The employing company, acting through the workplace manager (pengurus), is legally required to follow up on periodic check-up findings by addressing both the health abnormalities or disorders identified and their underlying workplace causes (Ministerial Regulation PER-02/MEN/1980, Article 3(6)). Because the regulation does not prescribe a single technical form of follow-up, concrete actions must be established together with the examining physician.
How employers follow up with the examining physician
Periodic health examinations aim to maintain workers' health and detect as early as possible any work-related influences that need to be controlled (Ministerial Regulation PER-02/MEN/1980, Article 3(1)).
Medical decisions, including conclusions on fitness for work, remain with the physician. In practice, the company acts on the physician's conclusions and recommendations, for example by adjusting job placement, restricting specific tasks, or fixing the working conditions that caused the health issue. Together with the physician, the employer or workplace manager must also draw up periodic examination guidelines suited to the nature of the work (Ministerial Regulation 2/1980, Article 3(4)).
Under Occupational Safety Law 1/1970, this statutory duty rests with the workplace manager (pengurus), defined as the person directly leading a workplace or an independent section of it (Article 1(2)). The manager must have all workers examined periodically by a physician appointed by the employer and approved by the director, meaning the official designated by the Minister of Manpower (Article 8(2) in conjunction with Article 1(4)). These provisions apply to workplaces listed in Article 2(2) of Law 1/1970. Because that list is broad and includes healthcare undertakings among many others, each company should verify how its workplace category maps to the statutory list.
Special examinations, the two-month reporting window, and dispute resolution
When periodic check-ups indicate specific health concerns, Ministerial Regulation PER-02/MEN/1980 and current health regulations set out three follow-on procedures:
- Special health examinations: Workers suspected of experiencing specific health disorders must undergo targeted special health examinations as needed (Article 5(2)(c)), and the company must prepare an examination plan (Article 6(1)).
- Reporting to the manpower authority: The workplace manager must submit an examination report to the manpower authority no later than two months after the examination is completed (Article 6(2); the 1980 text designates the Director General of Industrial Relations and Manpower Protection through the Regional Office, without specifying the report contents). Where an appointed administering body detects an occupational disease during a periodic examination, it must likewise report the finding to the Directorate General (Ditjen Binalindung) through the Regional Office (Article 4). Beyond the 1980 regulation, Government Regulation 28/2024, Article 240 assigns occupational health recording and reporting duties to employers, workplace managers or administrators, and/or healthcare facilities in accordance with statutory regulations.
- Dispute resolution: Disputes over periodic examination findings are resolved by the Regional Health Advisory Board (Majelis Pertimbangan Kesehatan Daerah) (Article 8(1)). A party that disagrees with its decision may appeal to the Central Health Advisory Board (Majelis Pertimbangan Kesehatan Pusat) within 14 days from the regional board's decision date (Article 8(2)). The workplace manager bears the cost of examinations ordered by the board (Article 9).
Medical record confidentiality and employer cost obligations
Following up on MCU findings does not entitle the company to read each worker's detailed medical record. Personal health data confidentiality is guaranteed under Health Law 17/2023, Article 4(1)(i). Medical practitioners and health workers are bound to keep patients' personal health secrets confidential (Article 301(1)), including examination results and diagnoses (Government Regulation 28/2024, Article 788(3)(b)).
Under Government Regulation 28/2024, Article 783(4), medical record contents may only be disclosed to the extent necessary:
- With patient consent for the purposes set out in paragraph (5), such as at the patient's own request; or
- Without patient consent solely for the statutory purposes in paragraph (11), such as law enforcement and outbreak control.
In practice, the company receives the physician's fitness conclusion or work restriction recommendations, while granular clinical details may only be shared where permitted by law and worker consent (see our analysis on whether HR can receive worker medical check-up results).
Regarding costs, employers are legally obliged to bear the expenses for occupational diseases, health disorders, and work-related injuries suffered by workers in accordance with statutory regulations (Health Law 17/2023, Article 100(3)).
Micromeet builds governed healthcare AI infrastructure for continuous care. Clinicians and authorized staff review consequential outputs.
Statutory penalties and how current regulations fit together
The workplace manager is responsible for ensuring compliance with the 1980 Ministerial Regulation (Article 6(3)). Failure to comply carries a criminal penalty of up to three months' detention (kurungan) or a fine (Ministerial Regulation 2/1980, Article 10, referring to Occupational Safety Law 1/1970, Article 15(2)), classified as a regulatory violation (pelanggaran) (Law 1/1970, Article 15(3)).
Although Ministerial Regulation PER-02/MEN/1980 was issued in 1980, it now operates alongside Health Law 17/2023 and Government Regulation 28/2024. Health Law 17/2023, Article 99(5) requires employers and workplace managers to comply with occupational health standards, while Government Regulation 28/2024, Article 233(5) classifies health examinations and fitness-for-work assessments as preventive measures. Under Article 241(2)(b) of that Government Regulation, workplace standards for company employees are governed by regulations of the minister responsible for manpower affairs.
Under a governed healthcare AI workflow such as MCU CoPilot and Care Loop, the separation between clinical follow-up and workplace action follows the principle AI writes, doctors decide: the system helps structure draft reports and follow-up plans for physician review, while the employer receives only the authorized fitness conclusion without exposing the worker's confidential medical record.
Legal basis
- Ministerial Regulation PER-02/MEN/1980: Articles 3, 4, 5, 6, 8, 9, and 10.
- Occupational Safety Law 1/1970: Articles 1, 2, 8, and 15.
- Health Law 17/2023: Articles 4, 99, 100, and 301.
- Government Regulation 28/2024: Articles 233, 240, 241, 783, and 788.
FAQ
What is an employer's primary obligation when a periodic MCU finds a worker health issue? Under Ministerial Regulation PER-02/MEN/1980, Article 3(6), the workplace manager is required to follow up on the finding by addressing both the health abnormality or disorder identified and its underlying workplace causes in coordination with the examining physician.
Does employer follow-up mean the company can read the worker's full medical record? No. The confidentiality of personal health data is protected under Health Law 17/2023 (Articles 4 and 301) and Government Regulation 28/2024 (Articles 783 and 788). In practice, the company receives the physician's fitness-for-work conclusion or work restriction recommendations, while detailed medical findings may only be disclosed where permitted by law and worker consent.
What is the deadline for submitting periodic health examination reports to the manpower authority? Under Ministerial Regulation PER-02/MEN/1980, Article 6(2), the workplace manager must submit the health examination report to the manpower authority no later than two months after the examination is completed.
