Major Consolidation of Health Human Resources Management Regulation under Minister of Health Regulation Number 13 of 2025

Summary

The Regulation of the Minister of Health Number 13 of 2025 on the Management of Health Human Resources (“MOH Regulation 13/2025”) took effect on 3 November 2025.
This regulation was enacted to implement numerous mandates from Government Regulation Number 28 of 2024 on the Implementation of Law Number 17 of 2023 on Health (“GR 28/2024”), which serves as the implementing regulation of the Health Law (“Law 17/2023”). MOH Regulation 13/2025 restructures and consolidates the entire governance framework for health human resources (HHR) in Indonesia, encompassing needs planning, education (procurement), licensing systems (STR and SIP), utilization (including for foreign nationals and foreign graduates), welfare, and legal protection.

 

Background and Context

MOH Regulation 13/2025 was established to implement more than 20 provisions within GR 28/2024 related to health human resources. Prior to its issuance, the governance of HHR was fragmented across dozens of ministerial and council regulations that were partial and often overlapping. Therefore, MOH Regulation 13/2025 was issued to revoke dozens of previous regulations and to reestablish a unified, clear, and comprehensive framework for the national management of health human resources.

Article 309 of MOH Regulation 13/2025 revokes 61 regulations, including:

1. Decree of the Minister of Health No. 725/Menkes/SK/V/2003 on Guidelines for the Implementation of Training in the Health Sector;
2. Regulation of the Minister of Health No. 1192/Menkes/Per/X/2004 on the Establishment of Diploma Education in the Health Sector;
3. Regulation of the Minister of Health No. 889/Menkes/Per/V/2011 on Registration, Practice License, and Work Permit for Pharmaceutical Personnel;
4. Regulation of the Minister of Health No. 2048/Menkes/Per/X/2011 on the Awarding of Health Sector Merit Badges insofar as it regulates awards for medical and health personnel;
5. Regulation of the Minister of Health No. 2052/Menkes/Per/X/2011 on Medical Practice Licensing and Implementation;
6. Regulation of the Minister of Health No. 54 of 2012 on the Implementation of Dental Technician Work;
7. Regulation of the Minister of Health No. 9 of 2013 on the Special Assignment of Health Workers;
8. Regulation of the Minister of Health No. 19 of 2013 on the Implementation of the Work of Optician and Optometrist;
9. Regulation of the Minister of Health No. 22 of 2013 on the Implementation of Orthotist-Prosthetist Work and Practice;
10. Regulation of the Minister of Health No. 23 of 2013 on the Implementation of Occupational Therapist Work and Practice;
11. Regulation of the Minister of Health No. 24 of 2013 on the Implementation of Speech Therapist Work and Practice;
12. Regulation of the Minister of Health No. 26 of 2013 on the Implementation of Nutritionist Work and Practice;
13. Regulation of the Minister of Health No. 32 of 2013 on the Implementation of Sanitarian Work;
14. Regulation of the Minister of Health No. 55 of 2013 on the Implementation of Medical Record Technician Work;
15. Regulation of the Minister of Health No. 80 of 2013 on the Implementation of Physiotherapist Work and Practice;
16. Regulation of the Minister of Health No. 81 of 2013 on the Implementation of Radiographer Work;
17. Regulation of the Minister of Health No. 30 of 2015 on Licensing and Implementation of Cardiovascular Technician Practice;
18. Regulation of the Minister of Health No. 33 of 2015 on Guidelines for Preparing the Planning of Health Human Resource Needs;
19. Regulation of the Minister of Health No. 37 of 2015 on the Utilization of Health Workers Abroad;
20. Regulation of the Minister of Health No. 42 of 2015 on Licensing and Implementation of Medical Laboratory Technology Practice;
21. Regulation of the Minister of Health No. 45 of 2015 on Licensing and Implementation of Electromedical Practice;
22. Regulation of the Minister of Health No. 80 of 2015 amending MOH Regulation No. 9 of 2013 on Special Assignment of Health Workers;
23. Regulation of the Minister of Health No. 18 of 2016 on Licensing and Implementation of Anesthesia Technician Practice;
24. Regulation of the Minister of Health No. 20 of 2016 on Licensing and Implementation of Dental and Oral Therapist Practice;
25. Regulation of the Minister of Health No. 23 of 2016 on Guidelines for Awarding Outstanding Health Workers at Community Health Centers;
26. Regulation of the Minister of Health No. 31 of 2016 amending MOH Regulation No. 889/Menkes/Per/V/2011 on Registration, Practice License, and Work Permit for Pharmaceutical Personnel;
