Starting 19 November 2025, Employers Must Establish a P2K3 in Accordance with Minister of Manpower Regulation 13/2025

Introduction

On 17 November 2025, the Minister of Manpower enacted Minister of Manpower Regulation Number 13 of 2025 on the Occupational Safety and Health Supervisory Committee (“Ministerial Regulation 13/2025”), which took effect on 19 November 2025. Ministerial Regulation 13/2025 replaces Minister of Manpower Regulation Number PER.04/MEN/1987 on the Occupational Safety and Health Supervisory Committee and Procedures for Appointing Occupational Safety Experts (“Ministerial Regulation 4/1987”). Ministerial Regulation 13/2025 updates the provisions on the establishment, composition, and reporting of the Occupational Safety and Health Supervisory Committee (“P2K3”) to ensure relevance with current technological developments and labor law.

 

Background

Ministerial Regulation 13/2025 aligns the occupational safety and health (“OSH”) requirements mandated under Law Number 1 of 1970 on Occupational Safety (“Law 1/1970”). The Ministry of Manpower considers that Ministerial Regulation 4/1987 no longer aligns with developments in current legislation or with technological advancements in industry. Ministerial Regulation 13/2025 provides legal certainty, enhances the effectiveness of OSH protection, and supports a more modern OSH culture within the workplace.

 

Comparison

Below is a comparison between Ministerial Regulation 13/2025 and Ministerial Regulation 4/1987 regarding several key aspects:

Key Provisions

Establishment and Balanced Composition (Articles 3 & 6)

Ministerial Regulation 13/2025 affirms the obligation to establish a P2K3 for companies employing at least 100 workers or having a high-risk level. It regulates balanced membership composition between employer and worker representatives, as follows:

• For high-risk companies with up to 100 workers: At least 3 employer representatives and 3 worker representatives.
• For companies with at least 100 workers: At least 6 employer representatives and 6 worker representatives.

The Chair of the P2K3 must be top management, whereas the Secretary must be an appointed OSH Expert.

Digitalization of Establishment and Changes in Structure (Articles 7 & 8)

The process for establishing a P2K3 is now more modern, using written or electronic applications submitted to the Provincial Manpower Office Head. Ministerial Regulation 13/2025 provides a service level agreement for businesses: document verification must be completed within a maximum of 3 working days for new establishments or 5 working days for renewals, and the establishment decision must be issued within a maximum of 5 working days once requirements are complete.

In addition, companies must submit renewal of the establishment decision no later than 2 working days after any change in the position of Chair or Secretary of the P2K3.

Expanded Duties and Work Program (Articles 9 & 10)

Ministerial Regulation 13/2025 regulates the duties of the P2K3 in more detail than Ministerial Regulation 4/1987. Beyond providing recommendations, the P2K3 is responsible for evaluating work methods, determining corrective actions, developing hazard control systems, monitoring workplace nutrition, and supporting the implementation of the occupational safety and health management system (SMK3).

In carrying out these duties, the P2K3 must prepare a work program that includes, at a minimum, problem inventories, hazard identification, accident statistics analysis, and improvement recommendations.

Electronic Reporting Mechanism (Article 11)

Ministerial Regulation 13/2025 introduces a digital reporting system. The Chair of the P2K3 must submit activity reports every 6 months through the information system managed by the Ministry of Manpower. Manual reporting is allowed only when the electronic system is unavailable or experiencing technical issues.

 

Sanctions

Under Article 14, employers and/or management who fail to comply with the obligation to establish a P2K3 will be subject to sanctions under Law 1/1970.

 

Closing

Ministerial Regulation 13/2025 introduces digitalization of bureaucratic processes (establishment and reporting) and emphasizes balanced representation between management and workers within the OSH committee. Businesses should promptly review their existing P2K3 organizational structure to ensure that member ratios comply with the new requirements (3:3 or 6:6) and prepare administrative infrastructure for electronic reporting.