[01]
Written warning
The first form of sanction in Article 42 of Permenkes 24/2022 for health facilities that have not implemented an EMR as required.
Regulatory Guide · SATUSEHAT Obligations
SATUSEHATObligations
The obligation to connect to SATUSEHAT is no longer just talk — in March 2026, 1,306 hospitals were hit with administrative penalties, and since 1 September 2026 SATUSEHAT RME has been in use across facilities. This is the map of the obligations, penalties, and readiness steps, explained without fear-mongering.
Legal basis
Mandatory, and now genuinely enforced.
The obligation for health-data interoperability through SATUSEHAT rests on Permenkes 24/2022 (the medical records regulation): a facility's EMR must be connected to the Ministry of Health's interoperability platform (Article 21) and its contents accessible to the Ministry (Article 28). Permenkes 6/2026 (the hospital regulation) adds an obligation to record and report in a health information system integrated with the National Health Information System (Article 74).
The big difference in 2026: enforcement is already underway. Through letter YM.02.02/D/971/2026 (11 March 2026), the Ministry of Health imposed administrative penalties on 1,306 hospitals (± 44%) that had not submitted complete EMR data to SATUSEHAT. By 9 April 2026, 112 of them had been found to run an EMR after clarification and had their accreditation status restored (letter YM.01.02/D/1452/2026, in Indonesian). Since 1 September 2026, that data also feeds SATUSEHAT RME, which shows patient history across facilities — the completeness of submissions is now directly visible to doctors elsewhere.
Understand the HMS obligations in Permenkes 6/2026Administrative penalties
what's at risk if you delay
The forms of penalty are set by Article 42 of Permenkes 24/2022: a written warning, and/or a recommendation to revoke, or revocation of, accreditation status. Their 2026 application follows letters from the Director General of Advanced Health. We map them so hospitals can weigh the risk reasonably, not to fear-monger.
[02]
Accreditation downgrade
Article 42 provides for a recommendation to revoke, or revocation of, accreditation status. In March 2026, accredited hospitals that had not sent complete EMR data to SATUSEHAT had their accreditation status lowered by one level.
[03]
Recommended license suspension
For hospitals that are not yet accredited and have operated for more than two years, the March 2026 sanction letter recommended suspending the business license.
[04]
The way back: clarification
Sanctioned hospitals can request a clarification. By 9 April 2026, 112 requests were accepted and accreditation status restored; 40 were rejected and could reapply by 1 July 2026.
Readiness steps
from installed to actually sending data
Many hospitals "already have a system" but their data isn't really flowing to SATUSEHAT yet. These four steps are what determine real compliance.
[01]
Complete data from the EMR
Submission to SATUSEHAT relies on an EMR that records data within the care workflow — not separate manual entry. What the Ministry assesses: visits (Encounter), diagnoses (Condition), prescribing and dispensing (MedicationRequest, MedicationDispense), laboratory (Specimen), and radiology (ImagingStudy).
[02]
Organization registration & credentials
The hospital registers its organization in SATUSEHAT and obtains platform access credentials.
[03]
FHIR R4 bridging
Clinical data is mapped to FHIR R4 resources and sent through the SATUSEHAT platform.
[04]
Test, then production activation
Submission is tested in the sandbox before being activated in production, with monitoring so data flows consistently.
Adievia's SATUSEHAT bridging module is ready, and since October 2026 Adievia HMS has been listed in SATUSEHAT's directory of EMR system providers. Production submission still uses each hospital's own SATUSEHAT organization and credentials. We provide guidance — we don't claim a status that hasn't been issued.
FAQ
Questions about SATUSEHAT obligations.
Yes. Permenkes 24/2022 on medical records requires a facility's electronic medical records to be connected to the health data interoperability platform run by the Ministry of Health — SATUSEHAT (Article 21) — and their contents to be accessible to the Ministry (Article 28). Permenkes 6/2026 on hospitals adds an obligation to record and report in a health information system integrated with the National Health Information System (Article 74).
Real and already enforced. Through letter YM.02.02/D/971/2026 dated 11 March 2026, the Ministry of Health imposed administrative penalties on 1,306 hospitals (about 44%) that had not submitted complete EMR data to SATUSEHAT — accreditation downgrades and, for some, a recommended licence suspension. The stage-1 clarification results came in letter YM.01.02/D/1452/2026 (16 April 2026): by 9 April, 112 clarification requests were accepted and those hospitals' accreditation status restored, while 40 were rejected and could reapply by 1 July 2026. Hospitals declared compliant are still monitored for consistent data submission to SATUSEHAT, so submissions must be complete and keep flowing.
The Ministry of Health launched SATUSEHAT RME on 1 September 2026: patient records — diagnoses, lab results, medications, procedures, vital signs, and radiology — are linked across health facilities per individual. It started at RSUP Dr. Wahidin Sudirohusodo Makassar and RS PON Jakarta, expanding to facilities already integrated. Outside emergencies, a doctor's access to a patient's history requires the patient's consent via a six-digit code in SATUSEHAT Mobile, and the access history is visible to the patient. In short, the completeness of each hospital's submissions determines what doctors elsewhere can see.
That is the direction, but it is not yet in general effect. The Health Ministry and BPJS Kesehatan are preparing a pilot of capability-based referral (RBKP), together with KRIS and iDRG, in Bandung City, Tulungagung Regency, Makassar City, and Muara Enim Regency. According to the Ministry, the pilot only takes effect once a Presidential Regulation is signed, and as of 8 November 2026 we have not found it issued. Once it runs, JKN patients are referred to a hospital able to treat their condition rather than up a ladder of hospital classes. For hospitals, accurate bed and service-capability data will then help decide where patients are sent. Adievia has integration modules for SISRUTE and RS Online, including bed availability; we do not claim integration with any new referral system.
We'll be honest: Adievia provides a ready EMR and FHIR R4 bridging module, and supports the onboarding. But SATUSEHAT certification and production activation rest with each individual hospital (organization registration, credentials, data readiness). We provide the tools and guidance — we don't sell instant compliance status.
Since the 30 July 2026 joint circular, ever more closely: JKN claims are being steered 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). Complete, consistent SATUSEHAT submission is no longer just an interoperability obligation; it will become part of the hospital's revenue path.
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