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REGULATION OF THE MINISTER OF HEALTH OF THE REPUBLIC OF INDONESIA

NUMBER 24 OF 2022
ON
MEDICAL RECORDS

BY THE GRACE OF GOD ALMIGHTY

THE MINISTER OF HEALTH OF THE REPUBLIC OF INDONESIA,

Considering:
a. that the development of digital technology within the community has resulted in a transformation of the
digitalization of health services, therefore medical records need to be organized electronically with the
principles of security and confidentiality of data and information;
b. that Regulation of the Minister of Health Number 269/MENKES/PER/III/2008 on Medical Records is no
longer in accordance with the development of science and technology, the needs of health services, and
the legal needs of the community, therefore it needs to be replaced;
c. that based on the considerations as referred to in letter a and letter b, as well as to implement provisions
of Article 47 paragraph (3) of Law Number 29 of 2004 on Medical Practices and Article 72 of Law Number
36 of 2014 on Health Personnel, it has been deemed necessary to establish Regulation of the Minister of
Health on Medical Records.

Observing:
1. Article 17 paragraph (3) of the 1945 Constitution of the Republic of Indonesia;
2. Law Number 29 of 2004 on Medical Practices (State Gazette of the Republic of Indonesia of 2004 Number
116, Supplement to the State Gazette of the Republic of Indonesia Number 4431);
3. Law Number 11 of 2008 on Electronic Information and Transactions (State Gazette of the Republic of
Indonesia of 2008 Number 58, Supplement to the State Gazette of the Republic of Indonesia Number
4843) as amended by Law Number 19 of 2016 on the Amendment to Law Number 11 of 2008 on
Electronic Information and Transactions (State Gazette of the Republic of Indonesia of 2016 Number 251,
Supplement to the State Gazette of the Republic of Indonesia Number 5952);
4. Law Number 36 of 2009 on Health (State Gazette of the Republic of Indonesia of 2009 Number 144,
Supplement to the State Gazette of the Republic of Indonesia Number 5063);
5. Law Number 36 of 2014 on Health Personnel (State Gazette of the Republic of Indonesia of 2014 Number
298, Supplement to the State Gazette of the Republic of Indonesia Number 5607);
6. Regulation of the Government Number 46 of 2014 on Health Information Systems (State Gazette of the
Republic of Indonesia of 2014 Number 126, Supplement to the State Gazette of the Republic of Indonesia
Number 5542);
7. Regulation of the President Number 18 of 2021 on the Ministry of Health (State Gazette of the Republic of
Indonesia of 2021 Number 83);
8. Regulation of the Minister of Health Number 290/MENKES/PER/III/2008 on Informed Consent to Medical

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 Procedures;
9. Regulation of the Minister of Health Number 36 of 2012 on Medical Confidentiality (Official Gazette of the
Republic of Indonesia of 2012 Number 915);
10. Regulation of the Minister of Health Number 5 of 2022 on the Organization and Work Procedures of the
Ministry of Health (Official Gazette of the Republic of Indonesia of 2022 Number 156).

HAS DECIDED:

To establish:
REGULATION OF THE MINISTER OF HEALTH ON MEDICAL RECORDS.

CHAPTER I
GENERAL PROVISIONS

Article 1
Under this Regulation of the Minister, the following definitions are employed:
1. Medical Records are documents containing data on patient identity, check-ups, treatments, procedures,
and other services that have been provided to patients.
2. Electronic Medical Records are Medical Records that are drawn up by using an electronic system
intended for the organization of Medical Records.
3. Health Personnel is any persons who devote themselves to the health sector and have knowledge and/or
skills through education in the health sector which for certain types requires the authority to conduct health
efforts.
4. Medical Record and Health Information Personnel is a person who has passed the Medical Record and
health information education in accordance with the provisions of laws and regulations.
5. Health Services Facility is a device and/or place that is utilized to organize health services efforts, whether
promotive, preventive, curative, or rehabilitative which is conducted by the government, regional
governments, and/or the community.
6. Patient is any persons who consult on their health problems to obtain the necessary health services, either
directly or indirectly at Health Services Facilities.
7. Electronic System is a set of electronic devices and procedures that function to prepare, collect, process,
analyze, store, display, announce, send, and/or disseminate electronic information.
8. Electronic System Organizer is any person, state administrator other than the Ministry of Health, business
entity, and the community, that provide, manage, and/or operate Electronic Systems individually or jointly
to Electronic System users for personal interests and/or other party’s interests.
9. Minister is the minister who carries out government affairs in the health sector.
10. Director-General is the director-general at the Ministry of Health whose duties and responsibilities are in
the health services sector.

