The changes are contained in Minister of Transportation Regulation No. PM 3 of 2026 (PM 3/2026), which amends PM 59 of 2021 on businesses providing services related to carriage by water. The regulation was stipulated on 11 February 2026 and entered into force when it was promulgated on 11 March 2026.
The Ministry’s stated rationale is to strengthen the quality of human resources working in maritime support services so they are professional, competent, disciplined and responsible, while meeting national and international standards. In practical terms, the amendment moves personnel competency from being a general operational concern into a more explicit regulatory requirement for companies operating in this part of the Indonesian maritime sector.
For companies active in Indonesia’s maritime industry, the effect is not limited to training departments. The new rules touch employment administration, contractor management, port operations, compliance records and the selection of certification or training providers.
New competency requirements for stevedoring workers
One of the most significant additions is new Article 3A, which sets out the competency evidence that may be used for stevedoring workers. Under the amendment, competency can be demonstrated through a competency certificate, a training certificate and/or a letter showing relevant work experience.
The categories are not interchangeable in every respect. Competency certificates and training certificates are recognised at ports generally, while the work-experience letter route is narrower and applies to local and regional feeder ports. The experience letter is also valid for two years, meaning companies relying on that route need to manage expiry and replacement as part of their personnel records.
The rule is important for businesses supplying or managing tenaga kerja bongkar muat, commonly referred to as TKBM, because the regulation places responsibility for improving worker competency on the business entity itself. It also states that the associated competency-improvement costs are to be borne by the business entity.
That allocation is commercially relevant. Companies can no longer treat training and certification purely as a personal responsibility of the worker if the regulatory obligation sits with the employing or labour-providing entity. Budgeting, employment terms and arrangements with labour cooperatives or subcontractors should therefore be reviewed against the amended framework.
Stevedoring companies also face an operational cooperation requirement
PM 3/2026 also amends Article 3 so that a stevedoring company must cooperate with either the port operator or a port business entity that has obtained a concession. This requirement sits alongside the competency rules and reinforces the link between labour activity and the formal port-operating structure.
For companies reviewing their contractual arrangements, that means the compliance analysis should not stop at whether workers hold the correct certificates. The underlying cooperation arrangement with the relevant port operator or concessioned port business entity also needs to be documented and kept current.
The framework extends beyond stevedoring
The amendment is broader than TKBM. Revised Article 132 introduces competency requirements for personnel working in other businesses providing services related to carriage by water. In those businesses, competency must be evidenced by a competency certificate and/or a training certificate, and the company is again responsible for improving personnel competency and bearing the associated cost.
Crew-agency companies are expressly excluded from the Article 132 competency requirement. For other maritime support-service providers, however, the amendment means personnel documentation should be treated as part of the company’s regulatory file rather than only as an HR record.
The practical consequence is that companies may need to map which jobs fall within the amended rules, what evidence each employee or worker currently holds, when that evidence expires and whether the issuing institution meets the new regulatory standards.
Training and certification providers are brought into a more structured approval regime
PM 3/2026 does not regulate only the companies employing maritime personnel. It also tightens the framework for the institutions that issue competency and training certificates.
Professional certification bodies must obtain a recommendation from the Director General, hold the relevant licence and be registered with the Directorate General. Training institutions require approval from the Director General and must meet standards covering matters such as learning outcomes, curriculum content, teaching process, assessment, instructors, facilities, management and financing.
Approval for a training institution is valid for five years and may be extended. The regulation also requires certification and training institutions to report completed competency tests and/or training activities to the Director General within 30 calendar days. Monitoring and evaluation by the Directorate General is to be carried out every two years or when considered necessary.
This part of the regulation matters to employers because a certificate is only as useful as the regulatory standing of the institution that issued it. Companies procuring training should therefore verify the provider’s approval and registration rather than assuming that any certificate labelled as maritime training will satisfy the amended rules.
The transition period has already become relevant
The regulation gave existing professional certification bodies and training institutions six months from commencement to register with the Directorate General. Because PM 3/2026 entered into force on 11 March 2026, that transition period has now passed.
Existing training certificates issued before the regulation took effect are treated differently: the regulation provides that they remain valid for three years from commencement. That gives companies some continuity, but it should not be read as an indefinite grandfathering of old documentation.
For compliance teams, the sensible approach is therefore to distinguish between the status of the worker’s existing certificate and the status of the institution that now provides new training or certification. Those are separate questions under the transitional framework.
What companies should review now
Businesses affected by the amendment should start with a personnel audit. The company should identify which employees or workers fall within the stevedoring provisions and which fall within the broader Article 132 framework, then record the document relied on to establish competency for each person.
Where an experience letter is being used for stevedoring workers, the company should check both the two-year validity period and whether the relevant port falls within the local or regional feeder-port limitation. Where a competency or training certificate is relied on, the issuing body’s status should be checked against the current approval and registration requirements.
Companies should also revisit their contracts. Labour-supply agreements, service contracts and arrangements with training institutions should make clear who is responsible for arranging and paying for mandatory competency development, providing evidence of compliance and replacing expired documentation.
The amendment is only eight pages long, but its operational reach is wider than its length suggests. For businesses supporting carriage by water, personnel competency is now more clearly embedded in the legal compliance framework. The change also sits alongside other 2026 maritime licensing reforms, including new ship management standards under PM 1/2026, reinforcing the need for maritime companies to treat staffing, certification and operating systems as regulatory controls rather than administrative detail.
Primary sources
- Minister of Transportation Regulation No. PM 3 of 2026 — official regulation PDF.
- Peraturan.go.id — PM 3/2026 metadata and legal status.
- JDIH Ministry of Transportation — PM 3/2026.
Source note: Maritime Legal Business prepared this update primarily from the Indonesian-language text of PM 3/2026. English descriptions are MLB summaries and are not official translations. Businesses should review the regulation and applicable implementing requirements for their specific operations. This article is for general informational purposes and does not constitute legal advice.