Indonesian Seafood Factory Audit: Essential 2026 Buyer Guide

A 48‑hour, step‑by‑step UFLPA-focused audit kit for Indonesian seafood processors. What to collect, how to trace lots to vessel/farm, worker interview flows in Bahasa, payroll/BPJS red flags, and the corrective actions that actually keep products out of CBP detention.

If you’re buying seafood from Indonesia in 2026, you can’t wing UFLPA. CBP wants proof of no forced labor from the pond or vessel, through the plant, to your importer of record. We’ve sat on both sides of the table, and the buyers who avoid detentions do one thing consistently. They run a tight 48‑hour on-site audit that generates a clean, evidence-rich file before a single carton ships.

Here’s the exact system we use.

The three pillars that keep seafood out of CBP detention

People and pay. Prove there’s no forced labor. That means zero-cost recruitment, legal hours, correct overtime, and active BPJS. In our experience, payroll and BPJS tell the truth quickly if you know where to look.
Physical traceability. Connect finished goods to a specific vessel or farm. Not “area” or “fleet.” You need lot-level links and documents that survive CBP scrutiny.
Paper integrity. Policies, contracts, and logs that align with practice. CBP will test consistency across timecards, pay, production yields, cold-store in/out, and shipping.

The 48‑hour UFLPA on-site audit kit (what we actually do)

We assume a medium-sized processor in Surabaya or Medan. Adjust the depth for micro or multi-plant chains. This is UFLPA-focused. We’re not covering HACCP or quality here.

Hour 0–6: Kickoff and document grab

Company and labor files. Latest org chart. Complete worker roster with join date, contract type (PKWT/PKWTT), position, wage. Copies of employment contracts, job ads, and any recruitment agent agreements. Recruitment fee “zero-cost” policy.
Payroll and time. Last 6 months of payroll, timecards or biometrics export, overtime approvals, bank transfer proofs, payslips, any cash ledger. THR (13th month) payment proof. Deduction logs (kasbon/loans, koperasi, uniforms, meals, housing).
BPJS. Participant list with NIK, join dates, and contribution records for BPJS Ketenagakerjaan (JHT, JKK, JKM, JP) and BPJS Kesehatan. Evidence of premium payment and base wage used for calculation.
HR and identity handling. Passport/ID storage policy, custody logs, locker assignments, dormitory roster if applicable, grievance channel records (hotline/box), termination/resignation logs.
Supply chain and lots. Approved supplier list. For each raw material used in the last 90 days, collect purchase orders, receiving notes, cold store inbound logs, lot creation records, production batch sheets, rework logs, and finished goods lot register.
Wild-caught inputs. Vessel identity and licensing (SIPI/SIKPI), crew lists, e-logbook printouts or screenshots, landing site tickets or auction slips (TPI), landing permit/SPB, VMS/track excerpts if available, and aggregator purchase records.
Aquaculture inputs (shrimp especially). Farm ID and address, pond ID and stocking sheets, harvest ticket, transporter cold-chain records, feed invoices, water quality/PCR test if available.

Pick two finished goods lots to trace end-to-start. If you buy wild grouper or tuna, pick one wild lot (for example Grouper Fillet (IQF) or Yellowfin Saku (Sushi Grade)). If you buy farmed shrimp, pick one shrimp lot (for example Frozen Shrimp (Black Tiger, Vannamei & Wild Caught)).

Immediate red flags. Excessive overtime in high season. Negative net pay after deductions. BPJS enrollment lagging months behind start dates. “We keep passports for safety.” Any of these will slow you down.

Hour 6–24: Worker interviews that management can’t script

Private worker interview in a factory cafeteria with a same‑gender translator and an external auditor, away from supervisors.

We split interviews across departments and shifts. 60–90 minutes per group of 4–6 is typical. Use a same-gender translator. Don’t interview within sight of supervisors. Cafeteria corner or a quiet room near the clinic works. For a fuller picture, do 3–4 one-on-ones outside the gate after shift near a warung.

