Regulations That Change the Direction of the Industry
The Indonesian health insurance industry has entered a new era with the issuance of Financial Services Authority Regulation (POJK) No. 36 of 2025 concerning Strengthening the Health Insurance Ecosystem. This regulation is not merely an administrative improvement, but rather a structural reform that transforms the way health insurance is designed, managed, and monitored.
For years, health insurance in Indonesia has faced serious challenges: sharply rising premiums, uncontrolled claims, conflicts between hospitals and insurance companies, and uncertainty for policyholders—especially corporations. POJK 36/2025 is a response to these conditions by placing governance, risk management, and consumer protection as key pillars.
In the context of these major changes, one question becomes particularly relevant: is the old insurance broker model still relevant? The answer is increasingly clear: no. This POJK actually emphasizes the importance of the insurance broker’s new role as a risk advisor and healthcare ecosystem navigator.
The Essence of POJK 36/2025: From Risk Transfer to Risk Management
POJK 36/2025 marks a fundamental paradigm shift in health insurance. This regulation emphasizes that health insurance should no longer be understood solely as a claims payment mechanism, but rather as a comprehensive health risk management system.
Some of the key principles introduced include:
- Strengthening Governance and Risk Management
Insurance companies are required to have medical capabilities, digital capabilities, a Medical Advisory Board (DPM), and to conduct utilization reviews. This means that every claim and medical procedure must be assessed based on need, quality, and efficiency. - Restrictions on Repricing Premiums
Premium adjustments must not be made haphazardly. Repricing is limited to a maximum of once per year and must be accompanied by a transparent explanation and alternative options for policyholders. - Product Design Standardization and Risk Sharing
Products without mandatory risk sharing are available, while products with copayments and deductibles are strictly limited. This prevents the practice of excessive risk transfer to participants. - Obligation to Coordinate Benefits with BPJS Kesehatan (KAPJ)
Private health insurance must be integrated and complementary with BPJS, not run independently without coordination.
This regulation as a whole encourages the creation of a sustainable health insurance ecosystem, rather than a system that relies on premium increases as the sole solution.
Why the Old Insurance Broker Model Is No Longer Relevant
In the old system, insurance brokers were often positioned only as sales intermediaries.
The main focus is on:
- premium comparison,
- price negotiation,
- and policy administration management.
This model may still be relevant when regulations are loose and complexity is low. However, under POJK 36/2025, this approach becomes obsolete and even risky.
Some of the main disadvantages of old brokers include:
- Not Risk and Data Based
Transactional brokers rarely analyze loss ratios, utilization trends, or claims structures. As a result, their recommendations don’t address the root of the problem. - Not Understanding Governance and Compliance
POJK 36/2025 carries legal and reputational consequences. Brokers who don’t understand the regulations could potentially drag clients into non-compliant programs. - Failing to Manage Client Expectations
With utilization reviews and claims controls, claims are no longer always “automatically paid.” Legacy brokers are often unprepared to explain this reality to clients.
In the new context, brokers who only sell policies without strategic added value will naturally be eliminated.
Modern Brokers as Risk Advisors: A Role That Is Now Mandatory
POJK 36/2025 implicitly demands a transformation in the role of insurance brokers. Modern brokers are no longer mere intermediaries, but rather health risk advisors with strategic functions, including:
- Health Benefits Design Architect
Modern brokers help companies design benefits that:
- comply with regulations,
- according to employee risk profile,
- and cost-effective.
- Claims and Utilization Risk Controller
Through analysis of claims data and disease patterns, brokers play a role in:
- suppress unnecessary claims,
- controlling health cost inflation,
- and improve service quality.
- Orchestrator of KAPJ BPJS and Private Insurance
Implementing KAPJ is not simple. Modern brokers bridge the interests of:
- company,
- insurance,
- BPJS,
- and health facilities.
- Strategic Partner for Management and HR
In many cases, HR and finance lack the technical capacity to manage the complexities of health insurance. Modern brokers act as an extension of management.
L&G Insurance Broker: Ready for the New Era of Health Insurance
Amidst this transformation, L&G Insurance Broker is positioning itself as a brokerage that is ready and relevant to face the era of POJK 36/2025. L&G’s approach focuses not on short-term transactions but on long-term risk management and governance.
Some of L&G’s key differentiations include:
- Risk-Based, Not Price-Based Approach
L&G helps clients understand the root causes of claims and premiums, not just find the cheapest price. - In-depth Understanding of Regulation and Governance
By actively following OJK regulatory developments, L&G ensures that every recommendation is in line with the principles of prudence and compliance. - Cross-Industry Corporate Experience
L&G has experience assisting companies in the industrial, energy, construction and services sectors—sectors that have diverse and complex health risk profiles. - Position as a Strategic Partner, Not Just a Broker
L&G acts as an advisor that helps management make data- and risk-based decisions.
This approach makes L&G not only relevant, but necessary in the increasingly complex health insurance landscape.
Strategic Impact of POJK 36/2025 for Companies/Insured
For companies, POJK 36/2025 has major implications:
- Health insurance programs need to be re-evaluated
- Premium and benefit structures need to be adjusted
- KAPJ must be designed appropriately
- The risk of non-compliance must be avoided from the start
Without competent broker assistance, companies risk facing:
- uncontrolled cost increases,
- employee dissatisfaction,
- to potential disputes with healthcare providers.
Conclusion: It’s Time to Evaluate Your Health Insurance Program
POJK No. 36 of 2025 represents a catalyst for change, not simply a regulatory obligation. This regulation marks the end of the reactive and transactional era of health insurance and paves the way for a more rational, transparent, and sustainable system.
In this era, old insurance brokers are no longer relevant. What is needed is a modern broker who can act as a risk advisor, understand governance, and manage the complexity of the health ecosystem.
L&G Insurance Broker is here to answer these challenges—assisting companies in designing, evaluating, and managing health insurance programs that are compliant, efficient, and long-term oriented.
If your company wants to ensure its health insurance program remains relevant and sustainable in the era of POJK 36/2025, now is the right time to conduct a thorough evaluation.
Contact L&G Insurance Broker for a strategic discussion and review of your company’s health insurance program.
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HOTLINE L&G 24 JAM: 0811-8507-773 (PHONE – WHATSAPP – SMS)
Website: lngrisk.co.id
Email: halo@lngrisk.co.id
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