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A foreign doctor may practise in Indonesia only as a specialist or subspecialist who has passed a competency evaluation, holds an STR (registration certificate) and a SIP (practice licence), and has been requested by the health facility that will use their services. A foreign general practitioner does not fit this route. The one opening is a determination by the Minister of Health for specific conditions. For a company site clinic, that settles the question: a plan to bring a general practitioner from the home country to run the clinic cannot be handled like an ordinary expatriate hire, and the clinic head and the person in charge of services must still be Indonesian citizens.
This article is for management and HR teams, including those at foreign-managed companies, who are setting up health services at a mine, smelter, or construction project.
Which foreign doctors may practise?
Indonesia's current health law, Law No. 17 of 2023, limits practice by foreign medical staff trained abroad to specialists and subspecialists, and only after a competency evaluation (Article 248(1)). Government Regulation No. 28 of 2024 repeats that limit in Article 661(1), and Article 660(2) applies the same limit to foreigners who graduated from Indonesian schools. Minister of Health Regulation No. 13 of 2025 on health human resources states it for all foreign medical staff in Article 91(1).
Articles 662 and 663 of Regulation 28/2024 add these conditions:
- at least 3 years of practice in their field;
- a request from the health facility that will use them, based on its needs;
- the purpose is transfer of technology and knowledge;
- a term of up to 2 years, with one extension of 2 years;
- no independent practice.
The exception is narrow. Article 91(2) and (3) of Regulation 13/2025 lets the Minister approve foreign medical staff with other qualifications under specific conditions: health service needs, including in special economic zones (KEK), and education and training needs. The elucidation of Article 661(3) of Regulation 28/2024 gives special economic zones, charitable medical work, and disasters as examples. The decision sits with the Minister, not with the company. Article 107 of Regulation 13/2025 also leaves it to the Minister to set which types or positions of foreign medical staff, which regions, and which facilities may use them. We had not found that determination when this article was written, so ask the Ministry of Health directly before you plan around it.
On special economic zones, Government Regulation No. 34 of 2021 defines a KEK as an area with set boundaries, designated to carry out economic functions and receive specific facilities. A site inside an industrial estate is not automatically inside a KEK, so check the site's status against the zone's designation documents.
| Doctor you are planning for | Route under the rules |
|---|---|
| Foreign general practitioner | No standard route; only if the Minister makes a determination for specific conditions |
| Foreign specialist or subspecialist | Competency evaluation, adaptation, STR, and SIP, at the request of the user facility |
| Indonesian doctor trained abroad | Competency evaluation and adaptation, then STR and SIP (Law 17/2023, Articles 241 to 244) |
| Indonesian doctor trained in Indonesia | STR and SIP for the clinic where they work |
Professional licensing steps for a foreign specialist
Regulation 13/2025 sets out the sequence:
- The user facility registers the doctor and uploads their file to the health information system (Article 95(4)). The file covers identity, CV, professional and competency certificates from the home country, a logbook, proof of 3 years' work experience with a home-country practice licence, and a health certificate. Documents in other languages need a sworn translation into Indonesian or English.
- The competency evaluation starts with an administrative review, followed by an assessment of practical ability through equivalence and a competency test, or through a portfolio review (Article 94). A doctor found not yet competent must return to their home country (Article 98(4)).
- A foreign doctor's competency certificate is valid for 2 years and can be extended once for 2 years. In a special economic zone it is valid for 5 years (Article 103).
- Adaptation of up to 1 year at the user facility, under supervision, with an adaptation STR and SIP (Article 104). The facility head appoints a supervising doctor (Article 105). Doctors who qualify through the portfolio route are exempt from adaptation.
- STR and SIP. A SIP covers one place of practice only. For foreign staff, the STR and SIP last up to 2 years and can be extended once for 2 years, except in a special economic zone (Regulation 28/2024, Articles 677 and 682).
