Written by
Asean Mobility
Spotlight
May 2023
Executive summary
Asean Mobility Spotlight
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In this edition of the Asean Mobility Spotlight, we take a deep dive into the immigration rules for short-term
business travelers (STBTs) as jurisdictions in Southeast Asia open borders to a near normal state, bouncing
back from the COVID-19 pandemic resulting in an increase of travels for business purposes. This includes
the following:
General entry requirements
Permitted activities
Adherence to regulatory guidelines
In a nutshell, STBTs refer to employees who travel outside of their base location for business and who are
not on any formal assignment or transfer to the destination country. Each country has its own respective
definition and threshold on what encompasses an STBT, but a similar characteristic is that STBTs are not
allowed to perform activities defined as work in the respective destination country. Failure to adhere to the
conditions imposed upon an STBT may result in repercussions toward not only the individual but also the
deemed host or sponsoring entity.
With the increase in travels for business purposes in line with reinvigorating the economy, employers will
need to undertake a review of whether current processes that are in place are sufficient to manage STBTs.
Employers will need to practice diligence toward monitoring the business travel of their employees to not
only ensure that the destination country’s entry requirements are adhered to, but also to avoid any
exposure to non-compliance. Employers may do so by:
Having the necessary business travel policy in place
Monitoring the latest immigration updates and requirements to enter the destination country
Ensuring a mechanism is in place to track and monitor employee’s business travels
Where gaps are identified, our EY teams are here to review and make recommendations about best
practices that a company can implement to better manage STBTs and provide assessment and commentary
where needed on case-by-case basis on entry requirements and other general immigration considerations.
Please note that the information provided in this spotlight is updated as of May 2023.
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Entry requirement
STBTs must have a valid visitor visa to enter Indonesia.
The visa types that can be applied for are as follows:
Single entry visit visa (SEV) for stays up to 60 or
180 days
Multiple entry visit visa (MEV) for stays up to 60 or
180 days
Visa on arrival (VoA) for stays up to 30 days
STBTs with certain nationalities can also enter using the
visa-free facility for a maximum stay of 30 days.
General requirements to apply for Indonesian visit visa:
Have a minimum six-month passport for SEV with a
validity period of 60 days or a 12-month passport
for SEV with a validity period of 180 days or an 18-
months passport for MEV with a validity period of
12 months
Have a letter of guarantee from a sponsor company
in Indonesia
Have proof of having fund for living expenses for
themselves and their family of at least US$2,000
or equivalent
Have a return ticket
Have a recent color photograph with a white
background, taken in last three months
Have a declaration letter to bear the cost of medical
treatment if tested positive for COVID-19 and to
adhere to the health protocols in Indonesia
Have proof of Insurance ownership
Have a certificate of vaccine completion
Permitted activities
Visitor visa holders are not permitted to perform any
working activities when in Indonesia.
However, they may take part in the following
activities with a valid visitor visa while being
in Indonesia:
Attend meetings
Purchase of goods
Social and tourism visits
Government duties
Increasing regulatory and enforcement
scrutiny
A business visit visa cannot be used for
working activities.
Frequent business visits to Indonesia may trigger
additional scrutiny from the immigration authority
upon arrival. Hence, a valid explanation should be
provided in case questions arise upon arrival.
Common examples of STBTs carrying out
unpermitted activities may include:
Visiting a plant or factory that involves touching
tools or machines
Having activities in a working area (not in a
meeting room), which could trigger further
checking by the authority as it might be deemed
working activities
Performing continued supervision of
production activities
Additionally, STBTs should also restrict their
meeting to being conducted in a meeting room. The
Ministry of Manpower and Immigration Office may
do a spot check or a random check on the
company’s premises. If a visitor is found in the
office doing some activities, they could be deemed
to be carrying out work without the proper
formalities, which will put both the company and
the STBTs at immigration non-compliance risks.
Indonesia
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Malaysia
Entry requirement
All foreigners entering Malaysia must satisfy the following
conditions:
Possess a valid passport or international
travel document
Possess an entry visa
Possess a valid return ticket and sufficient travel funds
for expenses
Not being classified as a prohibited person under
Section 8 of the Immigration Act 1959/1963
Have completed the Malaysia Digital Arrival Card
(MDAC) application
Permitted activities
The permitted activities as a social visitor are as follows:
Social visit
Visiting relatives
Tourism
Journalism or reporting
Meeting or conference
Business discussion
Factory inspection
Auditing company accounts
Signing agreement
Carrying out a survey on investment opportunities or
setting up a factory
Attending seminars
Students on goodwill missions or taking examinations
at a university
Taking part in sports competitions
Other activities approved by the Director General
of Immigration
Any other activities falling outside of the above permitted
activity list will need to be assessed. It is important to
note that foreign visitors do not possess any rights to
work in the country unless in possession of the
appropriate work permit.
Increasing regulatory and enforcement
scrutiny
The Malaysian Immigration Department (MID)
generally continues to carry out operations to
apprehend illegal immigrants in both commercial
and residential locations known to have large
populations of foreign residents. As such, it is
important for STBTs whose activities cross into
those considered as work activities to ensure that
they apply for the correct type of permit.
