Six Outsourcing Fields Under Manpower Regulation 7 of 2026

Update of 7 November 2026: Law 27 of 2026, in force from 28 October 2026, changes the basis for outsourcing and the adjustment deadline. See the last section.

Manpower Regulation 7 of 2026 on outsourced work was promulgated and took effect on 30 April 2026. Article 3(2) limits the types and fields of work to supporting activities: cleaning, food and beverage provision, security, drivers and worker transport, operational support services, and supporting work in mining, oil, gas and electricity.

Companies should note who the sanctions target. Article 8(1) says a user company that breaches Article 3 faces a written warning and limits on business activities, applied in stages. Article 8(3) sets out those limits: limits on production capacity for a period, or delayed business licensing at one or more locations.

Contents of the agreement

Article 4(1) requires the agreement to state at least the work outsourced, the term, the location, the number of workers, worker protection and rights, and the rights and obligations of the parties. Those rights include at least wages, overtime, working hours, annual leave, occupational safety and health, social security, religious holiday allowance, and rights when employment ends.

Article 4(2) makes the outsourcing company responsible for delivering them. Article 4(3) still binds the user company, which is responsible for ensuring the outsourcing company meets those protections and rights.

Registration

Article 5(2) requires the outsourcing company to apply for registration at the local manpower office where the work takes place, within 3 working days of signing. The office may hold back proof of registration if the agreement does not meet Articles 3(2) and 4. Companies with work sites in several districts should ask early how registration works.

Transition

Article 10(a) keeps existing agreements in place until their term ends. Article 10(b) requires types and fields of work to be adjusted within 2 years of promulgation, which is 30 April 2028.

Starting with a list of contracts

HR and procurement should list all contracts for the supply of workers and map each position to the six fields. Positions on the production line or in core work outside the list need a decision: move them onto the company’s own payroll, or change the form of the contract.

Finance should work out the effect on the 2027 and 2028 budgets. If workers become permanent employees, employee benefit obligations change and should enter the actuarial calculation.

After Law 27 of 2026

Law 27 of 2026 on Employment Protection took effect on 28 October 2026. Article 95(3) lists four supporting services: cleaning, meals for workers, security, and worker transport. Article 96 adds supporting services in mining and oil, which must go through a subsidiary in the form of a limited liability company.

Operational support services and supporting work in electricity under Manpower Regulation 7 of 2026 are not written in those two articles. Article 310 keeps earlier regulations in place so far as they do not conflict with the Law, and Article 101 promises a Government Regulation. Until it is issued, those two fields should be treated as a risk.

Article 306 requires adjustment within 1 year of promulgation, by 28 October 2027, earlier than 30 April 2028. Existing agreements stay in place until they end. Article 98 adds a new consequence: outsourced workers used for activities directly related to production become, by law, workers of the company using them.