In December 2025, the Financial Services Authority (OJK) issued OJK Regulation (POJK) No. 36/2025, regulating the strengthening of the health insurance ecosystem in Indonesia. The POJK covers health insurance products, which are defined as “insurance products providing cover for one or more types of risk related to the insured’s health or a decline in the insured’s health conditions”.

In this POJK, some of the provisions of a previous OJK Circular Letter (SEOJK) have been revised. Notably, insurers must sell health insurance products without co-payment features (while limits remain applicable to products with co-payment features), and the waiting period for critical and chronic illness benefits has been shortened. New provisions have also been introduced, such as new restrictions on repricing exercises and requirements to conduct public awareness programs on healthy lifestyles. Meanwhile, certain requirements have remained unchanged, such as those for coordination of benefits, digital integration, a medical advisory board, and fraud detection systems. The OJK has set an implementation period of one year from the POJK issue date. During this transition period, companies are expected to adjust their operational governance and products to comply with the new POJK. This e-alert provides a summary of the POJK, with comparisons against the previous SEOJK where relevant, and offers some insights on the new regulation’s likely impact.

Key provisions of the POJK include:

• Copayment: Implementation of co-payment schemes and health insurance product variants
• Coordination of benefits: Organization and sharing of benefit liabilities with other insurance providers and benefit administrators
• Product design: New guidelines for underwriting, repricing, and waiting period
• Operational requirements: Digital integration with healthcare providers, medical advisory functions, data governance, public awareness, and third-party administrators