Enforcement of International Arbitration Award in Indonesia: A Practical Approach on its Procedures and Challenges

• Regulatory Framework and Definition of National and International Arbitral Award
• Registration and Exequatur of the International Arbitral Award
  • Documents Submitted to Central Jakarta District Court
  • Authentication of Foreign Document
• Closing

Regulatory Framework and Definition of National and International Arbitral Award

Arbitration is an alternative dispute resolution that produces an award that is binding to the disputing parties (vide Article 52 of Law Number 30 of 1999 concerning Arbitration and Alternative Dispute Resolution -”Arbitration Law”). This arbitration award can be in the form of a national arbitration award or an international arbitration award (Article 1 numbers 13 and 14 of Supreme Court Regulation Number 3 of 2023 concerning Procedures for Appointing Arbitrators by the Court, Right of Objection, Examination of Applications for Enforcement and Cancellation of Arbitration Decisions -”PERMA 3/2023”).

A national arbitration award is an award rendered by an arbitral institution or sole arbitrator within the territory of Indonesia (Article 1 number 13 PERMA 3/2023), while an international arbitral award is an award rendered by an arbitration institution or sole arbitrator outside the territory of Indonesia or which according to Indonesian law is categorized as an international arbitral award (Article 1 number 14 PERMA 3/2023). In the implementation of arbitral awards, there are different rules for national arbitralawards and international arbitral awards.

In order to be enforced in Indonesia, an international arbitral award must first be registered to the Central Jakarta District Court. After being registered, the award can be applied for exequatur and then can be executed (vide Article 66 and Article 67 of the Arbitration Law).

Registration and application for exequatur of international arbitral awards require a number of documents that in practice may not be easy to fulfill.

An international arbitration dispute often involves foreign elements consisting of several countries at once. The implication of the presence of these foreign elements is that the required documents need to go through a foreign document authentication procedure.

This article will discuss how to fulfill the document requirements for the enforcement of international arbitration awards and their authentication procedures, especially at the registration and exequatur stages, with a practical approach. To explain this, this article will also discuss:

• the meaning of private and public documents;
• the application of the Apostille convention; and
• document legalisation for non-participating countries to the Apostille convention.

Registration and Exequatur of the International Arbitral Award

The registration stage and the exequatur stage of an international arbitral award are the focus of this article. International arbitral award must first be registered to the Central Jakarta District Court before it can be applied for exequatur.

First of all, at the registration stage, Article 7 paragraph (3) of PERMA 3/2023 stipulates that the documents required to register an international arbitration award are as follows:

• “An original or authentic copy of the international arbitration award (subject to authentication of foreign document provisions) and a sworn translation in the Indonesia language;
• An original or authentic copy of the arbitration agreement (subject to authentication of foreign document provisions) and a sworn translation in the Indonesia language;
• An official statement from the Indonesian diplomatic representatives in the country where the international arbitration award is rendered, certifying that the issuing country is a party to bilateral and multilateral agreements on the recognition and enforcement of international arbitration awards with Indonesia.”

Article 7 paragraph (1) of PERMA 3/2023 stipulates that the party registering an international arbitral award should be the arbitrator. However, the arbitrator may be represented by his attorney, and if the arbitrator is appointed by an arbitration institution, the power to register may be granted by the relevant arbitration institution (vide Article 7 paragraph (6) of PERMA 3/2023).

In practice, arbitrators or arbitration institutions are often not in Indonesia, so it is necessary to grant power of attorney to a party in Indonesia who is easier to register the award. Thus, a power of attorney from the arbitrator or arbitration institution becomes an additional document requirement for registering an international arbitral award.

Furthermore, in the execution stage, PERMA 3/2023 does not regulate the details of the list of documents that must be fulfilled. Article 16 paragraph (1) of PERMA 3/2023 regulates as follows:

“In the event that there is a party who does not implement the International Arbitration Award/International Sharia Arbitration Award voluntarily, one of the parties submits a request to the Chairman of the Central Jakarta District Court/Chairman of the Central Jakarta Religious Court to obtain an exequatur.”

What is written in Article 7 paragraph (3) of PERMA 3/2023 [on registration of award] as mentioned above may be seen as unclear. This lack of clarity, for example:

• concerns how many copies of each document are needed, whether the copies are sufficient to be legalized by the post office or must be notarized;
• how the authentication process for each document is carried out; and
• what are the details of the provisions related to the power of attorney from the arbitrator for registration or from one of the parties for the exequatur application.