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 Article 2
The arrangement of Medical Record has the purpose to:
a. improve the quality of health services;
b. provide legal certainty in the organization and management of Medical Records;
c. ensure the security, confidentiality, integrity, and availability of Medical Record data; and
d. realize the organization and management of digital-based and integrated Medical Records.

CHAPTER II
ORGANIZATION

Division One
General

Article 3
(1) Any Health Services Facilities are required to organize Electronic Medical Records.
(2) Health Services Facilities as referred to in paragraph (1) consists of:
a. place for independent practices of doctors, dentists, and/or other Health Personnel;
b. public health center;
c. clinic;
d. hospital;
e. pharmacy;
f. health laboratory;
g. health center; and
h. other Health Services Facilities as determined by the Minister.

Article 4
(1) The obligation to organize Electronic Medical Records shall also apply to Health Services Facilities that
provide telemedicine services.
(2) The organization of Electronic Medical Records as referred to in paragraph (1) shall be conducted in
accordance with the provisions of this Regulation of the Minister.

Article 5
Electronic Medical Record is one of the subsystems of the information system of Health Services Facilities that is
connected to other information subsystems in Health Services Facilities.

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 Article 6
The organization of Electronic Medical Records in Health Services Facilities shall be conducted by a separate
work unit or adjusted to the needs and capabilities of each Health Services Facility.

Article 7
(1) The organization of Electronic Medical Records shall be conducted from the time a Patient enter until the
Patient return home, is referred, or pass away.
(2) Health Services Facilities must prepare standard operating procedures for the organization of Electronic
Medical Records as referred to in paragraph (1) which are adjusted to the needs and resources of each
Health Service Facility, with reference to the guidelines for Electronic Medical Records.

Article 8
(1) The Minister shall facilitate the organization of Electronic Medical Records in Health Services Facilities.
(2) The facilitation as referred to in paragraph (1) shall include the provision of:
a. Electronic Systems in the organization of Electronic Medical Records; and
b. service platforms and standards for health data interoperability and integration.
(3) In order to facilitate the organization of Electronic Medical Records in Health Services Facilities as referred
to in paragraph (1), the Minister shall coordinate with relevant ministries/institutions and regional
governments.

Article 9
(1) Electronic Systems in the organization of Electronic Medical Records may be in the form of Electronic
Systems which are developed by the Ministry of Health, Health Services Facilities themselves, or
Electronic System Organizers through a cooperation.
(2) The organization of Electronic Medical Records by using Electronic Systems developed by the Ministry of
Health as referred to in paragraph (1) shall be conducted through the submission of a written application
to the Ministry of Health.
(3) Electronic System Organizers in Electronic Medical Records as referred to in paragraph (1) must be
registered as Electronic System Organizers in the health sector at the ministry responsible for the
communication and informatics sector in accordance with the provisions of laws and regulations.

Article 10
(1) Electronic Systems that are used in the organization of Electronic Medical Records must have
compatibility and/or interoperability capabilities.
(2) Compatibility as referred to in paragraph (1) is the compatibility of one Electronic System with other
Electronic Systems.
(3) Interoperability as referred to in paragraph (1) is the capability of different Electronic Systems to be able to
work in an integrated manner to communicate or exchange data with one or more other Electronic
Systems, using data exchange standards.
(4) Interoperability as referred to in paragraph (3) shall refer to the electronic system standard which is

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 organized by the Ministry of Health in accordance with the provisions of laws and regulations.

