Navigating Change: Understanding Latest Immigration Guidelines on Stay Permit Applications in Indonesia

Indonesia’s Ministry of Immigration and Corrections (“MOIC”) has issued new nationwide guidelines for Immigration Offices aimed at reducing immigration violations, increasing oversight of foreign nationals, and improving clarity and consistency in stay permit services.

These updates are set out in Circular Letter Number IMI-417.GR.01.01 Year 2025 concerning Adjustment of Immigration Residence Stay Permits (“CL 417/2025”), which took effect May 29, 2025.  CL 417/2025 replaces the earlier Circular Letter Number IMI-261.GR.01.01 Year 2025 and is intended to help authorities map the number, activities, and distribution of foreigners in Indonesia, while ensuring more effective supervision and standardized stay permit processing.

Key Provisions and Their Relation to Prevailing Immigration Regulations

CL 417/2025 introduces two key procedural directives for Indonesian Immigration Offices in receiving and processing stay permit applications:

1. Permitting walk-in applications for certain categories of applicants and under specific conditions; and
2. Requiring photoshoot and interview sessions for all stay permit applicants.

Walk-In Stay Permit Applications

CL 417/2025 provides that walk-in stay permit applications are allowed for the following categories of applicants and circumstances:

• elderly persons;
• persons with disabilities;
• pregnant or breastfeeding women;
• in light of an emergency situation; and
• other situations requiring assistance from an immigration officer.

Mandatory Photoshoot and Interview Sessions

CL 417/2025 instructs immigration officers to direct all stay permit applicants – regardless of whether the application is submitted online or via walk-in – to undergo photo and interview sessions. These sessions must be conducted within two days following the completion of the applicant’s required documentation.

We note that the photoshoot requirement under CL 417/2025 is a slight deviation from the stay permit application procedures set out in Minister of Law and Human Rights Regulation No. 22 of 2023 (“MOLHR Reg. 22/2023”), which requires such sessions only for certain categories of stay permit applications. In contrast, CL 417/2025 appears to require photoshoot sessions for all stay permit applicants.

Furthermore, CL 417/2025 appears to introduce a new policy by requiring interview sessions as part of all stay permit applications. This differs from the provisions under MOLHR Reg. 22/2023, which do not mandate interviews as part of the stay permit application process. In this respect, there is a notable procedural difference between the directive set out in CL 417/2025 and the provisions under MOLHR Reg. 22/2023.

Lastly, Indonesian immigration laws and regulations, including MOLHR Reg. 22/2023, regulate that stay permit applications are not treated as standalone submissions. Instead, they are submitted as part of or in conjunction with the relevant visa application, or, in the case of permanent stay permits, in connection with an existing limited stay permit.

The only instances in which stay permit applications are submitted as standalone applications are in the case of stay permit extensions. Accordingly, it may be suggested and interpreted that the interview requirement under CL 417/2025 is intended to apply only to stay permit extension applications. This interpretation is further supported by the MOIC’s statement in the introductory message on its  website, which notes that foreign nationals applying for a stay permit extension are required to undergo photo capture and an interview session.

Implications for Foreigners and Conclusion

We are of the view that the directives and instructions set out in CL 417/2025 should be interpreted together with the provisions of MOLHR Reg. 22/2023. In this regard, CL 417/2025 should not be read as changing or amending the provisions of MOLHR Reg. 22/2023, but rather as an internal administrative guideline intended for use by immigration officers in carrying out their duties.

Therefore, while foreigner nationals applying for stay permits should be aware of the procedural practices implemented pursuant to CL 417/2025, there is no need for concern. These practices only represent additional administrative steps in the application process, but they do not change or add new requirements to the prevailing provisions set out in MOLHR Reg. 22/2023.

By SSEK, Indonesia, a Transatlantic Law International Affiliated Firm. 

For further information or for any assistance please contact indonesia@transatlanticlaw.com

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