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Investor KITAS E28A: Requirements and Work Limits

E28A is for an investor with a substantial, documented personal stake in a real PT PMA; incorporation alone does not qualify.

Who the E28A Investor KITAS Is For

An incorporation agent may offer an investor KITAS as the natural next step after setting up a PT PMA. That is a risky assumption. Immigration eligibility belongs to the person applying: their documented stake, the sponsoring company and the activities they intend to carry out all matter.

A PT PMA is an Indonesian company with foreign investment. Someone named as a shareholder in its current registered documents has a starting point for an E28A assessment. A founder whose ownership exists only in a side agreement, a proposed allocation or an agent's presentation does not yet have the same evidence. Nor does an impressive director title establish ownership.

Property buyers face a different misconception. Owning a villa on Bali may raise business and property-law questions, but the property itself is not proof of qualifying shares in a visa-sponsoring PT PMA. A limited-stay visa and the resulting limited-stay permit, or ITAS, are immigration permissions; KITAS is the familiar term often used for the latter. Neither term grants unlimited permission to work.

Before choosing this route, separate the shareholder, the legal entity and the person's day-to-day duties. Founders with the same company paperwork can reach different visa outcomes because their own equity and responsibilities differ.

E28A or E28: Which Visa Code Is Current?

Two official immigration pages are using different labels. Bontang's immigration office still hosts a detailed E28A investor visa card. A Southeast Sulawesi regional visa index updated in August 2026, meanwhile, lists the investor category as E28 without a separate E28A entry.

That discrepancy matters to anyone building an application around an old checklist. It may reflect a change in classification or differences in how information is published. The public pages alone do not establish that E28A has been discontinued, renamed or left untouched.

The sponsor should inspect the category available inside the live eVisa account and save its description, permitted activities and upload requirements. If the system presents E28, the paperwork needs to satisfy the requirements shown for that actual selection. A screenshot is a useful record of what was available when the filing decision was made; it is not an immigration approval.

Investor Shares vs PT PMA Capital: Three Tests

Three figures tend to appear in investor-visa conversations, and they measure entirely different things: the applicant's own shares, the PT PMA's paid-up capital and the investment value attached to its licensed business activity.

The Bontang immigration office's E28A card, checked on 15 October 2026, specifies at least IDR 10 billion in shares owned by the foreign applicant in the sponsoring company. A co-founder's holdings do not count towards that individual's stake. Neither a glossy company valuation nor a future capital-raising plan is a substitute for documentary proof of ownership. Where the company has multiple investors, the shareholder register and current amendments are indispensable.

Corporate formation is a separate test. Article 26 of BKPM Regulation No. 5/2025 sets a general minimum of IDR 2.5 billion in issued and paid-up capital for a PT PMA, subject to more specific provisions. This is a company-level requirement, verified against the published regulation on 15 October 2026. Meeting it can be necessary for the business yet insufficient for the individual seeking E28A.

There is also the project's investment threshold. Under the same regulation, the usual minimum exceeds IDR 10 billion, excluding land and buildings, for each five-digit KBLI activity and project location. Wholesale trade, food and beverage, construction and certain manufacturing activities use different aggregation rules. Property and accommodation activities have their own treatment of land and buildings, so a figure on an OSS screen cannot be interpreted without its business classification.

Imagine a company pursuing an investment project well above the general minimum, with a foreign founder holding only a minority stake. The project may meet its business-licensing requirement while the founder falls short of the published immigration share test. The reverse distinction matters too: substantial personal shares do not automatically make every business activity or job lawful.

The accompanying comparison keeps these tests separate. Any amount quoted for a live application should ultimately be reconciled with the shareholder documents, Article 26 and the precise visa conditions shown in eVisa that day.

PT PMA Documents for an Investor Visa

An incorporation certificate proves considerably less than many visa proposals imply. The application needs an unbroken documentary trail showing that the sponsoring PT PMA exists, that the foreign applicant owns the stated shares and that the person acting for the sponsor has authority to do so.

