Navigating OJK’s Health Insurance Regulation: Strategic Insights for Employers
A New Era in Employee Health Benefits
The Financial Services Authority (OJK) had announced transformative changes to health insurance regulations through Circular Letter Number 7 of 2025, originally set to take effect upon renewal of group policies between January 1, 2026 and December 31, 2026. These changes aimed to reshape how companies manage health coverage, particularly for those offering private insurance alongside BPJS Kesehatan.
But following discussions with Commission XI of the House of Representatives (DPR), OJK has officially agreed to postpone the implementation of this circular until a more robust OJK Regulation (POJK) is enacted.
This delay offers employers a temporary reprieve and an opportunity to better prepare for the eventual regulatory shift.
Key Changes (Now Deferred) and Strategic Implications
1. Co-Payment Model: Increased Employee Participation
OJK mandated a minimum 10% co-payment for medical claims, with caps set at Rp300,000 for outpatient services and Rp3,000,000 for inpatient care.
Strategic Insight: While this model could reduce insurer costs, it risked increasing the financial burden on employees. With the postponement, employers have more time to evaluate how to balance cost-sharing without compromising care quality.
2. Integration with BPJS Kesehatan
Private insurance to coordinate with BPJS Kesehatan’s National Health Insurance (JKN) program, preventing coverage duplication and ensuring private insurers cover only what BPJS does not.
Strategic Insight: Although implementation is delayed, companies should still begin reassessing dual coverage policies and educating employees on the distinctions between BPJS and private insurance.
HR teams should prioritize educating employees on claim processes.
3. Medical Advisory Board Requirement
Insurers were to establish a Medical Advisory Board to oversee healthcare decisions using digital health data, ensuring cost-effective and necessary treatments.
Strategic Insight: This requirement, signals a shift toward more data-driven oversight. Employers should start discussions with brokers and insurers to prepare for future compliance.
Actionable Steps for Employers
1. Monitor Regulatory Developments: Stay informed about the drafting and eventual enactment of the POJK
2. Review Current Health Insurance Plans: Evaluate whether your private coverage aligns with BPJS and anticipate future regulatory expectations.
3. Educate Employees: Begin internal communications about potential changes, even if delayed.
4. Collaborate with Brokers and Insurers: Ensure policies remain competitive while optimizing cost efficiency.
5. Consider Supplemental Benefits: Explore additional health perks, such as wellness programs, to maintain employee satisfaction amidst upcoming changes.
Strategic Adaptation for Sustainable Benefits
The postponement of OJK’s Circular Letter provides a valuable window for employers to reassess and realign their health benefit strategies. By proactively engaging with stakeholders and preparing for the eventual POJK, companies can ensure sustainable, compliant, and employee-friendly health insurance offerings. Reach out to discuss how these changes impact your business and explore tailored solutions for your company.
Aon Indonesia is a registered and license brokerage company from Otoritas Jasa Keuangan. Under no circumstances will Aon Indonesia act as an insurer, reinsurer, risk manager, or commercial, taxation, or legal advisor. The comments in this document are not binding on the Indonesian authority and there can be no assurance that the Indonesian authority will not take a position contrary to any of the comments herein.