Who bears the cost of worker medical examinations (MCU) under Indonesian law?

In principle, the company bears the obligation. Worker medical examinations must be organized by workplace managers and employers under Law Number 1 of 1970 (UU 1/1970 Article 8). Furthermore, Government Regulation Number 28 of 2024 (PP 28/2024 Article 241(1)). Law Number 17 of 2023 (UU 17/2023 Article 100(3)) also requires employers to bear the costs of occupational diseases, health disorders. In addition, Work injuries in accordance with statutory regulations, although that paragraph does not mention examination fees. Among the regulations reviewed here, no single clause explicitly states that all routine medical examination fees are paid by the company. The only fee clause in Permenaker PER-02/MEN/1980—Article 9—covers examinations ordered by the Health Consideration Council. Thus, employer responsibility derives from the combined duty to organize and fund occupational health efforts.

Who is required to organize the examinations

UU 1/1970 Article 8(1) requires the workplace manager (pengurus) to have the physical health, mental condition, and physical capability of prospective or transferring workers examined. Article 8(2) requires periodic examinations for all workers by a physician appointed by the employer. Permenaker PER-02/MEN/1980 specifies that companies must conduct pre-employment examinations (Article 2(2)), periodic examinations (Article 3(2)). In addition, Special examinations under conditions listed in Article 5, with compliance responsibility resting on the manager (Article 6(3)).

Newer regulations align with this duty. PP 28/2024 includes medical examinations and fitness-for-work assessments within preventive occupational health efforts (Article 233(5)). This Employers and managers must organize (Article 241(1)) and workers are entitled to receive (Article 242(1)). PP 88/2019 was repealed by PP 28/2024 Article 1170 letter w and replaced by Articles 232 to 244 of PP 28/2024.

What the statutes explicitly say about costs

In Permenaker PER-02/MEN/1980, the word "cost" (biaya) appears only in Article 9 with a narrow scope. The manager is responsible for the cost of periodic or special examinations ordered by the Regional or Central Health Consideration Council to resolve disputes over examination results (Article 8). Article 9 should not be misread as a general cost clause for all examinations.

Meanwhile, UU 17/2023 Article 100(3) requires employers to bear the costs of occupational diseases, health disorders. In addition, Work injuries suffered by workers in accordance with statutory regulations. That paragraph addresses illness or injury costs rather than preventive check-up fees.

Article 239 of PP 28/2024 sets out permissible funding sources for occupational health efforts: health social security. Furthermore, Employment social security in accordance with statutory regulations, other health insurance, or full workplace funding. While Article 239 lists funding channels, the duty to organize occupational health efforts remains with the employer and manager (Article 241(1)).

For pre-employment check-ups, Permenaker PER-02/MEN/1980 Article 2(2) states only that the company must hold them. At the same time, Article 100(3) of UU 17/2023 addresses individuals who are already workers. Those provisions do not explicitly settle who pays for pre-employment check-ups of applicants who are not yet hired.

Paying for the examination does not grant access to full clinical records

Every person has the right to confidentiality over their personal health data (UU 17/2023 Article 4(1)(i)). In addition, Medical and health personnel must maintain patient confidentiality (Article 301(1)). Therefore, even when the company funds the examination, individual clinical reports remain with the patient. Furthermore, Medical team while the employer receives only fitness-for-work conclusions permitted under confidentiality rules.