Article 11
(1) Electronic Systems as referred to in Article 10 must refer to the variables and meta data which are
determined by the Ministry of Health.
(2) Variables as referred to in paragraph (1) are data elements contained in Electronic Systems of Electronic
Medical Records.
(3) Meta data as referred to in paragraph (1) shall include definition, format, and codification.

Article 12
(1) Health Services Facilities organizing Electronic Medical Records or Electronic System Organizers as
referred to in Article 9 paragraph (1) are required to register the Electronic Systems they use at the
Ministry of Health.
(2) Registration of Electronic Systems as referred to in paragraph (1) shall be conducted by attaching
documents which shall at least include:
a. name of Electronic Systems;
b. system documentation;
c. available features/functions;
d. location of data storage;
e. variables and meta data; and
f. list of Health Service Facilities that use Electronic Systems, if Electronic Systems are used by other
Health Services Facilities.
(3) In the event that there is a change of data in the registration documents as referred to in paragraph (2),
Health Services Facilities organizing Electronic Medical Records or Electronic System Organizers must
report to the Ministry of Health.

Division Two
Activity

Subdivision 1
General

Article 13
(1) The activities of organizing Electronic Medical Records shall at least include:
a. registration of Patients;
b. distribution of Electronic Medical Record data;
c. filling out of clinical information;

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 d. processing of Electronic Medical Record information;
e. data input for financing claims;
f. storage of Electronic Medical Records;
g. quality assurance of Electronic Medical Records; and
h. transfer of the contents of Electronic Medical Records.
(2) The activities of organizing Electronic Medical Records as referred to in paragraph (1) letter a, letter b, and
letter d up to letter h shall be conducted by Medical Records and Health Information Personnel and may
coordinate with other work units.
(3) The activities of organizing Electronic Medical Records as referred to in paragraph (1) letter c shall be
conducted by Health Personnel providing health services.
(4) In the event that there is a limitation of Medical Records and Health Information Personnel at Health
Services Facilities, the activities of organizing Electronic Medical Records as referred to in paragraph (2)
may be conducted by other Health Personnel who has received training in Electronic Medical Record
services.
(5) In the event that Electronic Medical Records are organized at places for independent practices of doctors
and dentists, or places for independent practices of other Health Personnel, the activities of organizing
Electronic Medical Records as referred to in paragraph (1) shall be the responsibility of the said doctors
and dentists, or other Health Personnel.

Subdivision 2
Registration of Patients

Article 14
(1) Registration of Patients as referred to in Article 13 paragraph (1) letter a is a registration activity in the
form of filling out of identity data and social data of outpatients, emergency Patients, and inpatients.
(2) The identity data as referred to in paragraph (1) shall at least contain Medical Record numbers, name of
Patients, and Citizenship Identification Numbers (Nomor Induk Kependudukan/NIK).
(3) In the event that Patients do not have an identity or their identity are unknown, the filling out of identity
data as referred to in paragraph (2) shall be conducted based on a cover letter from the institution
responsible for the organization of affairs in the fields of social rehabilitation, social security, social
empowerment, social protection, and handling of the poor, or a cover letter from the institution responsible
for the organization of affairs in the population and civil registration sector, in accordance with the
provisions of laws and regulations.
(4) Social data as referred to in paragraph (1) shall at least include religion, occupation, education, and
marital status.

Subdivision 3
Distribution of Electronic Medical Record Data

Article 15

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 The distribution of Electronic Medical Record data as referred to in Article 13 paragraph (1) letter b is the activity
of sending Electronic Medical Record data from one services unit to other services units in Health Services
Facilities.

