Legal Support for PMK 6/2026 Hospital Compliance

Indonesia's healthcare regulatory chain has undergone fundamental change. Law 17/2023 on Health provides the new foundation, followed by Government Regulation 28/2024 as the implementing regulation, and Permenkes 6/2026 as the technical regulation governing all aspects of hospitals — from classification and licensing to governance and sanctions.

For hospitals and healthcare investors, this means prior regulations are no longer authoritative. PMK 6/2026 replaces 21 earlier regulations (Article 84), creating a more integrated regime that demands comprehensive understanding of new obligations.

Integra Law helps hospitals and investors understand this change practically — from assessing current classification positioning to developing realistic transition strategies aligned with regulatory timelines.

The most fundamental change is the abolition of the Class A/B/C/D classification system that has served as the primary benchmark. The new classification uses a service-capability approach per service group (Article 12(3)), meaning a hospital can hold different classification levels for different services.

The transition period is 2 years from the effective date of PMK 6/2026 (until 4 June 2028). Class D Pratama hospitals receive a 4-year extension (until 4 June 2030). During this period, hospitals must adjust their classification and obtain risk-based licensing under Article 6.

For foreign direct investment (PMA), PMK 6/2026 sets specific requirements: PMA must meet paripurna classification and minimum bed counts, unless the investment is made within a hospital-group structure that receives an exemption (Articles 10(10)–(12)). This creates a strategic opportunity for healthcare investors in East Java and throughout Indonesia.

The PMK 6/2026 sanctions regime is designed to be stricter and more integrated. Articles 77–79 establish an escalating mechanism: oral warning, written warning, fine, accreditation adjustment or revocation, and license revocation. Each stage has specific requirements and procedures.

Critically, Article 80 provides for direct escalation. For severe violations resulting in patient death, permanent organ damage, or widespread impact, sanctions can be imposed directly at the highest level without going through the gradual escalation process. This fundamentally changes the compliance risk profile.

Hospitals that do not understand this sanctions mechanism are in a highly vulnerable position. Integra Law helps hospitals assess current compliance and build adequate risk-mitigation systems before the transition period ends.

East Java has a significant number of hospitals — from public (RSUD) to private facilities — that must all adjust to the new classification regime. With a 2-year transition window, assessment and planning must begin now to allow sufficient time for operational, licensing, and governance adjustments.

Hospital-group investment opportunities are especially relevant for East Java. Articles 10(10)–(12) of PMK 6/2026 open pathways for hospital development within business groups, with specific exemptions for PMA that can become strategic investment instruments.

Integra Law has a healthcare case group based in Surabaya with direct experience in healthcare regulation and hospital advisory in East Java. We understand the local context, the specific needs of regional hospitals, and the challenges that must be addressed during the transition period.