Moreover, in complex case where the disputing parties are an Indonesian legal entity with an Angolan legal entity working on a permanent building project in Hungary, but the arbitration is carried out in Italy, then confusion arises regarding the documents that must be fulfilled to register the international arbitral award in Indonesia. Question also arises how to fulfill the requirement when the original underlying agreement no longer exists.

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Further, other confusion is related to the letter from the Indonesian diplomatic representative, where there are questions such as which Indonesian diplomatic representative needs to issue the letter and whether the information regarding the country that has an agreement with Indonesia is sufficient to be just Italy or also Angola and even Hungary. Therefore, a further research regarding the details of the documents for the registration stage and the exequatur application is necessary, of which result will be explained in section A below.

Documents Submitted to Central Jakarta District Court

In practice, when completing documents for registration of international arbitration award, additional documents might be required that are not listed in the laws and regulations as follows:

• International arbitral award that has been authenticated as foreign documents is then copied 3 (three) times and legalized by a notary. Official translation is made in 4 (four) copies for each original document and its copies.
• Arbitration agreement that has been authenticated as foreign documents is then copied 3 (three) times and legalized by a notary. Official translation is only required if the agreement is not made in Indonesian language. If needed, official translation is made in 4 (four) copies for each original document and its copies.
• Statement from the diplomatic representative of the Republic of Indonesia is copied 3 (three) times and legalized at the post office (nasegel).This letter does not need to be authenticated as a foreign document. This letter is sufficient to be issued from the country where the international arbitral award was issued and information regarding the country that has cooperation with Indonesia is the applicant’s country only or in other words the country of the arbitrator or arbitration institution.If one takes the previous case as an example, then a sufficient statement letter is from the Indonesian diplomatic representative in Italy stating that Italy has an agreement with Indonesia regarding the recognition and enforcement of international arbitration awards.
• The power of attorney from the arbitrator or arbitration institution is subject to the provisions on the authentication of foreign documents. An official translation is only required if the power of attorney is not made in Indonesian, but in practice the power of attorney is already made in 2 (two) languages (English and Indonesian). The power of attorney is copied 4 (four) times and legalised at the post office (nasegel).
• An application letter for registration of an international arbitral award to the Chairman of the Central Jakarta District Court. This application letter is based on the power of attorney from the arbitrator or arbitration institution, because based on Article 7 PERMA 3/2023 the party who can register an international arbitration award is the arbitrator.

Furthermore, to submit an exequatur application, in practice the following documents are required:

• Power of attorney from one of the disputing parties.
  This power of attorney contains special powers for the purposes among others of demand letter(s), exequatur application, and execution of the international arbitration award. The original version of this power of attorney is better be made in 3 (three) copies at once for each of these purposes. This power of attorney is also subject to the provisions of foreign document authentication, and official translation into Indonesian only if necessary because this power of attorney is usually already made in 2 (two) languages (English and Indonesian). The power of attorney then needs to be copied 4 (four) times and legalised at the post office (nasegel).
• Demand letter(s).
  As stipulated in Article 16 paragraph (1) of PERMA 3/2023, an exequatur application is submitted if a party does not voluntarily implement an international arbitral award. Thus, a prior demand letter becomes a prerequisite to provide the relevant party with the opportunity to implement the decision voluntarily.
• Letter of application for exequatur to the Chairman of the Central Jakarta District Court.
  Different from the registration stage, this application letter is based on a power of attorney from one of the disputing parties. This difference arises because the party who can register an international arbitration award is the arbitrator (vide Article 7 PERMA 3/2023), while an exequatur application must be made by one of the parties when the other party does not implement the decision voluntarily (vide Article 16 paragraph (1) PERMA 3/2023).

Authentication of Foreign Document

In the previous section, it often finds that there are documents that must comply with the provisions of foreign document authentication. What is meant by a foreign document and how is the procedure for authenticating foreign documents are the questions that will be answered in this section.

Article 1 number 1 of the Regulation of the Minister of Foreign Affairs Number 14 of 2022 concerning Procedures for Legalization of Documents at the Ministry of Foreign Affairs (“Permenlu 14/2022”) defines a document as “a written or printed letter used as evidence of information”. Documents can be divided into public documents and private documents.

