Indonesia is introducing major changes to its regulatory framework for private health insurance products. The changes include new co-payment requirements, waiting periods, benefit coordination, and enhanced criteria for health insurance providers. The changes announced in a circular letter were originally set to take effect on 1 January 2026 but have been deferred until regulations are issued.
Background
In Indonesia, Badan Penyelenggara Jaminan Sosial Kesehatan (“BPJS Kesehatan”) is the social security-funded national health insurance scheme which provides low-cost healthcare coverage to all Indonesian citizens and foreign nationals residing in Indonesia for at least six months. Private health insurance products provide broader coverage and are often employer-sponsored or purchased individually to supplement BPJS Kesehatan coverage.
On 19 May 2025, the Financial Services Authority of Indonesia (OJK) issued Circular Letter No. 7/SEOJK.05/2025 outlining new requirements for private health insurance products (the “Circular Letter”). These were meant to take effect on 1 January 2026, with all auto-renewing insurance products subject to compliance by 31 December 2026.
However, OJK announced on 12 July 2025 that the provisions within the Circular Letter have been deferred and will instead be regulated in an upcoming OJK Regulation on Strengthening the Health Insurance Ecosystem.
Key details
The most relevant details for employers to note include the following:
Co-payment requirement
All new and renewed indemnity-based health insurance policies (where medical care costs are reimbursed up to caps as set in the policies) will be required to include a co-payment scheme. Policyholders must bear at least 10 % of the total claim cost for both inpatient and outpatient services, with a maximum co-payment limit of IDR 300,000 per outpatient claim and IDR 3,000,000 per inpatient claim. Insurers may apply higher maximum co-payment limits if these are agreed with the policyholder in the policy terms. This mechanism aims to promote cost awareness and maintain affordable premiums over the long term.
This new co-payment requirement will also apply to managed care schemes, which provide comprehensive healthcare including health promotional, preventive, curative, rehabilitative and palliative care and typically cover almost all costs in-network, for services at higher-tier healthcare providers.
Waiting period
Individual health insurance products will be required to have a waiting period (the amount of time the policyholder must wait before specific benefits may be used) of up to 30 calendar days. A waiting period of up to one year may be applied for products that provide benefits for critical, chronic, or specific illnesses, provided this is clearly stated in the insurance policy.
Group health insurance products may apply a different waiting period than those required for individual policies, based on the agreement made between the policyholder and the insurer.
Coordination of benefits
Insurers must include a feature in health insurance products that allow coordination of benefits between insurers and other insurance providers, including BPJS Kesehatan. Coordination of benefits ensures that when a policyholder has multiple health coverages, payments are properly allocated to that insurers share costs without overlaps, enabling smooth integration between commercial health insurance and national health coverage.
Underwriting and health checks
For individual health insurance policies, insurers must consider implementing medical check-ups based on risk profiles for prospective policyholders, in line with their underwriting policy at the time of policy issuance. For group health insurance policies, insurers must obtain a claims performance report from the Association of Insurance Companies and Sharia Insurance Companies (setting out information including premiums paid, claims paid, loss ratios, etc.) prior to policy placement.
Strengthening medical oversight and digital infrastructure
Insurers offering health insurance products will be required to have the following in place:
Qualified medical staff capable of clinical analysis and utilization reviews of healthcare services.
Certified health insurance staff.
A dedicated Medical Advisory Board to advise on medical policies and service efficiency.
Robust digital systems to facilitate data exchange with healthcare providers to support effective cost control, provide data-driven oversight and prevent potential fraud.
Employer action: PREPARE TO ACT
Employers should review existing health insurance plans to understand how the new requirements could affect policy design and costs. As OJK has deferred the changes announced in the Circular Letter, employers should also monitor communications from their Lockton Consultant and local insurers on any developments and their expected impact on existing policies. However, existing policies renewed before the government issues regulations and confirms the implementation date are unlikely to be impacted by the changes.
Once the new regulations are released, the Lockton Global People Solutions Compliance Practice will update this article accordingly.
Further Information
Monthly Board of Commissioners Meeting | OJK International Information Hub (opens a new window)