Begin with the notarised deed of establishment, subsequent amendments and the corresponding ministerial approvals. The current share register should agree with those records, especially after any increase in capital or transfer of equity. An original deed from the company's first day is not enough if a later amendment changed who owns what. Names and holdings must be consistent throughout the file.

Corporate authority is another link in the chain. The sponsor signatory's appointment should match the latest company documents. OSS records, the NIB business identification number and the relevant KBLI classifications help establish the business's registered activities and licences. They matter for corporate compliance, but an NIB does not identify a qualifying individual investor by itself.

The Bontang E28A page also asks for company establishment approval and corporate bank statements covering the preceding two months. Its published provision for a company incorporated less than two months earlier allows those statements to be submitted to immigration within 90 days after ITAS is issued. That is a specific statement on the official page as checked on 15 October 2026; it should be matched against the currently available eVisa route, not treated as guaranteed discretion to omit financial evidence.

Small mismatches can have substantial consequences. A passport transliteration may differ from a shareholder deed, a former director may still control the filing account or the bank statement may belong to a related entity instead of the sponsor. Resolving those inconsistencies before a filing is far easier than trying to explain them once the application has entered review.

Can You Work on an E28A Investor KITAS?

The published E28A description is more nuanced than either of the slogans heard in the market: investors may do more than sit passively on a share register, but the permit does not make them free to take any job in Indonesia. It covers investment activities, certain director or commissioner duties at the company invested in, and supervision of that company's operations.

Consider a shareholder overseeing budgets, meeting with fellow board members and supervising the business they own. Those activities fit the category's published purpose, provided the shareholding and sponsor requirements are met. A director who runs the same PT PMA's daily operations has a more complicated factual profile. Board activities appear on the official visa page, yet the title alone cannot settle every question about employment duties or employer compliance.

Now change the customer. The investor starts selling consultancy services to unrelated villa operators, perhaps billing them personally. The sponsoring PT PMA cannot automatically extend the investor's immigration rights to those engagements. Or imagine a person taking an operational management position on another company's payroll. That arrangement has to be examined under the appropriate work category, with the employing business's obligations addressed independently.

Indonesia's foreign-worker framework adds another test. PP No. 34/2021 and Minister of Manpower Regulation No. 8/2021 provide conditional RPTKA exemptions for certain shareholders, directors and commissioners. An exemption from that employer-side planning requirement is not equivalent to a universal permit to perform every kind of work. A September 2026 inter-ministerial decision addresses integration of OSS, employment and immigration systems; it does not justify assuming blanket work rights.

Job descriptions should identify the actual services, clients, reporting lines and paying entity. A board appointment, an ITAS and an RPTKA determination answer related but distinct questions. Where the proposed duties fall beyond those authorised by the live investor visa conditions, the work route needs to be resolved before activities begin.

Applying for an Investor KITAS: Sponsor and Fees

The sponsor should be settled before anyone quotes an investor KITAS package. If the intended company cannot document the applicant's equity or its own registration, a polished agency invoice will not fix the underlying eligibility problem. The exact visa category must also be selected from what eVisa currently offers.

The Bontang E28A information page lists an application letter, passport, photograph, CV, travel itinerary and personal financial evidence. It describes recent account statements and a minimum funds test, but the applicant should use the documentary and passport requirements displayed for the selected live category. A public information card is useful guidance; the actual submission form controls what can be uploaded and how it is assessed.

Company evidence comes next, including establishment records, share ownership and corporate banking documents. The sponsoring entity submits the application through eVisa and receives an official payment reference. The government charge, known as PNBP, should be distinguished from an immigration agent's service fee, notarial work, translations or the expense of updating a company's records. An agency's all-inclusive quotation is not the same thing as the government's invoice.

