Occupational safety and health (“OSH” or Keselamatan dan Kesehatan Kerja – K3) has long been a cornerstone of Indonesia’s manpower regulatory framework.

This evolution of the government to provide safe working environment is recently being reflected in Minister of Manpower Regulation No. 13 of 2025 on the Occupational Safety and Health Advisory Committee (Peraturan Menteri Ketenagakerjaan Nomor 13 Tahun 2025 tentang Panitia Pembina Keselamatan dan Kesehatan Kerja) or “Permenaker 13/2025”, which formally revokes Minister of Manpower Regulation No. PER-04/MEN/1987, after nearly four decades. Permenaker 13/2025 updates the rules on when P2K3 must be formed, how it must be structured, how it is approved by the authorities, and how its activities must be reported. The regulation places stronger emphasis on formal governance, documentation, and regulatory oversight.

Key Provisions of Permenaker 12/2025

Permenaker 13/2025 forms part of Indonesia’s wider OSH regulatory ecosystem. Within this framework, Permenaker 13/2025 specifically regulates the Occupational Safety and Health Advisory Committee (Panitia Pembina Keselamatan dan Kesehatan Kerja  (“P2K3”), a bipartite body designed to facilitate cooperation between employers and workers in implementing OSH policies at the workplace.

The regulation applies to employers and/or managers that:

1. employ at least 100 workers; or
2. operate workplaces with a high level of risk, as determined under prevailing risk-based licensing regulations.

Key Changes and Corporate Compliance Analysis

1. Clearer and Enforceable Obligation to Establish P2K3

Permenaker 13/2025 expressly imposes a mandatory obligation on qualifying employers to establish P2K3. While the obligation existed under the 1987 regulation, it was framed more generally and often implemented inconsistently.

Under the new regulation, the obligation is tied directly to objective thresholds, workforce size and risk level. For corporate groups, this means OSH compliance must be assessed at the level of each operating entity or workplace, rather than being centralized solely at the group or holding company level.

2. Stronger Governance and Management Accountability

The regulation introduces a clearer governance structure for P2K3. The Chairperson must be senior management or the top executive at the workplace, while the Secretary must be a formally appointed OSH Expert (Ahli K3). Membership must reflect balanced representation between management and workers.

From a corporate compliance perspective, this signals a deliberate policy choice: OSH is no longer treated as a purely technical or operational matter, but as an issue of managerial responsibility and internal governance.

3. Formalized Appointment and Administrative Oversight

Permenaker 13/2025 establishes a structured administrative process for P2K3 appointment, including document submission, verification by the provincial manpower office, and issuance of an official determination.

This process enhances traceability and reduces informal practices that were common under the previous regime. Companies should anticipate that OSH compliance will be more readily auditable by manpower inspectors.

4. Expanded Scope of Duties and Preventive Orientation

The duties of P2K3 are significantly elaborated. In addition to providing advice, P2K3 is expected to actively participate in hazard identification, accident analysis, OSH program development, training, and internal monitoring.

This reflects a preventive and system-based approach to OSH, aligning domestic regulation more closely with international safety management standards.

5. Reporting Obligations and Digital Compliance

A key development under Permenaker 13/2025 is the introduction of mandatory six-monthly reporting of P2K3 activities to the provincial manpower authority, with copies submitted to the Minister of Manpower. Reporting is to be conducted electronically through a system managed by the Ministry.

For employers, this increases transparency and creates a data-driven compliance environment where OSH performance can be monitored more closely by regulators.

6. Sanctions

Although Permenaker 13/2025 does not introduce new standalone sanctions, it explicitly links non-compliance to sanctions under prevailing OSH legislation. Pursuant to Article 14, non-compliance with the obligation to establish a P2K3 may result in the imposition of sanctions under Law No. 1 of 1970 on Work Safety.

Comparison: Permenaker 13/2025 vs. Permenaker PER-04/MEN/1987 (“Permenaker 4/1987”)

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