The Financial Services Authority (Otoritas Jasa Keuangan or "OJK") issued Circular Letter No. 7/SEOJK.05/2025 (“Circular Letter 7/2025”) on 19 May 2025, introducing sweeping new standards for private health insurance products, including mandatory co-payments, waiting periods, and risk-selection criteria, set to take effect from 1 January 2026.

A central provision mandated a minimum 10% policyholder co-payment per claim, capped at Rp300,000 for outpatient and Rp3,000,000 for inpatient care.

However, following pushback from the House of Representatives' Commission XI, OJK officially agreed to postpone implementation pending enactment of a more comprehensive OJK Regulation ("POJK"). Legally, this deferral creates a compliance vacuum: insurers cannot structure products around a suspended circular, yet the underlying obligations under OJK Regulation No. 36 of 2024, which amended the governing insurance operations framework, remain fully in force.

Until the replacement POJK is enacted, contractual ambiguity between insurers, employers, and policyholders will persist.