Subdivision 4
Filling Out of Clinical Information

Article 16
(1) The filling out of clinical information as referred to in Article 13 in paragraph (1) letter c is a recording and
documentation activity of the results of check-ups, treatments, procedures, and other health services that
have been and will be provided to Patients.
(2) The recording and documentation as referred to in paragraph (1) must be complete, clear, and conducted
after Patients receive health services by including name, time, and signature of Health Personnel
providing health services.
(3) The recording and documentation as referred to in paragraph (1) must be conducted sequentially on the
records of each Health Personnel providing health services in accordance with the time of the health
services provided.
(4) In the event of a mistake in the recording or documentation during the filling out of clinical information,
Health Personnel providing health services may conduct corrections.

Article 17
(1) The filling out of clinical information by Health Personnel providing health services at Health Services
Facilities that have more than one type of Health Personnel as health services providers must be
conducted in an integrated manner.
(2) The filling out of clinical information in an integrated manner as referred to in paragraph (1) is the filling out
of Electronic Medical Records in one document which shall include several health records/information of
Patient from Health Personnel providing health services, and the time of the provision of health services in
sequence.
(3) In addition to the filling out of clinical information in an integrated manner as referred to in paragraph (1),
Health Personnel providing health services at first level Health Services Facilities may fill out clinical
information in family folder while still taking the privacy of each family member into account.

Subdivision 5
Processing of Electronic Medical Record Information

Article 18
(1) The processing of Electronic Medical Record information as referred to in Article 13 paragraph (1) letter d
shall include:
a. coding;
b. reporting; and

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 c. analysis.
(2) The coding as referred to in paragraph (1) letter a is the activity of giving clinical classification codes in
accordance with the latest International Statistical Classification of Disease and Related Health Problems,
in accordance with the provisions of laws and regulations.
(3) The reporting as referred to in paragraph (1) letter b shall include:
a. internal reporting of Health Services Facilities; and
b. external reporting from Health Services Facilities to health offices, the Ministry of Health, and
related stakeholders.
(4) The analysis as referred to in paragraph (1) letter c shall be conducted towards Electronic Medical Record
data quantitatively and qualitatively.
(5) In addition to the processing of Electronic Medical Record information as referred to in paragraph (1),
Health Services Facilities which, due to certain reasons, cannot organize Electronic Medical Records must
conduct indexing.
(6) The indexing as referred to in paragraph (5) is a data grouping activity, at least in the form of the following
indexes:
a. name of Patients;
b. address;
c. type of diseases;
d. measures/operations; and
e. dead.

Subdivision 6
Data Input for Financing Claims

Article 19
Data input for financing claims as referred to in Article 13 paragraph (1) letter e is an activity of inputting disease
classification codes in financing apps based on the results of diagnosis and procedures written by Health
Personnel providing health services in accordance with Medical Records, for the purpose of the submission of
service fee collections.

Subdivision 7
Storage of Electronic Medical Records

Article 20
(1) Storage of Electronic Medical Records as referred to in Article 13 paragraph (1) letter f is the activity of
storing Medical Record data on digital-based storage media at Health Services Facilities.
(2) The storage of Electronic Medical Records as referred to in paragraph (1) must ensure the security,
integrity, confidentiality, and availability of Electronic Medical Record data.
(3) The digital-based storage media as referred to in paragraph (1) shall be in the following forms:

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 a. server;
b. certified cloud computing system in accordance with the provisions of laws and regulations; and/or
c. other digital-based storage media based on certified information and technology developments.
(4) Health Services Facilities that conduct storage through digital-based storage media as referred to in
paragraph (1) are required to have a backup system.
(5) The backup system as referred to in paragraph (4) shall be implemented under the following conditions:
a. must be placed in a different place from the location of Health Services Facilities;
b. must be conducted periodically; and
c. must be outlined in the standard operating procedures of each Health Services Facility.

Article 21
Electronic Medical Records which are stored by Health Services Facilities must be connected/interoperable with
a service platform for health data interoperability and integration managed by the Ministry of Health.