Article 1 number 2 of Permenlu 14/2022 defines a public document as a document signed by an authorized official and/or affixed with an official stamp and/or seal. Article 1 number 3 of the Regulation of the Minister of Law and Human Rights Number 6 of 2022 concerning Apostille Legalization Services for Public Documents (“Permenkumham 6/2022”) defines an official as someone who has the authority and holds a certain position in a government office, institution, or non-governmental agency, and also includes public officials appointed by the government. One example of a public official appointed by the government who plays an important role in the authentication of foreign documents is a notary (vide Article 1 number 1 of Law Number 2 of 2014 concerning the Position of Notary).

For comparison, the definition of public body and public officials is also regulated in Law Number 14 of 2008 concerning Public Information Disclosure (“Law 14/2008”). Article 1 number 3 of Law 14/2008 regulates as follows:

“Public body is executive, legislative, judicial and other bodies whose main functions and duties are related to the administration of the state, some or all of whose funds are sourced from the State Budget and/or Regional Budget, or non-governmental organizations as long as some or all of their funds are sourced from the State Budget and/or Regional Budget, community donations and/or from abroad.”

Furthermore, Article 1 number 8 of Law 14/2008 regulates the following:

“A public official is a person who is appointed and given the task of occupying a certain position or post in a public body.”

Examples of public documents issued by officials include birth certificates, marriage certificates, and notarial deeds. On the other hand, what is included in private documents is simply documents that are not issued by officials, but signed by individuals or legal entities in their personal/civil capacity (vide Article 1 letter d of the Convention on the Abolition of the Requirement of Legalization of Foreign Public Documents/Apostille Convention). Examples of private documents include contracts and powers of attorney.

Both public documents and private documents can be regrouped into foreign documents and domestic documents.

The arguably main factor that determines whether a document is included in a foreign document is the place/territory of the country where the document in question was issued. For public documents, in addition to the place/territory, another determining factor is which official issuing the document.

These factors are as summarized from the following provisions:

• Article 4 paragraph (1) of Permenlu 14/2022;
• Number 79 point b of the Appendix to the Regulation of the Minister of Foreign Affairs Number 3 of 2019 concerning General Guidelines for Foreign Relations by Regional Governments (“Permenlu 3/2019“), and
• Article 2 paragraph (2) of Permenkumham 6/2022.

Examples of foreign public documents include birth certificates issued by a state civil registry office outside Indonesia and notarial deeds issued by a notary public outside Indonesia. Meanwhile, for private documents, the location of the signing of the document may be seen as a determining factor whether the document is a foreign document or not. Examples of foreign private documents are contracts signed outside Indonesia and powers of attorney signed outside Indonesia.

When a document is included in the category of foreign documents, then in order to be used in Indonesia, the foreign document must go through an authentication process. The 1961 Convention Abolishing the Requirement of Legalisation for Foreign Public Documents (“Apostille Convention”) is an important milestone that simplifies the process of authenticating foreign documents.

Before the Apostille Convention, the process of authenticating foreign documents was carried out through a rather complicated legalisation method due to involvement of many institutions. Indonesia became a member of the Apostille Convention with the issuance of Presidential Regulation Number 2 of 2021 concerning the Ratification of the Convention Abolishing the Requirement of Legalisation for Foreign Public Documents (“Perpres 2/2021”).

Due to its nature as a convention, an Apostille only applies to member countries of the Apostille Convention (vide Article 26 of the Vienna Convention on the Law of Treaties 1969). Thus, the foreign document authentication process consists of Legalization (for countries that are not members of the Apostille Convention) and Apostille (for countries that are members of the Apostille Convention).

Foreign documents intended to be used in Indonesia need to go through either one of the legalisation or apostille processes depending on the country where the document was issued. For example, a document issued in Angola and to be used in Indonesia needs to go through the Legalisation process because Angola, until this article was written, was not a member of the Apostille Convention.

Another example is a document issued in Italy and to be used in Indonesia only needs to go through the Apostille process because Italy is a member of the Apostille Convention. The Legalisation and Apostille procedures will be explained in the section below.

