By Indonesia’s House of Representatives approved the Manpower Protection Bill on 6 October 2026, according to a JD Supra article by Clarence Ding and Ratih Nawangsari of Ashurst Perkins Coie, with co-author Norman Ibnuaji. The Bill will become law once signed by the President, or after a 30-day period lapses from 6 October 2026, and is promulgated in the State Gazette.
The final text was not publicly available at the time of the JD Supra report. The Minister of Manpower issued a press release stating the Bill seeks to balance protection of workers’ fundamental rights with business sustainability. The article states the Bill will bring back the pre-Omnibus Law outsourcing regime once enacted, significantly impacting employers using outsourcing arrangements.
Where outsourcing rules stand today
Minister of Manpower Regulation No. 7 of 2026 on Outsourced Work, known as MoM 7/2026, is currently the primary instrument governing outsourcing in Indonesia. It was issued in response to Constitutional Court Decision No. 168/PUU-XXI/2023, which called for clearer limits on outsourced work and stronger protection for outsourced workers.
MoM 7/2026 reintroduces a closed list of permitted outsourcing categories, similar to the position before the Omnibus Law. It also reinstates substantive worker protections, prescribes a deadline for registering outsourcing agreements, and introduces new administrative sanctions.
Because MoM 7/2026 is a ministerial regulation, it ranks below a statute in the hierarchy of Indonesian legislation. Once the Manpower Protection Bill is enacted as law, MoM 7/2026 may need to be revisited or replaced.
What the Bill means for user companies
Employers that use outsourcing arrangements should treat the Bill as a signal that the stricter pre-Omnibus framework is returning at statutory level. The JD Supra authors describe their observations on the Bill as preliminary and subject to confirmation once the signed and promulgated text is released.
Under the current MoM 7/2026 framework, user companies are expected to map all outsourced activities against the six permitted categories. Non-compliant arrangements need transition plans before 29 April 2028. Contracts and procurement processes should be updated to include mandatory worker-protection clauses, and evidence of pre-deployment registration should be retained.
HR and payroll teams should prepare for the possibility that the new law hardens these requirements. Where a ministerial regulation can be amended relatively quickly, a statute carries more weight and may introduce additional obligations or sanctions that outlast the current regulation.
What outsourcing providers should check now
Outsourcing providers face their own compliance checklist under MoM 7/2026. The JD Supra article advises providers to confirm their KBLI classification and licences, register each agreement within three working days, maintain centralised records, and audit existing arrangements.
The KBLI classification matters because it determines whether a provider is formally recognised as operating in a permitted outsourcing category. A mismatch between the KBLI code and the actual work performed can expose both the provider and the user company to administrative sanctions.
Registration deadlines are tight. The three-working-day requirement for each agreement means providers need a process that captures new contracts immediately, not at month-end or quarter-end. Centralised records should include the registration evidence, the agreement itself, and any worker-protection clauses.
Payroll and compliance implications
Payroll teams in Indonesia should watch for changes to how outsourced workers are paid and protected. MoM 7/2026 reinstates substantive worker protections, which may include requirements around wages, benefits, and working conditions for outsourced staff. The Bill could extend or reinforce these protections at law.
The practical risk for employers is joint liability. Where an outsourcing provider fails to meet wage or social security obligations, the user company may face claims or sanctions. Payroll leads should verify that providers are registered with BPJS Ketenagakerjaan and BPJS Kesehatan and that contributions are current.
The table below summarises the key dates and actions from the JD Supra article.
| Date or deadline | Event or action |
|---|---|
| 6 October 2026 | House of Representatives approves Manpower Protection Bill |
| 30 days from 6 October 2026 | Bill becomes law if not signed by President, once promulgated |
| 29 April 2028 | Deadline for transition plans for non-compliant arrangements under MoM 7/2026 |
| Within 3 working days | Providers must register each outsourcing agreement |
What to do while waiting for the final text
The JD Supra authors state they will issue a follow-up article discussing the provisions of the Manpower Protection Law once it is promulgated. Until then, employers should avoid making irreversible changes based on the Bill’s expected content.
A measured approach is to continue compliance work under MoM 7/2026, since that regulation is in force today. Mapping outsourced activities against the six permitted categories, updating contracts, and confirming provider registrations are all steps that remain relevant regardless of how the new law is finalised.
Employers with significant outsourcing exposure should also monitor the State Gazette for promulgation. The 30-day period from 6 October 2026 means the law could take effect quickly if the President does not sign it. HR leads in Indonesia should confirm the final text and its transitional provisions with local counsel before changing contracts, headcount plans, or provider relationships.
Sources: JD Supra
Photo: Building of the Parliament of East Indonesia, Sulawesi Utara Bergolak, p118 by IPPHOS, Ministry of Information, Public domain