Article 22
(1) In the event of a limitation of resources at Health Service Facilities, the storage of Electronic Medical
Records as referred to in Article 20 may be conducted in cooperation with Electronic System Organizers
that have data storage facilities within the country.
(2) Electronic System Organizers as referred to in paragraph (1) must secure recommendations from the
work unit responsible for the data and information management sector at the Ministry of Health.
(3) Electronic System Organizers as referred to in paragraph (1) are prohibited from opening, retrieving,
manipulating, destroying, utilizing data, and other things that are detrimental to Health Services Facilities.
(4) Provisions on the prohibition as referred to in paragraph (3) shall be stated in the form of an integrity pact
or Non-Disclosure Agreement which is attached when entering into a cooperation agreement with Health
Services Facilities.
(5) Health Services Facilities that cooperate with Electronic System Organizers that have data storage
facilities within the country as referred to in paragraph (1) must obtain unrestricted access to the stored
Electronic Medical Record data.

Subdivision 8
Quality Assurance

Article 23
(1) The quality assurance as referred to in Article 13 paragraph (1) letter g shall be conducted internally by
Health Services Facilities.
(2) Internal quality assurance as referred to in paragraph (1) is a quality audit of Electronic Medical Records
which is conducted periodically by a Medical Record reviewing team established by the Head of Health
Services Facilities and shall be conducted in accordance with the guidelines for Electronic Medical
Records.

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 (3) In addition to internal quality assurance as referred to in paragraph (1), the government may conduct a
quality audit of Electronic Medical Record and may involve related parties, as a part of the development
and supervision.

Subdivision 9
Transfer of the Contents of Electronic Medical Records

Article 24
(1) Transfer of the contents of Electronic Medical Records as referred to in Article 13 paragraph (1) letter h is
a transfer activity of Medical Records for the purpose of referrals of individual health services to Health
Services Facilities receiving referrals.
(2) The transfer of the contents of Electronic Medical Records as referred to in paragraph (1) shall be
conducted through a service platform for health data interoperability and integration managed by the
Ministry of Health.

Division Three
Ownership and Contents of Medical Records

Article 25
(1) Medical Record documents shall belong to Health Services Facilities.
(2) Health Service Facilities shall be responsible for the loss, damage, forgery, and/or use by persons and/or
entities that are not entitled to Medical Record documents as referred to in paragraph (1).

Article 26
(1) Contents of Medical Records shall belong to Patients.
(2) The contents of Medical Records as referred to in paragraph (1) shall be submitted to Patients.
(3) In addition to Patients, Medical Records as referred to in paragraph (2) may be submitted to the closest
family or other parties.
(4) The submission of Medical Records to the closest family as referred to in paragraph (3) shall be
conducted in the event that:
a. Patients are under 18 (eighteen) years old; and/or
b. Patients are in emergency.
(5) The submission of Medical Records to other parties as referred to in paragraph (3) shall be conducted
after securing consent from Patients.
(6) The contents of Medical Records as referred to in paragraph (2) shall at least contain:
a. identity of Patients;
b. results of physical and supporting check-ups;
c. diagnosis, treatment, and follow-up plan for health services; and

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 d. name and signature of Health Personnel providing health services.
(7) Medical Records as referred to in paragraph (2) must be drawn up by the person in charge of services.
(8) Medical Records as referred to in paragraph (2) must be provided to inpatients and emergency Patients
upon returning home, or to Health Services Facilities receiving referrals at the time of referral.
(9) In addition to inpatients and emergency Patients as referred to in paragraph (8), Medical Records may be
provided to outpatients if required.
(10) Medical Records intended for Health Services Facilities receiving referrals as referred to in paragraph (8)
shall be part of the referral letter in the health service referral system in accordance with the provisions of
laws and regulations.
(11) Medical Records provided when Patients return home as referred to in paragraph (8) and paragraph (9)
shall be in the form of letters which are sent and received in electronic form by using computer networks
or other electronic communication devices including mobile phones or in printed form.