As described on the Bontang card on 15 October 2026, E28A had one-year and two-year stay options, with ITAS and a re-entry permission issued following admission at the immigration checkpoint. Entry visa validity, authorised stay and re-entry validity are separate dates to track. The fee actually due, extension terms and any changes to this workflow need checking in the issued documents and current billing information.

Once approved, keep the visa, ITAS, re-entry record, official receipt and the corporate evidence supporting the application together. Those documents become especially relevant when renewing the stay, travelling or changing the ownership structure.

If Your Shares, Sponsor or Company Role Changes

Shareholding can change long before a residence permit reaches its printed expiry date. A founder may sell shares, be diluted by a funding round or move an operating business into a different PT PMA. None of those events is merely a housekeeping matter for an immigration application that depended on a particular stake and sponsor.

Falling below the equity threshold published for E28A deserves particular attention. The Bontang visa card says that someone with insufficient shares who also serves as a director or commissioner must use a work visa suited to that role. It does not establish an automatic cancellation date for every ownership change, however, nor should an applicant assume the existing ITAS can safely be ignored until renewal.

Resigning from the board presents a different question if the person remains a qualifying shareholder. The scope of their future activities may change even where the equity does not. Switching sponsoring entities is more fundamental, since the original application rested on records belonging to a specific company. Family members holding dependent stay permits may be affected by a change to the principal holder's status.

Before a share transfer or company restructuring, assemble the existing and proposed shareholder register, notarial resolutions, sponsor details and issued immigration documents. The useful question for immigration is precise: does this event require notification, an amendment or a new basis of stay, and what is the applicable procedure for the principal and dependants? A generic agency timeline is not a substitute for that answer.

When a Work KITAS or Golden Visa Fits Better

An investor KITAS is sometimes the wrong answer, even for someone with a genuine business interest in Indonesia. A director's appointment cannot make up for an insufficient personal shareholding under the published E28A test. Nor does a friend or associate's investment become the applicant's merely because they appear in the same company presentation.

Where the person will work as an employee, the employer-sponsored route deserves priority. Official visa lists include work categories such as E23 and E25, with E25B identified for company directors in the regional index. The correct code depends on the employer, the role and the requirements shown at the time of filing. RPTKA obligations and any exemption must be assessed as a separate employment-law matter.

Golden Visa is a distinct discussion. Investment options such as E28B and E28C have their own evidence standards, qualifying commitments and stay periods. A founder considering a major capital project may wish to compare them, but their existence does not relax the shareholding or activity conditions for an ordinary investor route. Detailed Golden Visa planning belongs in a dedicated assessment.

There is a more basic warning for property owners: a paper PT PMA established solely to support a residence claim can create corporate and immigration exposure without delivering a valid business purpose. Ownership of a villa, business licensing and permission to reside are separate legal questions. Someone who needs to live in Indonesia without operating a genuine investment business should explore a lawful residence category on its own merits.

The decision becomes clearer when the proposed role is described accurately. A qualifying shareholder overseeing their PT PMA, an employee carrying out paid duties and an investor pursuing a much larger programme are different applicants. The final route needs to be matched to the live visa conditions and professional advice on the actual documents, not to a label in an agency brochure.

Evidence to Have in Hand Before Paying

Four Investor KITAS Claims That Need Evidence

E28A Investor KITAS FAQs

Does owning PT PMA shares alone qualify me for E28A?

Holding shares makes you a potential applicant, not an automatic visa holder. The published E28A route requires a qualifying personal stake in the sponsoring company, supported by corporate records. You do not necessarily need a director title, but your intended activities must still fit the immigration permission. The decisive checklist is the one attached to the live eVisa category when the sponsor files.

What shareholding value is required for an E28A Investor KITAS?

The Bontang immigration office's E28A card specified at least IDR 10 billion in shares owned by the individual applicant as of the 15 October 2026 review. Shares belonging to other founders cannot be added to that person's holding. The evidence should trace ownership through the deed, amendments and shareholder register. Because official websites currently use both E28A and E28 labels, verify the threshold for the category actually available in eVisa.

