Regulatory Guide · Permenkes 24/2022
The provisions by article, the deadline, retention, sanctions, and an EMR readiness checklist — explained by a vendor that builds its own system, complete with an honest mapping of what is already full and what is still being matured.
Summary
Permenkes 24/2022 on Medical Records requires every health facility to implement Electronic Medical Records, with a deadline for implementation no later than 31 December 2023 (Article 45). Compliance is not merely installing an application — it demands meeting the provisions on content, security, retention, and interoperability.
This guide maps those provisions thematically, with their article numbers, explains the risk of non-compliance without scaremongering, and then presents a checklist hospitals can use to assess themselves.
4 groups of provisions
The EMR provisions of Permenkes 24/2022 can be grouped into four broad themes. This is a map to make them easier to assess, not a replacement for the official Permenkes text — the article numbers are included so you can check them directly.
Every health facility must run an EMR (Article 3). The activities include at least patient registration, data distribution, entry of clinical information, information processing, data entry for claims, storage, quality assurance, and transfer of EMR content (Article 13).
The EMR must meet the principles of confidentiality, integrity, and availability (Article 29). Access rights are granted by the facility head as part of the standard operating procedure (Article 30), and the EMR may be supplemented with electronic signatures (Article 31).
EMR data is kept for at least 25 years from the patient's last visit; after that it may be exempted from destruction if it is still in use (Article 39). Where resources are limited, storage may be arranged with an electronic system operator that has data storage facilities in Indonesia (Article 22).
The medical record document belongs to the health facility and its content to the patient (Articles 25–26). The EMR must connect to the Health Ministry's interoperability platform, SATUSEHAT (Article 21), and the facility opens access to EMR content to the Ministry (Article 28).
Sources: the text of Permenkes 24/2022 on the Health Ministry's legal database (JDIH). The variables and metadata to record are set separately in Ministerial Decree HK.01.07/MENKES/1423/2022, and the 2026 sanction clarification results are in Director General of Advanced Health letter YM.01.02/D/1452/2026 (in Indonesian).
Honest mapping to Adievia
Transparency is our main weapon. Here it is as it stands — not a claim of "100% compliant".
Self-assess
Eight concise points to gauge how ready your hospital is — and, at the same time, a list of questions to put to a prospective vendor.
FAQ
Permenkes 24/2022 (the medical records regulation) requires every health facility to implement Electronic Medical Records (Article 3), no later than 31 December 2023 (Article 45). This covers hospitals, community health centres, clinics, and doctors' solo practices alike. After that deadline, health facilities that have not adopted an EMR may be subject to guidance and administrative sanctions.
Article 42 of Permenkes 24/2022 sets two forms of administrative sanction, imposed by the Minister through the Director General: a written warning, and/or a recommendation to revoke, or revocation of, accreditation status. Enforcement is real: through letter YM.02.02/D/971/2026 (11 March 2026), the Ministry of Health imposed administrative sanctions — including accreditation downgrades — on 1,306 hospitals that had not submitted complete EMR data to SATUSEHAT. Sanctioned hospitals could request a clarification: by 9 April 2026, 112 requests were accepted and those hospitals' accreditation status was restored, while 40 were rejected and could reapply by 1 July 2026 (letter YM.01.02/D/1452/2026). This page does not aim to alarm, but to map the risk reasonably.
Not that we can find. The "28 criteria" figure circulates widely, but it does not appear in Permenkes 24/2022, in Ministerial Decree HK.01.07/MENKES/1423/2022 on EMR variables and metadata, or in the Health Ministry's sanction letters. This page used the figure too; since 8 November 2026 we have replaced it with a map of the provisions by article. Which data must be recorded is set out in Decree 1423/2022.
The EMR must connect to the Health Ministry's interoperability platform, SATUSEHAT (Article 21), so it becomes the data source for those submissions, while UU 27/2022 (the personal data protection / PDP law) governs the protection of patients' personal data. All three are interconnected: a compliant EMR makes SATUSEHAT and PDP compliance easier at the same time.
Ever more directly. A joint circular signed 30 July 2026 — by BPJS Kesehatan, the Health Ministry, the Home Affairs Ministry, KPK, and BSSN — pushes JKN claims onto SATUSEHAT-integrated EMR: pilots run from August 2026, and according to the Ministry's 6 November 2026 presentation all JKN claims must be based on SATUSEHAT-integrated EMR from June 2027 (follow-up implementing guidance has not been published). Under this direction, a Permenkes 24/2022-compliant EMR is no longer just an administrative obligation; it underpins the hospital's BPJS cashflow.
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