Article 27
(1) The contents of Electronic Medical Records shall contain:
a. administrative documentation; and
b. clinical documentation.
(2) The administrative documentation as referred to in paragraph (1) letter a shall at least contain registration
documentation.
(3) The clinical documentation as referred to in paragraph (1) letter b shall contain all documentation of health
services provided to Patients in Health Services Facilities.
(4) Health Services Facilities may develop the contents of Electronic Medical Records as referred to in
paragraph (1) in accordance with the needs of health services.
(5) Further provisions on the contents of Electronic Medical Records as referred to in paragraph (1) shall be
regulated under the guidelines for Electronic Medical Records.

Article 28
(1) Health Services Facilities must open access to all contents of Electronic Medical Records of Patients to
the Ministry of Health.
(2) The Ministry of Health is authorized to utilize and store the contents of Electronic Medical Records for the
purpose of the processing of health data.
(3) The processing of health data as referred to in paragraph (2) shall be implemented for the development of
science and technology, and/or policy making in the health sector, by taking the principles of evidence-
based medicine, medical ethics, and the provisions of laws and regulations into account.
(4) Health data that is processed as referred to in paragraph (3), in addition to originating from Electronic
Medical Record data, may also come from other data at Health Services Facilities and/or other institutions.

Division Four
Data Security and Protection

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 Article 29
(1) Electronic Medical Records must fulfil the principles of data and information security, including:
a. confidentiality;
b. integrity; and
c. availability.
(2) The confidentiality as referred to in paragraph (1) letter a is a guarantee of data and information security
from interference by internal and external parties that do not have access rights, therefore the use and
distribution of data and information contained in Electronic Medical Records are protected.
(3) The integrity as referred to in paragraph (1) letter b is a guarantee for the accuracy of data and information
contained in Electronic Medical Records, and changes to data may only be conducted by persons who are
granted access rights to change.
(4) The availability as referred to in paragraph (1) letter c is a guarantee that data and information contained
in Electronic Medical Records may be accessed and used by persons who already have access rights
determined by the head of Health Services Facilities.

Article 30
(1) For the security and protection of Electronic Medical Record data, the head of Health Services Facilities
shall grant access rights to Health Personnel and/or other personnel in Health Services Facilities.
(2) The granting of access rights as referred to in paragraph (1) shall be part of the policies on standard
operating procedures for the organization of Electronic Medical Records determined by the head of Health
Services Facilities.
(3) The access rights as referred to in paragraph (1) shall include the right to:
a. perform data input;
b. perform data correction; and
c. view data.
(4) Data input as referred to in paragraph (3) letter a is a filling out activity of administrative data and clinical
data of Patients, which is conducted by Health Personnel providing health services and administrative
officers including Medical Records and Health Information Personnel in accordance with their respective
authorities.
(5) Data correction as referred to in paragraph (3) letter b shall be conducted if a mistake occurs in the input
of administrative data and clinical data of Patients.
(6) Data correction as referred to in paragraph (5) may only be conducted by Health Personnel providing
health services and administrative officers including Medical Records and Health Information Personnel
within a maximum period of 2x24 hours since the data is inputted.
(7) In the event that a mistake in administrative data that is found has exceeded the deadline as referred to in
paragraph (6), data correction shall be conducted after securing approvals from Medical Records and
Health Information Personnel and/or the head of Health Services Facilities.
(8) Data view as referred to in paragraph (3) letter c is an activity conducted by the internal personnel of
Health Services Facilities to obtain information related to the data in Electronic Medical Records for the
service or administration purposes.
(9) The access rights as referred to in paragraph (1) shall be regulated under a policy of the head of Health

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 Services Facilities by taking the principles of data and information security as referred to in Article 29 into
account.

Article 31
(1) In addition to the granting of access rights as referred to in Article 30, for the purpose of data security and
protection, the organization of Electronic Medical Records at Health Services Facilities may be equipped
with electronic signature.
(2) The electronic signature as referred to in paragraph (1) shall be used as a means of verification and
authentication of the contents of Electronic Medical Records and the identity of signers.
(3) The electronic signature as referred to in paragraph (1) shall be conducted in accordance with the
provisions of laws and regulations.

