with a defined set of exemptions. Under Permenaker 8/2021, the following categories are exempt from the requirement: directors and commissioners, heads of representative offices, members of governing, executive, and supervisory boards, and foreign workers undertaking temporary work. The exemption for directors and commissioners is tied to their position as stated in the company’s deed of establishment, and separate provisions exclude foreign workers engaged in after-sales service and impresariat services from certain accompanying requirements. For employers, the practical consequence is that the obligation attaches to the general foreign workforce—engineers, specialists, technicians, and other non-exempt roles—rather than to the most senior governance positions.
The training itself is structured around Bahasa Indonesia for Foreign Speakers (BIPA) programmes, which are the standard vehicle for Indonesian language instruction for non-native speakers. Employers may deliver the training in-house or outsource it to an accredited institution, but the obligation is on the employer to ensure that training is actually provided and that the institution meets applicable accreditation requirements. This dual pathway gives employers flexibility, but it also means that an employer that neither runs its own programme nor contracts with an accredited provider is non-compliant, regardless of whether the worker is otherwise performing well.
The Compliance Risk: Administrative Sanctions and Renewal Scrutiny
The consequence of non-compliance is not merely reputational. Under Permenaker 10/2018 on the Use of Foreign Workers, the Ministry of Manpower may impose administrative sanctions ranging from delay of services and temporary suspension of the foreign worker licensing process to revocation of the notification and other measures permitted by law. The MoM’s official JDIH guidance on sanctions states explicitly that temporary suspension of the foreign worker licensing process is imposed where an employer “does not facilitate Indonesian language education and training for foreign workers”. In other words, the failure to provide training can directly disrupt an employer’s ability to obtain or renew work permits—a serious operational risk for companies that depend on foreign specialists.
The current enforcement posture adds a second layer of risk: scrutiny at the renewal stage. Although employers are not currently required to submit proof of training completion with their work permit applications, compliance may be tested through officer questioning during renewal rather than through documentary submission. This mode of scrutiny places a premium on accurate records and workers who can speak credibly about their training. Employers that have treated the training obligation as a formality, without maintaining documentation, are therefore exposed if an officer probes the arrangement during a renewal. Employers should therefore retain records of training arrangements, enrolment, attendance, and completion, and should prepare foreign workers to answer related questions during work permit renewals.
The Direction of Travel: Mandatory Language Testing From 2027
The scrutiny increase is occurring against a backdrop of planned regulatory reform that would go further than the current training obligation. The Ministry of Manpower has been preparing a revision to the foreign worker regulations that would introduce a mandatory Indonesian language proficiency test for foreign workers. Reporting by ANTARA News in October 2026 quoted the Minister of Manpower stating that the revision is expected to be completed by February 2027, after which the language proficiency test could be implemented for foreign workers seeking to work in Indonesia. The test materials are being developed with Universitas Indonesia’s language development body, and the proficiency level is expected to be determined using a TOIFL (Test of Indonesian as Foreign Language) score or an equivalent standard.
Separate analyses of the compliance landscape point to the UKBI (Uji Kemahiran Berbahasa Indonesia) framework as the likely benchmark, with Marginal (A2) level or an equivalent BIPA 2 standard identified as the minimum for basic workplace communication and comprehension of safety instructions. The two standards—TOIFL and UKBI—are not mutually exclusive; both measure Indonesian proficiency against a level scale, and the regulatory revision will ultimately designate the applicable instrument and threshold. For employers, the trajectory is clear: the training facilitation obligation is likely to be supplemented by a demonstrable proficiency requirement, shifting compliance from “we provided training” to “the worker can demonstrate a defined level of Indonesian.” The Ministry’s official regulatory portal and the Kemnaker main site are the authoritative sources for the revised regulation when it is issued.
What Employers Should Do Now
Employers should review their compliance arrangements and identify which foreign workers are subject to the training obligation, distinguishing exempt categories (directors, commissioners, board members, representative office heads, temporary workers) from the general workforce. They should then facilitate appropriate training for non-exempt workers, either in-house or through an accredited BIPA provider, and confirm that the provider meets the applicable accreditation requirements. Employers should also retain records of the training arrangement, enrolment, attendance, and completion—not because these records must be submitted today, but because they may be requested or discussed at renewal. Finally, they should prepare foreign workers to answer questions about their training during renewal interviews, which means ensuring that workers can describe the programme, its duration, and what they learned.
Employers with mixed workforces—some exempt, some not—should document the basis for each exemption so that the distinction is defensible if questioned. Employers that use in-house training should ensure that the programme is substantive and documented, rather than nominal. Employers that rely on third-party providers should verify accreditation and retain the cooperation agreement, enrolment confirmations, and completion certificates. Given the February 2027 target for the regulatory revision, employers should also begin planning for proficiency testing by assessing the current Indonesian language levels of their non-exempt foreign workers and identifying those who may need additional instruction before a test becomes mandatory.
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Key Points at a Glance
Aspect | Detail |
Legal basis for training obligation | Article 7(2), Permenaker 8/2021, implementing PP 34/2021 |
Delivery options | Employer-run training or cooperation with accredited education/language institution |
Exempt categories | Directors, commissioners, heads of representative offices, board members, temporary workers |
Current application requirement | Proof of training completion not required with work permit applications |
Sanction for non-compliance | Temporary suspension of foreign worker licensing process, among other administrative sanctions |
Renewal risk | Officers may question workers about training arrangements; records should be retained |
Planned reform | Mandatory language proficiency test targeted for completion around February 2027, likely using TOIFL or UKBI (A2/BIPA 2) standards |
Conclusion
Indonesia’s increased scrutiny of the Indonesian language training obligation is a compliance signal, not a procedural change. The obligation itself has existed since Permenaker 8/2021, and the sanctions for non-compliance—including suspension of the licensing process—are already on the books. What is changing is the intensity of enforcement attention, with renewal-stage questioning and record retention becoming practical requirements even without a documentary submission mandate. The larger shift is coming in 2027, when the Ministry of Manpower intends to move from training facilitation to demonstrable proficiency, likely through a TOIFL or UKBI-based test. Employers that treat the current period as an opportunity to build robust training records and raise their workers’ language levels will be better positioned when the proficiency requirement takes effect. The authoritative references are the MoM’s JDIH portal for the regulations and Kemnaker for policy announcements.
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