What does Indonesia's Job Creation Law (UU 6/2023) regulate regarding periodic examinations?

Law Number 6 of 2023 on Job Creation (UU 6/2023) does not alter periodic worker health examination rules. The term "Periodic Examination" (Pemeriksaan Berkala) inside UU 6/2023 refers to periodic building functional reliability inspections. The obligation to arrange periodic medical examinations for workers comes from other regulations, primarily Law Number 1 of 1970 (UU 1/1970) and Permenaker PER.02/MEN/1980.

Periodic building examinations in UU 6/2023

UU 6/2023 enacts Government Regulation in Lieu of Law Number 2 of 2022 (Perppu 2/2022) into law (Article 1). Amending multiple sectoral statutes including Law Number 28 of 2002 on Buildings (UU 28/2002). Under amended UU 28/2002, Periodic Examination means inspecting building reliability, components, and infrastructure at set intervals to declare functional worthiness (Article 1 point 6). Building owners and/or users—including clinics and hospitals—must carry out these inspections (Article 41(2)(d)) and hold a functional worthiness certificate (SLF) under Article 37(1).

Where periodic worker health examinations are regulated

The employment cluster of UU 6/2023 (Article 81) amends several provisions of Law Number 13 of 2003 (UU 13/2003). Such as fixed-term contracts, outsourcing, working hours, wages. Furthermore, Termination, but leaves Articles 86 and 87 on occupational safety and health untouched. It also does not amend UU 1/1970.

The duty to have workers examined resides in UU 1/1970 Article 8(2). Workplace managers must have all workers under their supervision periodically examined by a physician appointed by the employer and approved by the Director. Permenaker PER.02/MEN/1980 specifies that a physician conducts this examination at least once a year unless directed otherwise (Article 3(2)). In addition, PP 28/2024 includes health examinations and fitness-for-work assessments as mandatory workplace preventive efforts (Article 233(5)(d)–(e) and Article 241(1)).

Implications for clinics, HR teams, and hospital managers

Employee MCU obligations rest on UU 1/1970, Permenaker PER.02/MEN/1980, and PP 28/2024. The examining physician determines the examination conclusions, including fitness for work. Because health data is specific personal data under UU 27/2022 Article 4(2)(a). Any disclosure to the employer requires a valid legal processing basis under Article 20(2).