Division Five
Confidentiality

Article 32
(1) The contents of Medical Records must be kept confidential by all parties involved in health services at
Health Services Facilities even though Patients have passed away.
(2) The parties as referred to in paragraph (1) shall include:
a. Health Personnel providing health services, doctors and dentists, and/or other health personnel who
have access to health data and information of Patients;
b. the head of Health Services Facilities;
c. personnel related to the financing of health services;
d. legal entities/corporations and/or Health Services Facilities;
e. university students/students who are in charge of check-up, treatment, medical care, and/or
information management at Health Services Facilities; and
f. other parties that have access to health data and information of Patients in Health Services
Facilities.

Division Six
Opening of the Contents of Medical Records

Article 33
(1) Opening of the contents of Medical Record may be conducted:
a. with the consent of Patients; and/or
b. without the consent of Patients.
(2) Requests for the opening of the contents of Medical Records as referred to in paragraph (1) must be
conducted in writing or electronically.

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 (3) The opening of the contents of Medical Records as referred to in paragraph (1) shall be limited in
accordance with the needs.

Article 34
(1) The opening of the contents of Medical Records with the consent of Patients as referred to in Article 33
paragraph (1) letter a shall be conducted for:
a. the interests of health maintenance, treatment, cure, and medical care of Patients;
b. the request from Patients themselves; and/or
c. the purposes of administration, insurance payments, or health financing guarantees.
(2) Requests for the opening of the contents of Medical Records as referred to in paragraph (1) shall be
submitted to the head of Health Services Facilities.
(3) In the event that Patients are incompetent, consent for the opening of the contents of Medical Records as
referred to in paragraph (1) may be granted by the closest family or their guardians in accordance with the
provisions of laws and regulations.
(4) The closest family as referred to in paragraph (3) shall include husband/wife, adult children, biological
parents, and/or biological siblings of Patients.
(5) In addition to the closest family as referred to in paragraph (3), consent for the opening of the contents of
Medical Records as referred to in paragraph (1) may be conducted by the heirs.
(6) In the event that the closest family and heirs are unable to grant consent because their existence is
unknown, are legally incompetent, have passed away, or are absent, the consent as referred to in
paragraphs (2) and (4) is not required.
(7) The opening of the contents of Medical Records for the purposes of administration, insurance payments,
or health financing guarantees as referred to in paragraph (1) letter c must be conducted in writing and/or
through an electronic information system at the time of patient registration at Health Services Facilities.

Article 35
(1) The opening of the contents of Medical Records without the consent of Patients as referred to in Article 33
paragraph (1) letter b shall be conducted based on the provisions of laws and regulations, for the
purposes of:
a. fulfilment of requests by law enforcement officers for law enforcement;
b. enforcement of ethics or discipline;
c. medical audits;
d. handling of extraordinary events/outbreaks of infectious diseases/public health
emergencies/disasters;
e. education and research;
f. protection efforts against the dangers of threats to the safety of other persons individually or the
community; and/or
g. other matters regulated under the laws and regulations.
(2) The opening of the contents of Medical Records as referred to in paragraph (1) shall be conducted without
revealing the identity of Patients.

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 (3) Requests for the opening of the contents of Medical Records shall be conducted by authorized parties or
institutions for the purposes as referred to in paragraph (1).

Article 36
(1) The opening of the contents of Medical Records as referred to in Article 35 must secure approvals from
the Minister.
(2) In order to secure the approval as referred to in paragraph (1), authorized parties or institutions shall
submit an application to the Minister through the Director-General.
(3) Based on the approval as referred to in paragraph (1), authorized parties or institutions shall submit a
request for the opening to the head of Health Services Facilities.
(4) Approval from the Minister as referred to in paragraph (1) shall be exempted for the opening of the
contents of Medical Records which is conducted on the basis of a court order, and may be conducted by
providing a copy of the Medical Record documents and/or showing the original documents.

