Three employment documents your company may not have

A company that pays wages properly, pays contributions, and gives staff their entitlements can still be found in breach — not because of substance, but because the document was never made, or was made and then expired without anyone knowing.

These three are the ones most often missing. They interlock, and their deadlines come from three different sources.

1. Company Regulations (Peraturan Perusahaan) — and their two-year life

Company Regulations are mandatory for companies employing ten workers or more.

But it is not the duty to create them that is most often breached. It is the duty to renew them.

Company Regulations are valid for at most two years. The renewal application must be submitted 30 working days before validity ends. Because drafting takes time, and because worker representatives have a window to comment, drafting needs to start around four months before the expiry date.

Companies have been prosecuted purely for failing to renew — not for failing to have them.

Nothing will remind you

The office that approves Company Regulations and the office that inspects compliance are two different offices.

What arrives is not a notice that your document has expired. What arrives is a labour inspector.

And the inspector can check it from a document your own company submitted: your annual employment report contains a Company Regulations field including its validity period. So your own report can be the pointer that your document has lapsed.

The sanction is criminal, not administrative

This is the important difference from other reporting obligations. There is no formal warning stage first, and the person in the dock is the employer or the director personally, not the company.

Once an inspection is running, there are usually two written inspection notes before the matter reaches court. The first note is still a window to put things right. The second is at the end of the road. If the first note lands on your desk, that is the time to move — not the time to wait for the next one.

Four things misunderstood about the content

• Clauses below the statutory standard will not bind, even if your Company Regulations were approved. The approval decision is not a shield: in a dispute, the statutory provision applies.
• Conversely, terms you write that are better than the statute become worker entitlements that can be claimed. Every concession that enters the text should be a conscious decision, not a sentence carried over from a sample document.
• Changing policy mid-term is not enough by internal memo. The change requires agreement with worker representatives and re-approval; without that, the change is treated as never having happened.
• If your company already has a Collective Labour Agreement, you are not required to make Company Regulations. Check this first, so you do not pay for an obligation that does not apply to you.

And if your company is part of a group: each legal entity must have its own Company Regulations. One document for the whole group does not satisfy the obligation.

2. Wage structure and scale — no employee-count threshold

This is the document most often assumed to be "a big-company matter". It is not.

The duty to draw up a wage structure and scale has no worker-count threshold. Unlike Company Regulations, which only bind at ten workers, there is no minimum here. Micro and small businesses are exempt from the minimum wage — but that exemption does not touch this obligation.

Do not assume your company is exempt just because you have few staff.

The risk comes from employees, not from the ministry

This is what makes it different from an ordinary administrative duty.

There is a final and binding cassation ruling ordering a company to make a wage structure and scale and to notify it to all its workers.

Which means workers do not have to wait for an inspector's visit to claim this.

The good news belongs in the same paragraph, so the picture is honest: in that same case, the order to pay a sum of money and a daily penalty imposed at first instance was set aside on cassation. What remained was the order to make the document and notify it. The court enforced the obligation, not your wage figures.

Keeping it without notifying still counts as a breach

Notification must be made to each worker individually, at least as to their own job grade.

Posting a notice on the board does not satisfy this — unlike Company Regulations, which may be posted. Many companies already have the document, filed neatly, and are still in breach because there is no evidence each person was told.

Nobody approves it, so your archive is the only proof

This document is not registered and not approved by anyone, so you will not receive a decision letter. When attached to a Company Regulations approval application, it is only shown and handed straight back; what is kept is your statement letter.

Which is why your internal archive — the decision letter adopting it and the acknowledgement from each worker — is the only compliance evidence you hold. If that archive is lost, no agency can issue you a copy.

A five to six week window every year end

Every minimum wage increase raises the floor of your structure.

The new figures are announced towards the end of November — at the latest 21 November for provinces and 25 November for regencies or cities — and take effect on 1 January. Your window to check and adjust the structure is only about five to six weeks.

The lowest grade is the one most easily left below the floor without anyone noticing, and that is a separate breach — distinct from the duty to draw up the document.

Three things to decide consciously

• The figures you write bind upwards, and cannot be fixed by lowering wages already being paid. Map first who sits outside their grade range, before the decision letter is signed.
• Be careful about writing an annual wage increase formula into this document. Formulas like that have been the subject of union disputes, and courts have been willing to write the formula themselves down to performance and service percentages. Keeping it separate as an annual policy is a legitimate choice — as long as it is chosen consciously.
• Your old document is probably now incomplete. Since a constitutional ruling in late 2024 and its implementing regulation in late 2025, the mandatory factors have expanded: not only company capacity and productivity, but also grade, position, length of service, education and competence.

And as with Company Regulations: if you are part of a group, each legal entity sets its own wage structure and scale, because company capacity is assessed per legal entity.

One useful thing about the cost

The size of this job is driven by the number of job positions, not the number of employees.

A company with two hundred people across eight positions is lighter work than a company with twenty-five people across nineteen positions. If you ask anyone to quote for this, the number of positions and the method used should be written into the quote.

3. Annual employment report — the December window

The annual report on your company's workforce is filed in the December window.

It is often treated as a formality, until it is required as a condition for something else and it turns out it was never filed.

Four things to know:

• The sanction is criminal and lands on directors personally — unlike investment reporting, which is administrative. The fine amount is small and has not been adjusted since 1981, but the personal exposure of directors is real.
• Event reports must precede the event. There is a duty to notify 30 days before relocating, halting or dissolving the company. Once the act has happened, the obligation can no longer be fulfilled — there is no way to fix it afterwards.
• Every branch that stands on its own is a separate filer. A multi-location company that only files from head office leaves obligations unmet elsewhere.
• New companies often think they have never filed when they have. The first report is usually satisfied through the business licensing system, and your business identity number doubles as the reporting number. Check before paying anyone to repeat it.

The real pattern

Notice how the three interlock:

The wage structure and scale must be attached to the Company Regulations approval application. If your company does not have one, the Company Regulations cannot be approved first. Some offices also ask for proof of your annual employment report.

So these are not three separate matters to be done in any order you like. One is a condition for another, and the third is where the first two get checked.

If one of them is missing, usually more than one is.

What you can do yourself, this week

1. Count your workers today. Ten is the Company Regulations threshold. The wage structure and scale has no threshold at all.
2. Find your Company Regulations approval letter. Note its expiry date. If it cannot be found, that is an answer in itself.
3. From that expiry date, count back 30 working days — that is the renewal filing deadline. Then mark four months before it as the drafting start date.
4. Check whether your wage structure and scale was ever notified per person, and whether the acknowledgements are kept. If it was only posted on a board or filed in HR, the obligation is not met.
5. Compare your lowest grade against the minimum wage effective 1 January. Do this in early December each year, not in February.
6. Open your latest employment report filing and check two things: whether the Company Regulations field is filled with a validity period that is still alive, and whether every stand-alone branch has its own filing.
7. Name one person who holds all three dates. An obligation with no name behind it is an obligation that gets missed.

Those seven steps need no one's help, and they give you something you may not have right now: exact dates, instead of a feeling that "it is probably fine".

Written 2026-07-30. Rules change — if you are reading this long after that date, confirm before you act on it.