Some sample activities commonly mistaken for
business activities include but are not limited to:
Participating in workshops or training either as a
participant or facilitator
Any client-facing or intra-corporate activities that
include production of deliverables,
i.e., project activities
Conducting internal process audits
Conducting business as usual activities relevant
to an individual’s role regardless of where payroll
is administered
Other updates
Foreigners who wish to enter Malaysia for short
term work purposes may opt for the following
facilities that are available:
PLS@XPATS: work rights granted on a social visit
pass (SVP) to undertake work that is critical to a
business’ operation or activities
DE Rantau Nomad Pass: a work permit
introduced to allow foreign nomads to work
remotely in Malaysia for up to two years
Malaysia has recently introduced electronic entry
visa and autogate facilities for foreigners from 10
countries arriving via Kuala Lumpur International
Airport 1 and 2 to improve travelersexperience.
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Philippines
Entry requirement
All foreigners entering the Philippines must satisfy the
following conditions:
Have a minimum six-month passport validity
Possesses valid tickets for return journey to the
port of origin or next port of destination
corresponding to the permitted or allowable
duration of stay under a valid visa or visa free
entry
Fully receive COVID-19 vaccination, except only
for minor children below 12 years of age traveling
with their fully-vaccinated foreign parents
Possess an acceptable proof of COVID-19
vaccination, which shall be presented prior to
departing or boarding from the country of origin
and upon arrival in the Philippines
Must present a negative RT-PCR test taken within
24 hours, except for certain cases
Registers on the Philippine One-Stop Electronic
Travel Declaration System 72 hours prior to
departure from the port of embarkation
Foreign nationals will be given a tourist or business
visa upon entry.
Foreign nationals whose countries are not considered
as visa-free in the Philippines are required to secure an
entry visa from the Philippine Embassy.
Permitted activities
Foreign nationals holding a tourist or business or
9(a) visa are given a limited set of activities,
such as:
Conduct or attend business meetings, limited
only to discussion on business development,
strategic planning, contract discussion and
negotiation, processes and programs
Attend as a participant or technical or non
technical staff in a conference or exhibition
Deliver or receive training in a
classroom setting
Increasing regulatory and enforcement
scrutiny
Any activities involving contract signing,
consultation and advisory and any other technical
activity would pose a high risk of requiring a tax
identification number and special work permit as
the above-mentioned are considered as doing
business or work in the Philippines.
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Singapore
Entry requirement
STBTs must fulfil the following general requirements
to enter Singapore:
Have a minimum six-month passport validity
Have sufficient cash and proof of onward travel,
i.e., tickets, visas and more
Complete Singapore arrival card declaration
Possess entry visa (only applicable for certain
nationals)
Have international certificate of vaccination for
yellow fever (only applicable for travelers who
have visited any country of risk of yellow fever
transmission in the past six days)
There are now no COVID-19 health measures for
STBTs, regardless of vaccination status or
traveler profile.
Upon arrival Singapore, STBTs will be granted a
short-term visit pass (STVP) for a period of 14 to 90
days at the discretion of the Immigration and
Checkpoints Authority (ICA) officer. STBTs should
monitor the expiry of their STVP to avoid
overstaying in Singapore.
Permitted activities
STVP holders are not permitted to engage in any
work, professional or paid employment activities
when in Singapore.
However, they may undertake the following activities
with a valid STVP while in Singapore:
Attend company meetings, corporate retreats or
meetings with business partners
Attend study tours or visits, training courses,
workshops, seminars and conferences as
a participant
Attend exhibitions as a trade visitor
The above activities should not involve a contract of
service or a contract for service with an employer in
Singapore.
Increasing regulatory and enforcement
scrutiny
Business trips to Singapore are intended to be
reasonably short in duration. It will be accepted that
STBTs to be undertaking business activities for an
extended duration of stay in Singapore.
Extended and frequent business visits to Singapore
may trigger additional scrutiny from the ICA upon
entry into Singapore.
Common examples of STBTs carrying out unpermitted
activities may include:
Signing of corporate documents
Foreign employees attending on-the-job training in
Singapore
Audit-related peripheral activities such as a walk
through or review of audit process with subject
matter experts and management leads
Additionally, STBTs should also restrict their presence
in offices to meeting areas that are generally
accessible to business visitors. Entering office
premises that are accessible only to employees may be
deemed to be carrying out work in Singapore. It is
possible for the Ministry of Manpower to enter offices
to conduct random checks. STBT deemed to be
carrying out work without a work pass is an offence
and will put both the company and the business
traveler at immigration non-compliance risk.
Other updates
Certain work activities may be eligible for a work pass
exemption. If applicable, an STBT may undertake work
in Singapore for a short period without a work pass.
However, the Ministry of Manpower (MOM) must be
notified of the STBT’s intention to work in an
exempted activity after entering Singapore, and
before starting the activity. It is an offence to start
work without notifying the MOM of a work pass
exemption.