Article 37
Exempted from the provisions as referred to in Article 35 paragraph (2), in the event of the opening of the
contents of Medical Records for the following purposes:
a. handling of extraordinary events/outbreaks of infectious diseases/public health emergencies/disasters;
and
b. protection efforts against the dangers of threats to the safety of other persons individually or the
community,
the identity of Patients may be disclosed to authorized institutions for follow-up in accordance with the provisions
of laws and regulations.

Division Seven
Waiver of Rights to the Contents of Medical Records

Article 38
(1) Patients and/or their family who inform the contents of Medical Records to the public through the mass
media are deemed to have waived the confidential rights to the contents of Medical Records to the public.
(2) The waiver of the confidential rights to the contents of Medical Records to the public as referred to in
paragraph (1) grants the authority to Health Services Facilities to disclose the confidentiality of the
contents of Medical Records as the rights to reply of Health Services Facilities.

Division Eight
Storage Period

Article 39
(1) Storage of Electronic Medical Record data in Health Services Facilities shall be conducted for at least 25

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 (twenty-five) years from the date of the last visit of Patients.
(2) After the time limit as referred to in paragraph (1) expires, Electronic Medical Record data may be
exempted from destruction if the said data will still be used or utilized.
(3) The destruction of Electronic Medical Records shall be conducted in accordance with the provisions of
laws and regulations.

Article 40
Further provisions on the organization of Electronic Medical Records as referred to in Article 3 up to Article 39
shall be regulated under the guidelines for Electronic Medical Records as determined by the Director-General.

CHAPTER III
DEVELOPMENT AND SUPERVISION

Division One
General

Article 41
(1) The Minister, governors, and regents/mayors shall perform development and supervision toward the
organization of Electronic Medical Records in accordance with their respective authorities and the
provisions of laws and regulations.
(2) In conducting the development and supervision as referred to in paragraph (1), the Minister, governors,
and regents/mayors may involve other related parties.
(3) The development and supervision in the implementation of Electronic Medical Records shall be directed to
ensure and improve the quality of Electronic Medical Record services.
(4) The development and supervision as referred to in paragraph (1) may be conducted through:
a. dissemination of information;
b. monitoring and evaluation; and/or
c. technical guidance.

Division Two
Sanction

Article 42
(1) The Minister in implementing the development and supervision may impose administrative sanctions upon
Health Services Facilities that violate the provisions as referred to in Article 3.
(2) The imposition of administrative sanctions by the Minister as referred to in paragraph (1) shall be
implemented through the Director-General.

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 (3) The administrative sanctions as referred to in paragraph (1) shall be in the following forms:
a. written reprimands; and/or
b. recommendations for revocation or revocation of accreditation status.

Article 43
(1) Administrative sanctions shall be imposed based on reports of alleged violations originating from:
a. complaints; and/or
b. monitoring and evaluation results.
(2) The report on the alleged violations as referred to in paragraph (1) shall be submitted to the Director-
General.

Article 44
(1) The complaints as referred to in Article 43 paragraph (1) letter a may be conducted by individuals, groups,
and/or institutions/agencies/institutes/organizations.
(2) The complaints as referred to in paragraph (1) must fulfill the following requirements:
a. must be conducted in writing; and
b. must have a description of events in which the facts can be traced.
(3) The complaints as referred to in paragraph (2) shall at least contain:
a. full name and address of reported parties; and
b. information containing facts, data, or indications of a violation.

CHAPTER IV
CLOSING PROVISIONS

Article 45
All Health Services Facilities must organize Electronic Medical Records in accordance with the provisions of this
Regulation of the Minister by no later than 31 December 2023.

Article 46
At the time this Regulation of the Minister comes into force, Regulation of the Minister of Health Number
269/MENKES/PER/III/2008 on Medical Records is repealed and declared invalid.

Article 47
This Regulation of the Minister comes into force from the date of its promulgation.
For public cognizance, it is hereby ordered that this Regulation of the Minister be promulgated in the Official
Gazette of the Republic of Indonesia.

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