27. Regulation of the Minister of Health No. 41 of 2016 on the Accelerated Program for Upgrading Health Worker Education Qualifications;
28. Regulation of the Minister of Health No. 80 of 2016 on the Implementation of Assistant Health Worker Work;
29. Regulation of the Minister of Health No. 28 of 2017 on Licensing and Implementation of Midwife Practice;
30. Regulation of the Minister of Health No. 45 of 2017 on Licensing and Implementation of Clinical Psychologist Practice;
31. Regulation of the Minister of Health No. 24 of 2018 on Licensing and Implementation of Traditional Jamu Health Practice;
32. Regulation of the Minister of Health No. 33 of 2018 on Special Assignment of Health Workers in support of “Nusantara Sehat”;
33. Regulation of the Minister of Health No. 34 of 2018 on Licensing and Implementation of Acupuncture Therapist Practice;
34. Regulation of the Minister of Health No. 18 of 2019 on Health Management Consultants;
35. Regulation of the Minister of Health No. 26 of 2019 on the Implementation of Law No. 38 of 2014 on Nursing;
36. Regulation of the Minister of Health No. 36 of 2019 on the Implementation of Presidential Regulation No. 31 of 2019 on the Utilization of Specialist Doctors;
37. Regulation of the Minister of Health No. 83 of 2019 on Health Worker Registration;
38. Regulation of the Minister of Health No. 6 of 2020 on Foreign Health Management Consultants;
39. Regulation of the Minister of Health No. 17 of 2021 on Licensing and Implementation of Intercontinental Traditional Health Worker Practice;
40. Regulation of the Minister of Health No. 27 of 2021 on Affirmative Higher Education Programs for Health Workers;
41. Regulation of the Minister of Health No. 7 of 2022 on the Internship Program for Doctors and Dentists;
42. Regulation of the Minister of Health No. 14 of 2022 on the Adaptation Program for Indonesian Specialist Doctors Graduating from Overseas Institutions;
43. Regulation of the Minister of Health No. 37 of 2022 on Financial Assistance for Medical Education and Fellowship;
44. Regulation of the Minister of Health No. 6 of 2023 on the Utilization of Foreign Health Workers;
45. Regulation of the Indonesian Medical Council No. 6 of 2011 on Doctor and Dentist Registration;
46. Regulation of the Indonesian Medical Council No. 17 of 2013 on Temporary and Conditional Registration for Foreign Doctors and Dentists;
47. Regulation of the Indonesian Medical Council No. 18 of 2014 on the Electronic Registration Information System for Doctors and Dentists;
48. Regulation of the Indonesian Medical Council No. 21 of 2014 on the Registration of Doctors and Dentists Participating in Specialist Education Programs;
49. Regulation of the Indonesian Medical Council No. 22 of 2014 on Approval of the Transfer of Medical/Dental Science and Technology;
50. Regulation of the Indonesian Medical Council No. 26 of 2014 on Doctor and Dentist Identification Numbers;
51. Regulation of the Indonesian Medical Council No. 39 of 2015 on Doctor and Dentist Re-registration;
52. Regulation of the Indonesian Medical Council No. 41 of 2016 on the Adaptation Program for Indonesian Doctors and Dentists Graduating from Overseas Institutions;
53. Regulation of the Indonesian Medical Council No. 46 of 2016 amending IMC Regulation No. 22 of 2014 on the Transfer of Medical/Dental Science and Technology;
54. Regulation of the Indonesian Medical Council No. 53 of 2018 on Electronic Registration Procedures for Doctors and Dentists;
55. Regulation of the Indonesian Medical Council No. 54 of 2018 on Additional Qualification Registration for Specialist Doctors and Dentists;
56. Regulation of the Indonesian Medical Council No. 58 of 2019 on the Format of Doctor and Dentist Registration Certificates;
57. Regulation of the Indonesian Medical Council No. 84 of 2020 amending IMC Regulation No. 54 of 2018 on Additional Qualification Registration for Specialist Doctors and Dentists;
58. Regulation of the Indonesian Medical Council No. 97 of 2021 on the Adaptation Program for Indonesian Specialist Doctors Graduating from Overseas Institutions;
59. Regulation of the Indonesian Medical Council No. 110 of 2022 on Registration of Internship Doctors and Dentists; and
60. Regulation of the Indonesian Medical Council No. 111 of 2023 on Additional Competencies for Indonesian Specialist Doctors Graduating from Overseas Institutions;
61. Regulation of the Indonesian Medical Council No. 112 of 2023 on Registration of Indonesian Specialist Doctors Graduating from Overseas Institutions Participating in Adaptation and Competency Enhancement Programs.

