The increase in Chinese foreign direct investment in Indonesia has encouraged the growth of Chinese foreign direct investment companies that bring human resource management systems, work culture, and regulatory orientations from their home country. Differences between Chinese and Indonesian labor regulations, along with cultural differences between Chinese workers and local employees, create challenges in implementing HRM systems that are legally compliant, adaptive, and organizationally effective. This study aims to identify the characteristics of Chinese labor regulations that influence HRM systems in Chinese foreign direct investment companies, analyze the influence of Chinese work culture on HRM implementation, identify the factors that cause differences in HRM practices between China and Indonesia, and formulate a conceptual model of an adaptive HRM system. This study adopts a qualitative approach based on a Systematic Literature Review guided by PRISMA 2020, using narrative synthesis and analysis through open coding, axial coding, and selective coding of scholarly literature published between 2015 and 2025. The synthesis results indicate that HRM systems in Chinese foreign direct investment companies are influenced by a combination of regulatory compliance, parent-company standardization, localized SOPs, expatriate deployment, cross-cultural communication barriers, and the need to adjust to Indonesian labor law. This article contributes to the development of International Human Resource Management, Cross Cultural Management, and Regulatory Compliance studies by offering a conceptual model of an adaptive HRM system for Chinese foreign direct investment companies in Indonesia.
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