Indonesian Hospitals: Key Regulatory Changes to Hospital Classification, Investment and Operations

Indonesia's hospitals sector is undergoing significant regulatory change. On 4 June 2026, the Ministry of Health (MOH) issued Regulation No. 6 of 2026 on Hospitals (Regulation 6), which came into force on 12 June 2026. Regulation 6 changes the regulatory framework for hospitals in Indonesia, ranging from hospital classification and investment thresholds to minimum service requirements, operational obligations and enforcement.

While some key changes will need clarifying through implementing regulations, Regulation 6 represents a fundamental shift in the regulation of Indonesia's hospital industry that will have significant implications for both existing hospital operators and prospective investors. In this article, we summarise the key developments relevant to hospital operators and investors.

Hospital classification overhauled: new grading system for services

Before Regulation 6, hospitals were classified under categories A through D by reference to the minimum number of inpatient beds, among other things. Regulation 6 replaces those categories with a "service capability" grading system determined by the level of service provided for a particular service group – comprehensive (paripurna), primary (utama), intermediate (madya) or basic (dasar).

Service capability is defined as a hospital's ability to provide health services within a particular service group, based on diagnoses and procedures performed by competent medical and health personnel, supported by medical facilities, equipment and infrastructure. A hospital can hold different grades for different service groups.

The detailed grading criteria will be set out in future implementing regulations. Until then, there is no formal conversion framework for hospitals to assess and re-classify their current categorisation. However, MOH socialisation materials suggest that the tiers will be differentiated by the level of complexity of the services that can be delivered under each grade, from the lowest (basic) to the highest (comprehensive). Pending issuance of the implementing regulations, hospital operators retain their current classifications.

Foreign investment: lower thresholds, new service conditions

General hospitals. Regulation 6 revises the minimum number of inpatient beds for foreign investment (penanaman modal asing) hospitals (PMA hospitals) from 200 inpatient beds to either (a) at least 50 inpatient beds with at least one comprehensive-grade service, or (b) at least 200 inpatient beds with at leasttwo comprehensive-grade services. Hence, the requirement to provide two comprehensive-grade services applies once a PMA hospital reaches the 200-bed threshold. In contrast, domestic investment (penanaman modal dalam negeri) hospitals (PMDN hospitals) must simply have at least 50 inpatient beds and two basic-grade services.

Specialist hospitals. Hospitals operating certain single specialist services (pelayanan unggulan), which are limited to ophthalmology; ear, nose and throat (ENT); and dental and oral services (i.e. specialist hospitals in these areas), face lower minimum inpatient bed thresholds and different service grade requirements. The service grade required for a specialist hospital in these areas depends on whether it is a PMA or PMDN hospital, as summarised in the table below.

* The relevant provision on ophthalmology and ENT specialist care hospitals uses the conjunctive "serta" (meaning "as well as"), which suggests that the reduced inpatient bed threshold applies only where both services are offered together. However, the publicly available MOH socialisation session has indicated that each service should qualify independently.

Article 10(9) of Regulation 6 provides that a specialist hospital providing ophthalmology, ENT, or dental and oral services which then adds specialised services other than ophthalmology, ENT or dental and oral services must comply with the full inpatient bed and service grade requirements applicable to general hospitals. However, it remains unclear whether the provision of routine ancillary or supporting services, as distinct from the addition of a new specialist service (pelayanan unggulan), would trigger this. Pending issuance of the implementing guidelines on these issues, investors should seek confirmation from the MOH before relying on the reduced inpatient bed threshold.

Exemption for PMA hospitals. PMA hospitals that invest in a hospital group established to contribute toward meeting national healthcare service needs may be exempted from both (i) the minimum inpatient bed and comprehensive-grade service conditions applicable to PMA hospitals generally and (ii) the minimum inpatient bed and/or comprehensive-grade service conditions applicable to specialist PMA hospitals providing ophthalmology, ENT and dental and oral services. The applicability of this exemption depends on the cumulative investment value and the shareholding percentage of the investment, but the MOH has yet to determine the specific criteria. Accordingly, the scope and practical application of this exemption remain unclear until the MOH issues regulations setting out those criteria.

Since the service capability grading criteria under Regulation 6 are not yet defined, existing hospital operators are not yet able to determine how the new grading system will impact their current licences and service classifications. For potential investors, the reduction of the minimum inpatient bed threshold to 50 beds for PMA hospitals appears significant. However, the practical implications of the service capability grading criteria, the scope of exemptions for investments in hospital groups that contribute towards meeting national healthcare service needs, and the conditions applicable to specialist care hospitals all require further clarification from the MOH.

Minimum services expanded

Up to now, hospitals have only been required to offer three broad types of services:

1.  medical and medical support services (pelayanan medik dan penunjang medik);
2. nursing and maternal care services (pelayanan keperawatan dan kebidanan); and
3. non-medical services (pelayanan non-medik).