Key Provisions

The main substance of MOH Regulation 13/2025 is as follows:

Sanctions

1. Sanctions on Individuals (Medical Personnel, Health Workers, and Students)

Sanctions for individual health workers generally relate to violations of obligations arising from government programs (such as scholarships or special assignments) or behavioral misconduct (such as bullying).

Violations of Educational Assistance (Scholarships)

a. Violation of Performance Contract: Health workers or support personnel who breach their performance contracts (Article 29(6)) are sanctioned by the aid provider (Minister/Governor/Regent/Mayor) through:

• Written reprimand;
• Suspension of financial assistance payments;
• Partial reimbursement of the assistance;
• Termination of assistance recipient status;
• Repayment of the full amount received; and/or
• Disqualification from future selection processes for similar assistance.

b. Failure to Fulfill Service Commitment (Health Workers): Health workers who received scholarships and fail to fulfill their service obligations (Article 33(2)) are subject to administrative sanctions from the Minister in the form of STR revocation.

c. Failure to Fulfill Service Commitment (Support Personnel): Support personnel recipients who violate their service obligations (Article 36(2)) are subject to disciplinary sanctions as employees.

d. Failure to Fulfill Fellowship Commitment: Health workers who received Fellowship Financial Assistance and breach their service commitment (Article 42) are sanctioned by the Minister with the revocation of additional qualification STR and/or repayment of all fellowship funds received.

Violations Related to the Special Assignment Program (Pensus):

Health workers participating in Pensus who fail to meet their obligations (Article 52(2)) are sanctioned progressively by the Minister, Governor, or Regent/Mayor as follows:

• Verbal reprimand (maximum twice);
• Written reprimand (issued if verbal warnings are ignored, maximum once);
• Suspension of remuneration (for unauthorized absence);
• Termination from participation in the Pensus program (for repeated violations or those causing patient harm or service disruption).

Violations Related to the Internship Program:

Applicable to facilities, supervising doctors, or interns who breach their obligations (Article 286).
Sanctions imposed by the Minister include:

• Verbal reprimand;
• Written reprimand;
• Recommendation to delay STR issuance (for interns);
• Termination (as facility, supervisor, or participant).

Violations by Indonesian and Foreign Graduates:

Violation of Obligations: 

Indonesian foreign graduates, mentors/supervisors, foreign health workers, and employing facilities who violate obligations (Articles 117, 118, 120) are sanctioned by the Minister through:

• Verbal or written reprimand;
• Termination as mentor/supervisor or adaptation participant;
• Revocation of STR, SIP, assignment letter, or approval letter.

Violation of Prohibitions: 

Indonesian or foreign health workers violating prohibitions (e.g., foreign nationals engaging in private practice) (Articles 119, 120(3)) are sanctioned by the Minister with:

• Verbal reprimand;
• Written reprimand;
• Revocation of STR, SIP, assignment letter, or approval letter.

Misuse of Licensing Accounts:

Health workers who misuse accounts or employ intermediaries (brokers) in registration or licensing processes (Article 172) are sanctioned with deactivation of their STR and/or SIP.

Bullying Violations (Perpetrators): (Article 294)

a. Any individual within a healthcare facility (health worker, educator, student, or staff) who commits bullying shall be sanctioned progressively by the Minister, Regional Government, or facility leader as follows:

1. Minor Sanction:

• Recorded in the National Health Information System (SISKesNas);
• Prohibited from providing services at the incident site for 3 months;
• Suspension for 3 months (for educators/students);
• Enforcement of employee discipline (for civil servants, military, police, or other employees).

2. Moderate Sanction:

• Recorded in SISKesNas;
• STR and SIP deactivation for 6 months;
• Suspension as educator/student for 6 months;
• Enforcement of employee discipline.

3. Severe Sanction:

• Recorded in SISKesNas;
• STR and SIP deactivation for 12 months;
• Suspension as educator/student for 12 months;
• Loss or revocation of professorship (for educators);
• Enforcement of employee discipline.

b. Repeated violations are sanctioned one level higher.

 

2. Sanctions on Healthcare Facilities (Fasyankes)

Sanctions on healthcare facilities focus on failures to meet obligations as employers, education providers, or users of health workers. The most severe sanction may be the revocation of the business license.

Violation of Worker Placement Obligations: 

Privately owned healthcare facilities that manage worker placement but breach obligations (Article 59) are sanctioned by the Minister with verbal reprimand, written reprimand, or license revocation.

Violation of SIP Validation Deadlines: 

Facilities violating SIP validation timelines (Article 152(2)) are sanctioned progressively by the Minister/Regional Government through verbal reprimand, written reprimand, or accreditation downgrade.

