INDONESIA Trends and Developments Contributed by: Marshall Situmorang, Audria Putri, Fatya Alesi and Irfan Yusuf, Nusantara Legal Partnership
After preparing the legal and technical documents, a privately owned First-Class Clinic must proceed to obtain business licensing in the healthcare sector as stipulated under MoH Reg. 11/2025 (“Healthcare Licensing”). In particular, a First-Class Clinic falls with - in the medium to high-risk business category, which requires it to obtain Healthcare Licensing in the form of: • a Business Identification Number ( Nomor Induk These licensing requirements will be processed and issued electronically through the Online Single Sub - mission (OSS) system, and information on the estab- lished private clinic will later be integrated into the Ministry of Health system. Investors should also note that the OSS process is not limited to corporate filings alone. The current OSS guidance for KBLI 86105 also incorporates location- based and environmental compliance steps. As a result, site selection, environmental screening, and the technical suitability of the building should ideally be assessed in parallel with company establishment and licensing preparation, because a clinic project that appears ready from a corporate perspective may still face delays if the premises and technical docu - ments are not yet aligned with the applicable health- sector standards. 3. Requirements to be fulfilled by private clinics Apart from satisfying the pre-operational stage and obtaining Healthcare Licensing, a privately owned First-Class Clinic is also required to fulfil several operational and technical requirements to support its business activities. These requirements are detailed in the Appendix of MoH Reg. 11/2025 as follows. a. Organisational structure Berusaha , or NIB); and • a Standard Certificate. A First-Class Clinic is required to have an organisa - tional structure setting out the duties, responsibilities, authority, and reporting lines among staff members within the clinic. Such organisational structure con - sists, at a minimum, of the following personnel:
• Head of Clinic: The Head of Clinic must be a healthcare professional with competence in health - care management. A Head of Clinic may only be responsible for one First-Class Clinic. • Clinic Service Co-Ordinator: The Clinic Service Co-Ordinator must be medical personnel. However, MoH Reg. 11/2025 permits the Head of Clinic to also act in this capacity. • Operations Co-Ordinator: The Operations Co-Ordi - nator may be medical personnel, health personnel or supporting health personnel. Any medical personnel or health personnel providing services at the clinic must also hold the relevant prac - tice licence. MoH Reg. 11/2025 requires medical and health personnel providing services at a First-Class Clinic to hold a Practice Licence ( Surat Izin Praktik , or SIP) in accordance with the prevailing laws and regulations, while Articles 244 and 263 of Law No. 17 of 2023 provide that, to obtain an SIP, the relevant medical professional or health professional must hold a registration certificate/ surat tanda registrasi and a place of practice, and that the SIP remains valid so long as the place of practice remains consistent with the SIP. This is important because the mere availabil - ity of doctors or nurses is not sufficient; the relevant personnel must also be properly licensed to practise in the clinic where they will actually practise. Moreover, the composition of medical personnel and supporting staff in a First-Class Clinic depends on the services to be provided. Further details are set out below. i. First-Class Outpatient Clinic A First-Class Clinic that provides outpatient health - care services without inpatient stay (First-Class Out - patient Clinic) must at least have the following medical personnel to operate the clinic: • doctors: specialist doctors, sub-specialist doctors, or specialist doctors with additional competencies, and/or specialist dentists, sub-specialist dentists, or specialist dentists with additional competencies; • nurses or dental and oral therapists; and • health support or auxiliary personnel.
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