Regulation 6 replaces these three types of services with a more detailed list of 12 mandatory service types that all hospitals must provide:

1. medical (medik);
2. intensive care (intensif);
3. surgical (bedah);
4. nursing (keperawatan) and/or maternity care (kebidanan);
5. pharmaceutical (kefarmasian);
6. laboratory (laboratorium);
7. radiology (radiologi);
8. blood (darah);
9. nutrition (gizi);
10. mortuary (pemulasaraan jenazah);
11. central sterilisation (sterilisasi sentral); and
12. maintenance of health facilities, infrastructure and equipment (pemeliharaan sarana dan prasarana serta alat kesehatan).

The first seven service types listed must be provided directly by the hospital while the remaining five types may be provided in collaboration with third parties. Any existing hospitals that do not yet provide all 12 service types should upgrade their facilities promptly during the transitional period.

Tariff framework: regulatory vacuum for Non-JKN pricing

For healthcare services provided outside Indonesia’s national health insurance programme (Non-JKN), Regulation 6 requires hospitals to set their tariffs based on the national tariff framework (pola tarif nasional) set by the MOH, and the maximum tariff ceiling (pagu tarif maksimal) set by the provincial governor. Where maximum provincial tariffs have not been set, national tariffs will apply. The national tariff framework will be reviewed and assessed at least once every five years.

MOH Regulation 85 of 2015 on National Tariffs for Hospitals (Regulation 85), which was revoked by Regulation 6, expressly described the national tariff framework as basic guidelines (pedoman dasar) providing a reference point. Although Regulation 6 no longer uses that characterisation, neither regulation contains any sanctions in respect of tariff obligations. So, in practice, the national tariffs operate more like a pricing benchmark than a price-control mechanism.

Separately, Article 71(3) of Regulation 6 provides that maximum tariff ceilings will be set by the provincial governor by referring to national tariffs and considering local conditions. However, it is not yet clear how the tariff ceiling mechanism will be implemented, and whether it is intended to act as a price control mechanism. Notably, Regulation 6 does not prescribe sanctions for non-compliance, which suggests that the tariff framework as a whole is intended to function as a pricing reference tool.

Since Regulation 85 has been revoked by Regulation 6 but not yet replaced, there is now a regulatory vacuum on the applicable pricing reference for Non-JKN hospital tariffs. Meanwhile, hospitals that are in the JKN programme follow a separate tariff structure under existing JKN regulations, which remain in force and are unaffected.

New financial reporting requirements and health system integration

Audited financial statements. Regulation 6 contains a new requirement for hospitals to submit audited financial statements to the MOH on an annual basis, or at such other times as the MOH may require. Non-compliance may lead to administrative sanctions. The submission mechanism and designated platform are not specified. In the interim, operators should ensure that audited financial statements are prepared.

Health information system integration. Hospitals must record and report their operational activities through a Health Information System (Sistem Informasi Kesehatan or SIK) that is integrated with the national health platform (Sistem Informasi Kesehatan Nasional or SIKN). Changes to hospital data should be updated promptly, with failure to comply being subject to sanctions.

Concurrent hospital leadership roles

MOH Regulation 3 of 2020 regarding Classification and Licensing of Hospitals had prohibited hospital executives (pimpinan rumah sakit) from concurrently holding managerial positions at other hospitals. Following that regulation's revocation by Regulation 6, this restriction no longer applies. Accordingly, concurrent appointments of hospital executives should now be governed by the hospital's internal governance rules (peraturan organisasi rumah sakit) overseen by its supervisory board (dewan pengawas).

Sanctions and accreditation as enforcement tools

Regulation 6 restructures the sanctions regime by introducing a clear escalation mechanism consisting of (a) verbal warnings, (b) written warnings (which may include an order to replace the chief executive), (c) administrative fines, (d) adjustment or revocation of accreditation, and (e) revocation of the business licence.

Notably, Regulation 6 introduces the adjustment or revocation of a hospital's accreditation as a new form of administrative sanction. This gives the competent authorities (the MOH, governor and/or regent) the power to directly intervene in relation to a hospital's accreditation as a punitive consequence of non-compliance without having to wait for the licence renewal process, as was previously the case.

In Indonesia, a hospital has to be accredited in order to access Indonesia’s national health insurance programme by contracting with the Indonesian Social Security Agency for Health (BPJS Kesehatan). The practical impact of accreditation-based sanctions is therefore significant. Under MOH Regulation No. 71 of 2013 on Healthcare Services under the National Health Insurance Programme (as amended), hospitals must hold a valid accreditation certificate to contract with BPJS Kesehatan. Revocation of accreditation would therefore result in immediate loss of eligibility to treat JKN patients.

Transitional period

All hospitals have two years to comply with Regulation 6, and so they must do so by 12 June 2028, save for Class D Pratama hospitals (a now no longer recognised hospital category used for remote and underserved areas), which have four years to comply.

Conclusion

Regulation 6 is the most significant overhaul of Indonesia's hospital regulatory framework in recent years. The direction is clear, with a shift towards service capability-based classification, lower barriers to foreign investment, increased operational obligations, and stronger enforcement.

The practical effects of some of the key provisions of Regulation 6 – including the service capability grading criteria, tariffs, group hospital exemptions, and the national health information platform – will only become clear once the relevant implementing regulations are issued.

As the regulatory framework continues to evolve, hospital operators and investors should closely monitor further developments as they navigate an increasingly detailed and compliance-driven regulatory environment.