Legalisation

Legalisation is an authentication procedure that applies in Indonesia before Indonesia ratified the Apostille Convention and a procedure that still applies to countries that are not members of the Apostille Convention.

Legalisation is a fairly complex and lengthy procedure compared to Apostille. The Legalisation process is in principle to validate the signature of an official and/or stamp on a document, and not to validate the contents of the document (vide Numbers 77 and 78 of the Appendix to Permenlu 3/2019).

The steps or procedures for Legalisation regulated in Number 79 point b of Appendix to Permenlu 3/2019, Article 5 paragraph (1) of Permenlu 14/2022, and Circular Letter of the Supreme Court Number 07 of 2012 concerning the Formulation of Laws from the Results of the Plenary Meeting of the Supreme Court Chamber as a Guideline for the Implementation of Duties for the Courts (“SEMA 07/2012“) mention the important parties involved in the Legalisation process, namely:

• the competent foreign authority where the document was issued;
• the representative of the Republic of Indonesia in the country where the document was issued;
• the Ministry of Foreign Affairs;
• representatives of foreign countries domiciled in Indonesia; and
• notary.

The court jurisprudence provides the legal norms on the validity of a power of attorney. Jurisprudence stipulates that a power of attorney made abroad must be legalised by the relevant Embassy of the Republic of Indonesia in order to be admitted in Indonesian courts (vide Supreme Court Decision No. 3038 K/Pdt/1981, Decision No. 60/Pdt.G/2008/PTA.Sby, and Tax Court Decision No. 38655/PP/M.IV/16/2012).

The existing regulations do not clearly and consistently regulate the Legalisation procedures in practice. After doing further research on this subject-matter, the author obtained information regarding the standard procedures that generally apply to the Legalisation of foreign documents. It should be noted that this procedure is the one that generally applies, but do not always apply to all countries.

The general Legalisation procedure can be seen in the following diagram:

Legalisation by a foreign notary is the first step for foreign private documents because in principle legalisation can only be done for public documents. Foreign private documents need to be attached with something public in order to be legalised. Foreign public documents do not need to go through this first step.

The second step is legalisation by the authority of the country where the foreign document was issued. Which authorized authority in this step depends entirely on the country concerned.

Third step, after receiving legalisation from the foreign authority, the document needs to be legalised by the embassy of the Republic of Indonesia in the country where the foreign document was issued.

Fourth step, when the foreign document arrives in Indonesia, the document is legalised again at the Ministry of Foreign Affairs of the Republic of Indonesia. After going through all these steps, then the foreign document can be used in Indonesia.

Permenlu 14/2022 regulates an alternative to the Legalisation procedure described above. Article 5 paragraph (1) letter b in conjunction with Article 1 number 10 of Permenlu 14/2022 regulates that legalisation can be carried out at a foreign country’s representative office situated in Indonesia. This provision does not however replace the entire procedure. Legalisation by a foreign country’s representative office domiciled in Indonesia only replaces the legalisation stage by the Republic of Indonesia’s embassy in the foreign country.

How a foreign country’s representative office provides legalisation may differ by each country, without eliminating the possibility that the first and second steps must still be taken.

Foreign documents that have been legalised by a foreign country’s representative office situated in Indonesia must still be legalised again at the Ministry of Foreign Affairs of the Republic of Indonesia in order to finally be used in Indonesia.

SEMA 07/2012 and the previously mentioned jurisprudence are no longer in accordance with the new regulation that legalisation can be carried out at foreign country representatives in Indonesia and no longer needs to be mandatory through the embassy of the Republic of Indonesia in the country concerned. The rules in SEMA 07/2012 refer to the Regulation of the Minister of Foreign Affairs No. 09/A/KP/XII/2006/01 dated 28 December 2006, which is no longer valid with the enactment of Permenlu 3/2019. Therefore, currently the authentication procedure refer to the new rules, namely Permenlu 14/2022.

Apostille

Since ratifying the Apostille Convention through Perpres 2/2021, Indonesia now uses the Apostille authentication procedure for fellow member countries of the Apostille Convention.

Apostille is a simpler authentication procedure compared to Legalisation. In principle, an Apostille can only be carried out on public documents listed in Article 1 of the Apostille Convention as follows:

• “documents emanating from an authority or an official connected with the courts or tribunals of the State, including those emanating from a public prosecutor, a clerk of a court or a process-server (“huissier de justice”);
• administrative documents;
• notarial acts;
• official certificates which are placed on documents signed by persons in their private capacity, such as official certificates recording the registration of a document or the fact that it was in existence on a certain date and official and notarial authentications of signatures.