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Thailand
seminar or performance of arts, culture, sports
competition or other activities as prescribed by the
Council of Ministers
Increasing regulatory and enforcement
scrutiny
The Thailand immigration authorities are
increasingly scrutinizing the following misuse of
business visa cases:
Business trips to Thailand are expected to be in
short duration. Frequent use of business visas to
enter Thailand for working will trigger scrutiny
from the immigration authorities and may lead to
an entry denial.
Travelers of certain nationalities enjoy visa
exemption or bilateral agreement, i.e., they are
entitled to a 30- or 90-day visit in Thailand
without visa or 15-day visa on arrival that are for
tourism purpose. Going on business travels using
these visas may trigger scrutiny from the
immigration authorities at port of arrival and may
lead to an entry denial.
Working in Thailand under a business visa
without a valid work permit is viewed as non
compliance for both the expatriate and the
company sponsoring the visa. Penalties for non-
compliance including fine and imprisonment will
be imposed.
Other updates
An Urgent Work Permit (Form WP.36) may be
applied in certain situations when STBTs are
required to conduct work activities in Thailand which
are necessary and urgent in nature for a period of
no more than 15 calendar days. The processing time
is one business day and application should be filed
immediately upon arrival in Thailand by the
sponsoring company in Thailand.
Entry requirement
STBTs must fulfil the following general requirements
to enter Thailand:
Have a minimum six-month passport validity
Business visa (non-immigrant visa “B”)
There are now no COVID-19 health measures for all
inbound travelers regardless of vaccination status or
traveler profile.
Non-Immigrant Visa “B” (Business)
Travelers who wish to enter Thailand for conducting
business must apply for a non-immigrant visa “B” at
the Royal Thai Embassy or Consulate-General in their
home or residence country before departure.
A single-entry visa is valid for three months and a
multiple-entry visa could be varied from three months
to one year.
Holders of this type of visa are granted a period of
stay in Thailand for 90 days.
Notes: Participants of meeting, incentives, convention
and exhibitions (MICE) event supported by Thailand
Convention and Exhibition Bureau are regarded as
tourist activities and may apply for tourist visas.
Permitted activities
There are no formal regulations providing a list of
permitted activities in Thailand for STBTs. The list
below provides common activities for STBTs with a
valid business visa, and which are exempted from
work permit requirements:
Arrangement or attendance of meeting,
expression of view, lecture or presentation in a
meeting, training, visit or
Asean Mobility Spotlight
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Vietnam
I
Entry requirement
STBTs must fulfil the following general
requirements to enter Vietnam:
Have a minimum six-month passport validity
Have proof of onward travel, i.e., tickets,
visas and more
Complete Vietnam Arrival Card declaration
Have an entry visa (applicable for
certain nationals)
There are now no COVID-19 health measures for
STBTs, regardless of vaccination status or
traveler profile.
Permitted activities
There are no formal regulations providing a list
of permitted activities in Vietnam for STBTs. The
list below provides common permitted activities
for STBTs with a valid business visa while being
in Vietnam:
Attend internal meetings, events, workshops,
training courses, orientations or
candidate interviews
Attend client meetings (no services are
allowed to be provided to the clients during
the meeting)
Visit Vietnam offices for orientations or
meetings, if needed
The above activities should not involve a service
contract or employment contract with an entity
in Vietnam.
It is worth to note that business visa can be used
for expert, executive director, business manager
or technical worker who work in Vietnam for less
than 30 days for each trip and not having more
than three trips to Vietnam in a year.
Increasing regulatory and enforcement
scrutiny
The Vietnam immigration authorities are
increasingly scrutinizing the following misuse of
business visa cases :
Business trips to Vietnam are expected to be in a
short duration. Frequent use of business visas to
enter Vietnam for working will trigger scrutiny
from the immigration authorities and may lead
to an entry denial.
Using “ghost” companies for business visa
sponsorship will put the expatriates at risk of
being included in the blacklist of immigration
authorities. Consequently, they are not allowed
to enter Vietnam in the future.
Working in Vietnam under a business visa but
without a valid work permit is viewed as non-
compliance for both the expatriate and the
Vietnam company that sponsors the
visa. Penalties for non-compliance will be
imposed and deportation will be executed.
Other updates
For those who have certain special nationalities,
i.e., Bangladesh, Sri Lanka, business visa approval
is subject to the discretion of the Vietnam
authorities and the processing time can be much
longer than expected, i.e., may take from three to
four weeks, in comparison with the standard
processing time of five working days.
Besides, STBTs from 80 listed countries can
apply for e-visas for business activities. The
duration to obtain for the visa for those are in the
list is from three to five working days.
Country contacts
Asean Mobility Spotlight
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Christopher Lim
Asean Immigration Lead
+60 3749 58378
Panneer Palaniandy
EY Asean PAS Integrated Mobile Talent Leader
+65 6309 8483
Indonesia
Kartina Indriyani
+62 2152 895240
Malaysia
Cynthia Wong
+60 12 323 5299
The Philippines
Jackie Lou D Lamug
+63 2 8910307
Singapore
Lily Cheang
+65 6309 8670
lily.cheang@sg.ey.com
Thailand
Wai Ph’ng Ng
+662 264 9090
Vietnam
Anh Thi Kim Ngo
+84 2836 297780
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