I know that has been the case for quite some time, but I encountered some information that said it has changed with implementation of PerPres 20/2018 such that Director/Commissioner with ownership need to move to 313 without IMTA and Director(/Commissioner?) without ownership will stay on 312, with IMTA, and will (now) need to fit the position. I admit I may have misunderstood or misremembered, I will try to find that source again.There is no education or expertize criteria for directors or commissioners.