What the company owes on the employment side
A professional licence does not replace a work permit. Article 662(4) of Regulation 28/2024 and Article 108 of Regulation 13/2025 require foreign medical staff to meet employment requirements as well. The core rules are in Government Regulation 34/2021 on the Use of Foreign Workers:
- foreign workers may be employed only in specific positions for a specific period, with competence that matches the position (Article 4);
- the employer must hold an RPTKA (foreign worker utilisation plan) approved by the Minister of Manpower or an appointed official (Article 6);
- the employer must appoint an Indonesian counterpart for transfer of technology and skills, train that counterpart, provide Indonesian language training for the foreign worker, and send the worker home when the employment agreement ends (Article 7);
- foreign workers employed for more than 6 months must be enrolled in national social security; those employed for less must be insured (Article 8).
The health rules repeat part of this. Article 120(4) of Regulation 13/2025 requires a facility using foreign medical staff to have an employment contract with them, provide Indonesian language training, and assign an Indonesian counterpart doctor to every activity they carry out. The elucidation of Article 253 of Law 17/2023 gives the reason for the language training: so the doctor can communicate properly with patients.
There is also a terminology mismatch. The occupational health clinic standard in Minister of Health Regulation No. 11 of 2025 asks a clinic employing foreign medical staff to upload a permit document it calls an IMTA, while Regulation 34/2021 uses the term RPTKA approval. Confirm which document the licensing authority will accept when you apply for the clinic licence. ADR Medika does not provide foreign worker permit services; that work stays with the company or its employment consultant.
Who can lead a site clinic?
The occupational health clinic standard in Regulation 11/2025 requires the clinic head and the person in charge of services to be Indonesian medical staff. Even a fully licensed foreign specialist can only work as a service provider within that structure. Clinic organisation and minimum staffing by clinic type are covered in our article on mine site clinics.
The ban on independent practice also has a practical effect: a foreign doctor cannot set up a private consulting room in the mess or camp. They may practise only at the facility that requested them, with a SIP for that location. Article 108(3) of Regulation 13/2025 does exempt foreign staff in managerial positions from the technical requirements, but Article 120(3) still prohibits professional practice without a SIP for the place of practice.
What is the risk if an unlicensed doctor keeps working?
Article 312(c) of Law 17/2023 prohibits anyone from practising as medical staff without an STR or SIP. Article 442 sets a penalty of up to 5 years in prison or a fine of up to Rp500 million for anyone who employs medical staff without a SIP. Article 1(37) of the same law defines "any person" to include corporations.
Be careful with older references. Some articles still cite Law No. 29 of 2004 on Medical Practice, which Law 17/2023 revoked (Article 454(c)), or Minister of Health Regulation No. 6 of 2023 on foreign health workers, which Regulation 13/2025 revoked and which the Ministry of Health legal database lists as no longer in force.
Serving foreign workers with Indonesian doctors and nurses
For most sites, the shorter path is a clinic staffed by Indonesian doctors and nurses whose SIPs are issued for that clinic, with services arranged so foreign workers are properly looked after:
- prepare health history and consent forms in two languages, and name an interpreter from the company's staff for consultations that need one;
- keep a summary of each foreign worker's health history and medical check-up results at the clinic, so the site doctor is not starting from scratch in an emergency;
- agree the referral hospital, and record the company and insurance contacts to call when a foreign worker is referred;
- decide who escorts the patient during an evacuation, then include that in your staffing numbers, as shown in our article on calculating medical staff for rosters;
- make sure site doctors have occupational health and emergency care competence, as described in our article on hiperkes doctors and paramedics.
If the company still needs a foreign specialist, for example to transfer specialist skills, the professional licence and the work permit run in parallel. Both need planning well before the doctor's arrival date, with the user health facility identified from the start.
Our onsite clinic service places Indonesian doctors and nurses on your roster, maps the referral route, and arranges a medical escort when a patient is evacuated.
