Observation (CEACR) - adopted 2025, published 114th ILC session (2026)

Minimum Age Convention, 1973 (No. 138) - Indonesia (Ratification: 1999)

Article 1 of the Convention. National policy and application of the Convention in practice. The Committee previously noted that according to the findings of the 2019 National Labour Force Survey, 2.36 million children aged 10–17 years were working. 

The Committee notes the detailed information provided by the Government in its report on the measures taken to eliminate child labour, including: (1) awareness-raising on child labour standards for various stakeholders, including in the agricultural sector; (2) the launch of the extended road map towards a Child Labour Free Indonesia in 2024 and the establishment of Child Labour-Free Zones in strategic industrial areas; (3) workshops on the implementation of the road map to strengthen understanding and practical application at the field level; (4) the development of labour practice guidelines for the agricultural sector, in collaboration with the Partnership for Action Against Child Labour in Agriculture (PAACLA); (5) presentation of the PAACLA Award to companies and supply chains that have implemented innovative practices in addressing child labour; and (6) development of training modules and delivery of training programmes for prosecutors focusing on law enforcement related to child labour.

The Committee further notes the Government’s indication that a total of 143,456 children have been withdrawn from child labour and reintegrated into education through national programmes from 2008 to 2020. The Committee encourages the Government to pursue its efforts to ensure the progressive elimination of child labour and to continue to provide information on the measures taken in this regard. It also requests the Government to continue providing information on the results achieved, including updated statistical data on the nature, scope and trends of child labour in the country.

Article 2(1). Scope of application and labour inspection. Informal economy. The Committee previously noted that Act No. 13 of 2003 (Manpower Act) excludes from its application children who are engaged in self-employment or working without a clear wage relationship. The Committee notes the Government’s indication that it has strengthened labour inspection capacity in collaboration with PAACLA by developing Labour Practice Guidelines for the Elimination of Child Labour, intended for companies and supply chains in the agricultural sector. The Government further indicates that some companies in the palm oil plantation sector were declared as being “Child Labour-Free Companies”. The Committee also notes, from the Government’s report submitted in 2024 under the Labour Inspection Convention, 1947 (No. 81), that a number of measures were taken to strengthen the capacities of the Labour Inspectorate services including the recruitment of new labour inspectors and the implementation of training programmes. The Committee therefore requests the Government to continue to take the necessary measures to ensure that all children, including children working on their own account or in the informal economy, particularly in agriculture, benefit from the protections laid down by the Convention. In this regard, the Committee: (i) encourages the Government to review the relevant provisions of the Manpower Act in order to address these gaps; (ii) requests it to continue to take the necessary measures to strengthen the capacity and expand the reach of the Labour Inspectorate services to better monitor children working in the informal economy and on their own account; and (iii) requests it to provide information on the number and nature of violations relating to the employment of children and young persons detected by the Labour Inspectorate, and the penalties imposed.

Article 9(3). Keeping of registers. With reference to its previous comments, the Committee notes the Government’s indication that Law No. 7 of 1981 on Mandatory Manpower Reporting in Companies and the Minister of Manpower Regulation No. 18 of 2017 on the Procedures for Online Reporting provide: (1) for the obligation for all companies to report on the number of workers, types of work, wages, working hours, and on workplace facilities and conditions; and (2) for criminal sanctions when companies fail to comply with their reporting obligations (article 10 of Law No. 7 of 1981).

The Committee notes that it appears, from the Government’s information, that only companies are under the reporting obligation set out in Law No. 7 of 1981 and in the Minister of Manpower Regulation No. 18 of 2017. In this regard, the Committee recalls that that Article 9(3) of the Convention requires all employers, and not only companies, to keep registers containing the names and ages or dates of birth, duly certified wherever possible, of persons whom they employ or who work for them and who are less than 18 years of age. The Committee therefore once again requests the Government to take the necessary legislative measures to ensure that all employers, and not only companies, are obliged to keep registers of all persons below the age of 18 years who work for them, in conformity with Article 9(3) of the Convention. It requests the Government to: (i) provide information on any measures taken in this regard; and (ii) provide a copy of Law No. 7 of 1981 on Mandatory Manpower Reporting in Companies and of the Minister of Manpower Regulation No. 18 of 2017 on the Procedures for Online Reporting, with a translation in one of the official languages of the ILO.