Sample Bahasa questions we actually use:

Perekrutan: “Apakah Anda membayar biaya untuk mendapatkan pekerjaan ini? Berapa? Dibayar ke siapa dan kapan?” Follow-up: “Ada bukti transfer atau kuitansi?”
Dokumen: “Apakah paspor/KTP Anda pernah ditahan perusahaan atau agen? Jika disimpan sukarela, apakah Anda bisa mengambil kapan saja?”
Jam kerja: “Berapa jam kerja per hari/minggu? Lembur sukarela atau wajib? Bagaimana cara menghitung upah lembur?”
Upah dan potongan: “Gaji dibayar tunai atau transfer? Ada potongan apa saja? Kasbon bagaimana prosesnya?”
BPJS: “Apakah BPJS Kesehatan/Ketenagakerjaan Anda aktif? Kapan terdaftar? Pernah dipakai?”
Kebebasan bergerak: “Apakah Anda bebas keluar-masuk asrama? Apakah ada sanksi jika menolak lembur?”
Keluhan: “Kalau ada masalah, kemana melapor? Pernah ditindaklanjuti?”

Cross-check on the spot. Match what workers say to the payslips you pulled and the BPJS join dates. Interview agency-hired and probationary workers too. That’s where fee issues hide.

Hour 24–48: Trace the lot to the vessel or pond and reconcile the math

Wild capture flow. Finished goods lot to production batch sheet to raw material intake to landing documentation. Confirm the named vessel on the landing record is licensed and not on any sanctions or UFLPA Entity List. We look for consistency in dates and yields. If 1,000 kg of Yellowfin in yielded 600 kg of saku and steaks, make sure rework and trim appear in ground meat or byproduct lots like Yellowfin Ground Meat (IQF). No gaps, no magical extra weight.

Aquaculture flow. Finished goods lot to production batch to farm harvest ticket. The farm ID should tie to pond stocking and feed invoices that make sense for biomass. Transporter logs should show temperature and timing. If a shrimp lot claims Farm A, there shouldn’t be mix-ins from Farm B without documented commingling controls.

Paper-to-physical checks. Pull 10 random worker lockers. There should be no passports. If the plant offers voluntary storage, there must be signed consents and 24/7 access logs showing same-day retrieval. Walk the dorms. Cleanliness is nice, but you’re looking for curfews, visitor bans, or fines that restrict movement.

Takeaways you can act on tomorrow. Build a zipped “UFLPA evidence pack” per lot with all above documents, photos of locker checks, interview notes, and yield math. Keep it ready before booking freight.

What documents actually prove no forced labor?

Zero-cost recruitment policy plus proof of practice. Worker declarations of no fees, signed on hire and rechecked annually. If fees were paid, repayment receipts with amounts and dates.
Payroll and time records for 6 months. Include bank slips, overtime approvals, and a summary showing rates comply with Indonesian law. Under GR 35/2021, overtime typically caps up to 4 hours/day and 18 hours/week with consent. Multipliers commonly apply at 1.5x for the first hour and 2x for subsequent weekday hours. Verify current local rules.
BPJS enrollment and payment proof matching start dates and actual wages. Trial periods don’t excuse non-enrollment.
Identity custody evidence. Locker photos. Passport custody log showing voluntary storage and unrestricted access.
Grievance effectiveness. Logs showing issues raised and resolved with dates and outcomes.
Traceability chain. Vessel/farm docs tied to specific lots, not generic origins.

Are SMETA or BSCI enough for UFLPA?

Short answer. Helpful, not sufficient. UFLPA focuses on end-to-end traceability to source, plus forced labor risk indicators aligned to ILO. A SMETA/BSCI report won’t replace vessel IDs, landing tickets, farm harvest records, and your own worker interview notes. Use them as a baseline. Then build a UFLPA annex with the lot-to-source evidence.

How do I confirm workers didn’t pay fees to brokers?

Ask for agency agreements and job ads. Any language about “placement fees” is a red flag.
Interview new hires and agency-supplied workers privately. Ask amounts, recipient, and payment method. Fees often show up as “administrasi,” “seragam,” or “medical” charges.
Scan payslips for recovery deductions in the first 3–6 months. Cross-check bank statements for large inbound transfers right before payday followed by plant withdrawals.
If fees are found, calculate full repayment including medicals, transport, and document costs. Repay within 30 days and issue receipts signed by workers.