Violation of Employment and Wage Obligations: 

Facility leaders who fail to prioritize employment relationships (over partnerships) (Article 217) or fail to establish wage structures and scales (Article 219) are sanctioned by the Minister/Regional Government with:

• Verbal reprimand;
• Written reprimand;
• Accreditation adjustment;
• Revocation of facility business license.

Violation of Legal Protection Obligations: 

Facility leaders who fail to provide legal protection, mitigation, or legal assistance (Articles 250, 251, 252, 260) receive the same sanctions:

• Verbal reprimand;
• Written reprimand;
• Accreditation adjustment;
• Revocation of facility business license.

Failure to Address Bullying: 

a. Facilities that fail to prevent or handle bullying (Article 272) are sanctioned by the Minister/Regional Government as follows:

• Minor Sanction: Mandatory preparation of a prevention action plan.
• Moderate Sanction: Accreditation downgrade and/or suspension of education activities (for affected programs) for 6 months.
• Severe Sanction: Accreditation downgrade, revocation of teaching hospital status, and/or permanent termination of related education programs.

b. Facility leaders may also face disciplinary sanctions as employees.

3. Sanctions on Training Institutions

Training institutions conducting professional development activities (for SKP) that violate provisions (Article 208) are sanctioned progressively by the Minister with:

• Verbal reprimand;
• Written reprimand;
• Accreditation level downgrade;
• Temporary suspension of the training institution’s account (for 6 or 12 months);
• Revocation of accreditation.

4. Sanctions on Regional Governments

Regency/municipal governments that impose additional SIP issuance requirements beyond those specified in Articles 151(4) and 158(5) are subject to administrative sanctions from the Minister and/or Governor in the form of a written reprimand. 

Furthermore, the Minister may evaluate the allocation of health sector funding for such regional governments.

 

Transitional Provisions

Article 302: Ongoing Programs 

Health workers currently participating in programs under previous regulations may continue until completion, including:

1. Residents under the Special Assignment Program (based on MOH Reg. 9/2013 jo. 80/2015);
2. Health workers in the “Nusantara Sehat” Special Assignment Program (based on MOH Reg. 33/2018);
3. Specialist doctors under utilization programs (based on MOH Reg. 36/2019);
4. Doctors and dentists currently in the Internship Program (based on MOH Reg. 7/2022);
5. Indonesian and foreign graduates undergoing competency evaluation or adaptation (based on MOH Reg. 14/2022, MOH Reg. 6/2023, and relevant Indonesian Medical Council Regulations);
6. Foreign health workers currently engaged in non-service activities (e.g., technology transfer) under approved arrangements (based on MOH Reg. 6/2023 and IMC Reg. 22/2014 jo. 46/2016).

Article 303: Deadline for SIP System Integration 

Regency/municipal governments whose SIP issuance systems are not yet integrated with the National Health Information System (SISKesNas) shall complete the integration within 2 years from the enactment of this regulation.

Article 304: Validity of Existing Licenses 

All SIPs, assignment letters, and deployment letters issued prior to the enforcement of this regulation remain valid until their expiry date.

Article 305: Transitional Professional Standards and Credentialing 

1. Until new professional standards (as mandated by Article 174(3)) are established, the practice authority of health workers shall follow the previous MOH regulations governing each profession. 
2. Healthcare facilities and local health offices shall align their credentialing and re-credentialing processes with the new provisions within 6 months.

Article 306: Deadline for Training Institution Adjustment

All training institutions (seminar, workshop organizers, etc., for SKP) shall comply with the new accreditation requirements within 6 months.

Article 307: Deadline for Wage Adjustment

Facility leaders or employers shall adjust their wage policies (including structure and scale) within 1 year in accordance with the new regulation.

Article 308: Deadline for Legal Protection and Anti-Bullying Compliance

Healthcare facility leaders shall align legal protection systems and anti-bullying mechanisms within 1 year of the regulation’s enactment.

 

Conclusion

Key highlights of MOH Regulation 13/2025 are as follows:

1. Revokes 61 previous regulations to resolve fragmentation and overlap in the governance of health human resources, consolidating them into a single integrated and comprehensive legal framework.
2. Introduces lifetime STRs for Indonesian citizens, separating proof of professional registration (STR) from the practice license (SIP), which shall still be renewed every 5 years through SKP compliance.
3. Imposes strict obligations and sanctions on healthcare facilities to ensure health worker welfare, particularly legal protection and anti-bullying enforcement.
4. Establishes new, centralized procedures under the Ministry of Health for the evaluation and adaptation of Indonesian foreign graduates and foreign health workers.