However, the present Convention shall not apply:

• to documents executed by diplomatic or consular agents;
• to administrative documents dealing directly with commercial or customs operations.”

Article 2 of the Apostille Convention basically stipulates that member countries of the convention are required to exempt the Legalisation process for public documents as stipulated in Article 1 of the Apostille Convention. Documents that have gone through the Apostille process no longer need to be legalised and can be used directly in the destination country (i.e. Indonesia).

The principle that the Legalisation process is exempted for documents that have been Apostilled is also stipulated in Article 4 paragraph (2) of Permenlu 14/2022.

In ratifying the Apostille Convention, Indonesia declared that documents issued by the prosecutor’s office as a prosecution institution in Indonesia are not included in public documents for which the legalisation requirement is exempted (vide Appendix to Perpres 2/2021).

The Apostille procedure varies from country to country. This section will look at examples of the Apostille procedure in Indonesia, the Netherlands, and France.

The Apostille procedure in Indonesia is regulated in Permenkumham 6/2022. Apostille in Indonesia is carried out on documents issued in the territory of Indonesia for use in other countries that are fellow members of the Apostille Convention (Article 2 paragraph (2) of Permenkumham 6/2022).

Apostille applications in Indonesia are submitted electronically via the website https://apostille.ahu.go.id/. In simple terms, the Apostille procedure via this website is that:

• the applicant first need to create an account;
• fill out the online form; and
• upload a scan of the identity card and the document for which the Apostille is being requested.

If necessary, the Ministry of Law can request a signature specimen and information from the relevant institution if the official who signed the document is not yet in the Ministry of Law’s database.

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After uploading the specimen, the Ministry of Law will review the application and decide whether to approve or reject it. If rejected, then the applicant needs to correct the Apostille application. If approved, the next step is to pay the Apostille fee, then pick up the finished Apostille certificate at the Ministry of Law.

Please note that when picking up the Apostille certificate, the applicant must bring the documents requested for Apostille, because the documents will be attached with the Apostille certificate using a special seal from the Ministry of Law.

The Apostille procedure in Indonesia can take a relatively short time (a few days) to a relatively long time (weeks), depending on each document requested. The process will take longer time especially if it involves a specimen request.

In the Netherlands and France, the Apostille procedure is much simpler and more practical compared to Indonesia.

Apostille in both countries is carried out in court (Government of the Netherlands, 2025) (Service-Public.fr, 2025). However, as of May 2025, the authority to carry out Apostille in France will shift to a notary (Paris Court of Appeal, 2025). The applicant can go directly to the court without prior appointment and tell the officer to Apostille the document (Paris Court of Appeal, 2025) (de Rechtspraak, 2025).

France does not charge any fees for Apostille (Paris Court of Appeal, 2025), while the Netherlands charges a number of Apostille fees (Government of the Netherlands, 2025).

After paying the Apostille fee (if any) and submitting the document to the officer, the applicant only needs to wait a moment until the Apostille is done. The Apostille process in France and the Netherlands can be completed on the same day.

In principle, an Apostille can only be done on public documents (vide Article 1 and Article 2 of the Apostille Convention). However, private documents can also be Apostilled after being affixed with something of a public nature such as legalisation by a notary first. Foreign private documents that wanted to be Apostilled, must always be made public first, then the Apostille can be done.

In France there is a procedure called “Hardware Signature Certification” or legalisation of the signature of a private person (Service-Public.fr, 2025). For French people, this procedure can be done at the Townhall for free, or through a notary for a fee (Service-Public.fr, 2025). For non-French people, legalisation of signatures can be done at their country’s representative in France (if the representative provides legalisation of signatures) (Service-Public.fr, 2025).

After the signature is legalised, the private document then has a public nature and therefore can be Apostilled (Service-Public.fr, 2025). Based on Article 1 letter a of the Apostille Convention, international arbitral awards are included in public documents that can be directly Apostilled.

Practical Condition

In practice, a foreign document can involve two or more countries at once. An example is a contract document involving several companies from several different countries.