What payroll or BPJS red flags should I look for?

BPJS join dates more than 30 days after employment start.
BPJS contribution base equals minimum wage for workers who clearly earn more through allowances. The base should reflect regular earnings.
Overtime exceeding legal caps or paid at flat rates. Gaps between time-in/time-out and paid hours.
Net pay below local UMK after deductions. Repeated cash advances with interest or penalties.
Mass identical signatures on timesheets. That screams backfill.

How do I link a shrimp or fish lot to source for UFLPA?

Wild. Vessel name and ID on landing ticket. Matching SIPI/SIKPI license. Crew list. E-logbook summary for the trip date. Purchase record from aggregator listing that vessel. Intake log with the same date and weight. Production batch sheet. Finished goods lot code.
Farmed. Farm name and address. Pond ID. Stocking and feed records leading to the harvest date. Harvest ticket and transporter log. Intake log. Production batch sheet. Finished goods lot code.

We often test this with mixed portfolios. For example, run one Grouper Fillet (IQF) lot and one Frozen Shrimp (Black Tiger, Vannamei & Wild Caught) lot in the same visit. If both chains hold up, the plant’s system is usually robust.

Can I run worker interviews without tipping off management?

Yes, but set expectations. Tell management the sample and locations in general terms, not names. Rotate time slots across shifts. Use QR codes for anonymous feedback after you leave. And do a few off-site chats. In our experience, three off-site interviews often surface what twenty in-room sessions won’t.

If you want our Bahasa script and scoring sheet, need help with your specific situation? Contact us on email and we’ll share a redacted set.

What goes in a corrective action plan if you find forced labor risk?

Root cause. Example: agency charged IDR 2,000,000 “admin” fees due to unclear zero-cost policy and weak onboarding checks.
Actions. Repay all affected workers with receipts. Terminate or retrain the agency. Update policy and contracts. Re-verify with interviews.
Owners and dates. Name the person, due date, and verification method. Most remediation can be closed inside 30–60 days if leadership commits.
Proof. Attach repayment receipts, new contracts, training records, and follow-up interview summaries.

How to respond if CBP detains your seafood

Move fast. Compile a dossier for the detained lots only. Include the full document chain, worker interview summaries, and a narrative tying dates, weights, and entities.
Screen entities. Check all parties against the UFLPA Entity List and sanctions lists. Document the negative results.
Translate. Provide English translations for key Indonesian documents. Label every page and reference it in a contents index.
Explain remediation. If you found and fixed issues before shipment, include evidence. CBP wants to see effective control.
Submit via the importer’s counsel through ACE within the timeline set by CBP. Partial, messy submissions don’t help.

The five mistakes that kill audits (and shipments)

Treating SMETA/BSCI as a UFLPA passport. It isn’t.
Skipping BPJS because “everyone’s on probation.” That excuse doesn’t fly.
Ignoring lot math. If yields don’t reconcile, CBP assumes the worst.
Interviewing in front of supervisors. You’ll get scripted answers.
Waiting until pre-shipment to start. UFLPA files take weeks to mature, not days.

Resources and next steps

Build a one-page Supplier Code of Conduct with a zero-cost recruitment clause and share the Indonesian translation during onboarding. Attach a short supplier social compliance checklist. We can share templates if you need a starting point. Contact us on whatsapp.
Stress-test traceability quarterly. Pick a tuna, a reef fish, and a shrimp lot. For tuna, test a Yellowfin Saku (Sushi Grade). For reef fish, try Grouper Fillet (IQF). For shrimp, pull one Frozen Shrimp lot. If the evidence pack is clean for all three, you’re in good shape.

Here’s the thing. UFLPA isn’t going away, and CBP’s expectations haven’t relaxed. But when you build files around people, traceability, and paper integrity, you don’t just pass audits. You ship on time without drama. That’s the goal.