Suspensions Regulated for Employer Access to Public Services

In order to increase the level of mandatory participation in the various social-security programs organized by the Social Security Agency for Labor (“BPJS Labor”), the Minister of Employment (“Minister”) has issued Regulation No. 23 of 2016 on Procedures for the Imposition and Revocation of Sanctions in the Form of Suspensions of Access to Certain Public Services by Non-State Employers excluding State Officials (“2016 Regulation”).In essence, the 2016 Regulation sets out guidelines which limit access to public services by non-state employers (“Employers”) who fail to comply with the provision on mandatory participation in the social security program for workers, and covers: work-accident insurance, life insurance, the pension program and the old-age benefits program. [1] The 2016 Regulation is relevant to all businesses in Indonesia, as well as to the general public.Administrative Sanctions for EmployersEmployers may become subject to administrative penalties if they commit any of the following types of violations: [2]