Thus, the first thing to look at is the location of the signing written in the contract document. If the contract clearly states the location of the signing, then document authentication is to be done from the country written, either in the form of Apostille of Legalisation.

It often happens that the location of the signing of the contract is not written in the document, and that the document is a document that is years old where the parties have even forgotten where they signed the contract. If so, then the country from which the party/company signed the contract can be used as a reference that the contract is a foreign private document or not.

For example, if the company that signed the contract is a legal entity from Singapore, then the authentication process is carried out from Singapore. The location of the project or implementation of the contract, the law governing the contract, and the language of the contract may not be the factors that determine where the authentication of foreign documents must be carried out.

Another practical condition is what is called the end-user principle. In which country the document will be used and to whom the document will be submitted is the reference point.

In Indonesia as described in this article, the foreign private documents are to be submitted to the Central Jakarta District Court for the implementation of an international arbitral award. Therefore, the reference is to the Central Jakarta District Court. How the court requests the documents, such as how many copies, legalized by a notary or post office, and whether or not foreign documents need to be authenticated, are standards that must be met. If the end-user does not request various complicated requirements regarding the authentication of foreign documents, then in practice the applicant does not need to do so because it is not required by the end-user (in this case the Central Jakarta District Court).

Closing

An international arbitration lawyer in Indonesia must understand the process of registering an international arbitral award at the Central Jakarta District Court. It requires 3 (three) types of documents, namely:

• an international arbitral award;
• an arbitration agreement; and
• a statement from the embassy of the Republic of Indonesia in the country where the international arbitral award was rendered.

In practice, of course, in addition to these three documents, a power of attorney from the arbitrator or arbitration institution and a letter of application for registration of an international arbitrationl award need to be submitted.

The process of applying for exequatur in practice requires 3 (three) types of documents, namely:

• a power of attorney from the applicant for exequatur;
• a demand letter(s); and
• a letter of application for exequatur.

Each of these documents has its own additional provisions, including provisions for the authentication of foreign documents.

Authentication of foreign documents can be done by means of Legalisation or Apostille, depending on the country where the document in question was issued. If the country where the foreign document was issued is a member country of the Apostille Convention, then the procedure that needs to be taken is only Apostille and does not require Legalisation. In the practice of authenticating foreign documents, it is always necessary to ensure with the end-user and specifically check the laws of the foreign country concerned.

Writer: Yosefin Mulyaningtyas
Editor: Dr. Eddy M. Leks

Court’s Decisions:

• Decision of the Supreme Court of the Republic of Indonesia Number 3038 K/Pdt/1981.
• Decision of the High Religious Court of Surabaya Number 60/Pdt.G/2008/PTA.Sby.
• Decision of the Tax Court Number 38655/PP/M.IV/16/2012.

Articles:

• De Rechtspraak, Apostille of legalisatie aanvragen bij rechtbank Noord-Nederland, Groningen, <https://www.rechtspraak.nl/Zelf-regelen/apostille-legalisatie/Paginas/Apostille-Legalisatie-rbnne-gro.aspx>, accessed 28 April 2025.
• Government of the Netherlands, Legalisation of Dutch documents by apostille, <https://www.netherlandsworldwide.nl/legalisation/what-is-legalisation-apostille>, accessed 28 April 2025.
• Government of the Netherlands, Legalising a Dutch document with an apostille, <https://www.government.nl/topics/identification-documents/certificates-and-official-documents/legalising-a-dutch-document-with-an-apostille>, accessed 28 April 2025.
• Paris Court of Appeal, Apostille Home, <https://www.cours-appel.justice.fr/paris/accueil-de-lapostille>, accessed 28 April 2025.
• Service-Public.fr, Legalization of signature on a document drawn up under private signature (CMS), <https://www.service-public.fr/particuliers/vosdroits/F1411/personnalisation/resultat?lang=en&quest0=0&quest=>, accessed 28 April 2025.
• Service-Public.fr, Legalization or apostille of a public act drawn up by a French authority, <https://www.service-public.fr/particuliers/vosdroits/F1400?lang=en>, accessed 28 April 2025.

Others:

• Consultation with the Central Jakarta District Court on 26 March 2025.
• Consultation with the Ministry of Foreign Affairs of the Republic of Indonesia on 10 April 2025.