Is a PT PMA’s minimum paid-up capital enough for E28A?

A company's paid-up capital does not by itself qualify its shareholders for an investor visa. Article 26 of BKPM Regulation 5/2025 set a general PT PMA floor of IDR 2.5 billion, subject to exceptions, when checked on 15 October 2026. The E28A card's personal shareholding test is separate, as is the business project's investment value. The applicant therefore needs shareholder evidence in addition to the company's capital and OSS records.

Can a PT PMA director work under an E28A Investor KITAS?

The published E28A description includes director and commissioner activities within the company invested in. It does not offer unrestricted permission to work for an unrelated employer or sell services to outside clients. A director carrying out extensive operational duties should have those functions assessed against both the visa terms and foreign-worker rules. Any RPTKA exemption is conditional and should be documented rather than assumed from the job title.

What company documents are needed for an E28A application?

The core file ties together the company's deed, registered amendments, ministry approval and proof of the applicant's stake. The Bontang requirements, checked on 15 October 2026, also mention the previous two months of company bank statements, with a special provision for newly incorporated sponsors. OSS, NIB and KBLI records help establish the business's licensed activities but cannot replace ownership evidence. Use the document list shown in the live application for the final filing.

What if my shares or company role change after approval?

A share transfer, dilution or resignation can change the facts on which your stay permit was issued. The consequences are not necessarily identical: someone retaining qualifying shares after leaving the board differs from a director who has sold most of the holding. Bring the old and proposed corporate records, sponsor details and ITAS to an immigration adviser before the change takes effect. Ask whether notification, a different status or changes to dependent permits are needed.

Why do official visa sources show both E28A and E28?

There is a genuine difference between public immigration pages. Bontang provides a detailed E28A page, while Southeast Sulawesi's visa list updated in August 2026 uses E28 without listing E28A separately. That alone does not prove cancellation or renaming. The sponsor should select the live eVisa category, save its description and align the application documents with the conditions shown there.

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Sources

  1. Kantor Imigrasi Bontang — Informasi Visa Republik Indonesia (E28A Visa Investor)Detailed E28A card: permitted activities, IDR 10 billion share test, sponsor, documents, stay options and fees; recheck against the live application.
  2. Kanwil Ditjen Imigrasi Sulawesi Tenggara — Daftar Visa IndonesiaRegional visa list updated in August 2026 shows E28 without listing E28A separately; a naming discrepancy, not proof of cancellation.
  3. Directorate General of Immigration — Official eVisa PortalLive selection of visa index, document uploads, payment invoice, application status and current payment options.
  4. Directorate General of Immigration — 2025 Visa Classification UpdateJune 2025 update to visa classifications; background only, not a substitute for the currently available visa card.
  5. JDIH BKPM — Peraturan Menteri Investasi dan Hilirisasi/BKPM No. 5 Tahun 2025Current PT PMA investment value and capital rules: inspect Article 26 and exceptions separately from the individual immigration shareholding threshold.
  6. OSS RBA — KBLI 2025Current KBLI categories and transition from KBLI 2020; verify the company’s permitted line of business.
  7. OSS RBA — Official Business Licensing PortalNIB and risk-based business licences; company compliance layer, not an immigration permit.
  8. JDIH Kemnaker — PP No. 34 Tahun 2021 tentang Penggunaan TKAForeign-worker and RPTKA framework; assess actual duties rather than assuming a director title settles work permissions.
  9. JDIH Kemnaker — Permenaker No. 8 Tahun 2021RPTKA implementation and conditional exemptions; do not claim a blanket investor exemption.
  10. JDIH Kemnaker — Joint Ministerial Decree No. 1 Tahun 2026 (OSS, Employment and Immigration Integration)Issued 9 September 2026: verify whether interagency system integration affects the specific work/status scenario; avoid assuming operational details.