Under Indonesia's occupational health rules, workplace management (pengurus) must prepare and submit a report no later than two months after a worker health examination is conducted (Ministerial Regulation PER-02/MEN/1980, Article 6(2)). In the text of that 1980 regulation, the report is addressed to the Director General of Labor Protection Relations (Direktur Jenderal Pembinaan Hubungan Perburuhan dan Perlindungan Tenaga Kerja) through the local regional office.
Because this ministerial regulation was enacted on 13 March 1980 and names organizational units from that era, employers and clinics should verify the current receiving unit and submission channel with their local manpower authority (Dinas Ketenagakerjaan) before filing. Its current procedural standing should also be confirmed against local administrative guidance.
Who Must Report, and Which Examinations Are Covered?
The general two-month reporting obligation rests on workplace management (pengurus), not the examining physician (Ministerial Regulation PER-02/MEN/1980, Article 6(2)).
Under the Work Safety Act (Law No. 1 of 1970):
- Management (pengurus) means the person directly leading a workplace or an independent section of it (Article 1(2)).
- Covered workplaces explicitly include businesses in the healthcare sector (Article 2(2)(d)). As a result, clinics and hospitals are also bound by these employer obligations for their own staff.
Which types of medical check-ups are covered?
- Article 6(1) requires employers to draw up examination plans covering all three statutory categories: pre-employment, periodic, and special examinations.
- Article 6(2) does not distinguish among the three, meaning the two-month reporting window applies across all examination types.
For mass or multi-wave check-ups, the text of Article 6(2) does not specify whether the two-month clock runs per individual worker or from the completion of an examination batch. The safest practice inside a structured MCU reporting workflow is to log the exact date of each examination and confirm how the local manpower office calculates batch deadlines.
What Goes Into the Report—and Where Do Privacy Boundaries Sit?
Article 6(2) simply requires a "report," while Article 7(3) states that the reporting form is determined by the Director. Neither provision mentions submitting individual clinical diagnoses or full personal medical records.
At the same time, Indonesia's Personal Data Protection Act (Law No. 27 of 2022) classifies health data and information as specific personal data (Article 4(2)(a)). Statutory reports submitted to government authorities should therefore stay strictly within the fields requested by the official form, without attaching individual clinical records that are not legally required.
Alongside management's general reporting duty, Ministerial Regulation PER-02/MEN/1980 establishes two separate obligations that should not be conflated:
- Reporting occupational diseases (Penyakit Akibat Kerja) by appointed examining bodies: An examining body appointed by the Director General to conduct periodic examinations (Article 3(8)) must report any occupational diseases it identifies to the Directorate General through the regional office (Article 4).
- Following up abnormal findings by management: When periodic examinations uncover health abnormalities, workplace management must follow up on those findings and address their causes to protect occupational safety and health (Article 3(6)).
Management that fails to comply with this ministerial regulation faces criminal penalties under Law No. 1 of 1970 Article 15(2) (Ministerial Regulation PER-02/MEN/1980 Article 10), where the offense is classified as a misdemeanor (pelanggaran, Law 1/1970 Article 15(3)).
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How Do Newer Occupational Health Regulations Fit In?
Newer health regulations have updated how occupational health recording and reporting are framed nationally:
- Government Regulation No. 88 of 2019 has been repealed: Article 14(2) of that earlier occupational health regulation required tiered reporting to central and regional governments for occupational health surveillance. However, that regulation was expressly repealed by Government Regulation No. 28 of 2024 (PP 28/2024) Article 1170(w).
- National integration under PP No. 28 of 2024: Its replacement, PP 28/2024 Article 240, provides that occupational health recording and reporting are carried out by employers, workplace management or operators, and/or healthcare facilities, integrated with the National Health Information System (Sistem Informasi Kesehatan Nasional).
- Delegation to implementing rules: Article 240 of PP 28/2024 does not state a specific deadline or receiving office, leaving those details to further regulations. For workplace occupational health standards in companies, Article 241(2)(b) points to regulations issued by the minister responsible for manpower affairs.
Notably, the repeal lists in PP 28/2024 Article 1170 and Ministerial Regulation No. 5 of 2018 Article 73 do not list Ministerial Regulation PER-02/MEN/1980 as repealed, though that alone does not prove every 1980 administrative detail remains unchanged outside the statutory text.
Finally, occupational health check-up reports should not be confused with workplace environment testing and inspection reports, which are governed separately under Ministerial Regulation No. 5 of 2018 Article 65(2). In a governed healthcare AI workflow such as MCU CoPilot and Care Loop, statutory compliance follows the principle AI writes. Doctors decide.: the platform helps organize examination dates, compile aggregate workplace compliance metrics, and separate physician-approved fitness conclusions from workers' confidential medical records before filing.
Legal basis
- Minister of Manpower and Transmigration Regulation No. PER-02/MEN/1980: Articles 3(6), 3(8), 4, 6(1)–(3), 7(3), and 10.
- Law No. 1 of 1970 on Work Safety: Articles 1(2), 2(2)(d), 15(2), and 15(3).
- Law No. 27 of 2022 on Personal Data Protection: Article 4(2)(a).
- Government Regulation No. 28 of 2024: Articles 240, 241(2)(b), and 1170(w).
- Government Regulation No. 88 of 2019: Article 14(2) (repealed by PP 28/2024 Article 1170(w); no longer in force).
- Minister of Manpower Regulation No. 5 of 2018: Articles 65(2) and 73.
FAQ
What is the deadline for submitting worker medical check-up reports in Indonesia? Under Ministerial Regulation PER-02/MEN/1980 Article 6(2), workplace management must submit the report no later than two months after the health examination is conducted. Because the regulation dates from 1980, employers should confirm the current receiving unit and official form with their local manpower authority.
Who is responsible for submitting the general MCU implementation report: the doctor or workplace management? Article 6(2) of Ministerial Regulation PER-02/MEN/1980 assigns the general two-month reporting obligation to workplace management (pengurus). Separately, an appointed examining body conducting periodic check-ups must report any occupational diseases it discovers under Article 4.
Does the statutory report to the manpower office include individual worker diagnoses? Articles 6(2) and 7(3) of Ministerial Regulation PER-02/MEN/1980 refer only to the official reporting form set by the Director and do not mention individual diagnoses. Because health data is specific personal data under Law No. 27 of 2022 Article 4(2)(a), submissions should be limited strictly to what the official form requires.
Is Government Regulation No. 88 of 2019 still in force for occupational health reporting? No. PP No. 88 of 2019 was repealed by Government Regulation No. 28 of 2024 Article 1170(w). Under PP 28/2024 Article 240, occupational health recording and reporting are conducted by employers, workplace management, and/or healthcare facilities and integrated with the National Health Information System.
