A hospital PMA is a foreign-owned limited liability company licensed under Government Regulation No. 47 of 2021 to build and operate a private hospital in Indonesia, and it can now be up to 100% foreign owned. That single fact covers the headline. It does not cover the stack of rules underneath it: bed-class thresholds, capital floors, clinic-type restrictions, telemedicine licensing, pharmaceutical distribution rules, staffing requirements, and BPJS accreditation. Each layer decides whether a healthcare investment actually opens its doors, not just whether it gets incorporated.
Key Takeaways
- Hospitals can be up to 100% foreign owned, but a PMA-owned hospital must be built as a Class A (minimum 250 beds) or Class B (minimum 200 beds) facility under Government Regulation No. 47 of 2021.
- Klinik utama (specialist clinics) allow up to 100% foreign ownership. Klinik pratama, Indonesia’s basic primary-care clinics, remain closed to direct foreign investment.
- A PT PMA needs a total investment plan of at least IDR 10 billion per business classification, with IDR 2.5 billion paid up under BKPM Regulation No. 5 of 2025. Actual hospital capex runs far higher once construction and equipment are counted.
- Foreign doctors need a Surat Tanda Registrasi (STR), typically valid two years and renewable once, plus a separate practice permit (SIP). Pharmaceutical distribution requires its own PBF license.
What Are the Foreign Ownership Rules for Hospitals in Indonesia?
Foreign ownership of Indonesian hospitals used to be capped well below full control. Non-ASEAN investors were limited to 67% of a private hospital, ASEAN investors to 70%. That changed under the 2020 Omnibus Law and its implementing regulation, Indonesia’s Positive Investment List, which lifted the cap to allow 100% foreign ownership of general and specialist hospitals.
Full ownership does not mean an open field. Government Regulation No. 47 of 2021 on the hospital sector requires a foreign-owned (PMA) hospital to be established as a Class A hospital, with a minimum of 250 beds, or a Class B hospital, with a minimum of 200 beds. Smaller, community-scale hospital classes stay reserved for domestic ownership structures. This bed-count requirement is the part most foreign investors miss when they read “100% foreign ownership” and assume any size project qualifies.
Hospitals also sit in the high-risk category under Indonesia’s risk-based licensing system, OSS-RBA. That means a hospital PMA needs a Business Identification Number (NIB) plus a separate operational license, not just the NIB alone. GR 47/2021 additionally requires every hospital, foreign or domestic, to provide support services such as laboratory, blood bank, and nutrition services as a condition of its operating license, and to complete accreditation within two years of first obtaining that license.
How Much Capital Do You Need for a Hospital PMA in Indonesia?
The statutory floor for any PT PMA, healthcare included, is a total investment plan of at least IDR 10 billion (roughly USD 650,000) per business classification (KBLI) per project location, excluding land and buildings. Under BKPM Regulation No. 5 of 2025, only IDR 2.5 billion of that needs to be paid up front into the corporate bank account, with the rest realized progressively against the investment plan. If you are still comparing entry vehicles at this stage, our comparison of PT PMA against PT PMDN and KPPA structures explains why PT PMA is almost always the right vehicle for a commercial healthcare operation.
That IDR 10 billion figure is a regulatory minimum, not a realistic hospital budget. A Class B hospital with 200 beds involves building construction, medical equipment procurement, and specialist staffing that routinely runs into the tens of millions of dollars before the first patient is admitted. Investors who plan around the statutory floor alone tend to underfund the project.
Notes from InvestinAsia Consultants
A pattern we see with first-time healthcare investors is treating the IDR 10 billion KBLI minimum as the project budget rather than the paperwork threshold. The regulatory floor gets your PT PMA incorporated and your KBLI approved. It has almost nothing to do with what a Class A or B hospital actually costs to build and staff. We generally advise clients to have their construction, equipment, and 18 to 24 months of operating capital modeled separately before the OSS filing, so the investment plan submitted to BKPM reflects the real project, not the minimum needed to clear registration.
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What Is the Difference Between Klinik Pratama and Klinik Utama for Foreign Investors?
Indonesia splits private clinics into two tiers, and only one of them is open to foreign capital. Klinik pratama are basic, primary-care clinics offering general practice services. They remain closed to direct foreign ownership and are reserved for domestic cooperatives, MSMEs, and Indonesian-owned entities.
Klinik utama are specialist clinics offering more advanced, specialist-level treatment. These moved from a 67% foreign ownership cap to up to 100% under the Omnibus Law. The catch sits in Ministry of Health Regulation No. 26 of 2018: a foreign-owned klinik utama must be established adjacent to, or near, a Class A or Class B hospital, and its information management system must integrate with that hospital’s. In practice, this means a standalone foreign-owned specialist clinic with no hospital nearby is difficult to license, even though the ownership percentage itself is unrestricted.
This is the distinction that trips up a lot of first-time healthcare investors. A general practice clinic model, the kind that would work in most Western markets as a low-capital entry point, is exactly the segment closed to foreign ownership in Indonesia. The specialist clinic model that is open comes with a physical proximity requirement most investors don’t budget for.
Can Foreign Companies Offer Telemedicine Services in Indonesia?
Telemedicine in Indonesia got its first broad legal foundation under Law No. 17 of 2023 on Health, which defines telemedicine as the provision and facilitation of clinical services through telecommunications technology. Government Regulation No. 28 of 2024, the implementing regulation, expanded the scope to explicitly cover teleconsultation and telepharmacy, and named the parties allowed to offer these services, including operators using a third-party application.
Before this, the only real framework was Ministry of Health Regulation No. 20 of 2019, which governed telemedicine between healthcare facilities rather than direct facility-to-patient services, leaving consumer-facing platforms in a legal gray area for years. A health-tech company acting as an intermediary platform typically falls under KBLI 63122 (web portal or platform activities). Every doctor or dentist delivering care through the platform still needs a valid STR and SIP, the same credentials required for in-person practice, and platforms handling patient data must comply with Indonesia’s Personal Data Protection Law (No. 27 of 2022).
I’ll be direct about the limits of what’s settled here. The 2023 Health Law and GR 28/2024 establish that telemedicine is legal and define its scope, but detailed implementing regulations from the Ministry of Health, covering platform accreditation standards and operator-level requirements, are still being developed. If you’re structuring a telemedicine entry now, expect the compliance requirements to tighten over the next one to two years rather than stay static.
Why Is Pharmaceutical Distribution Licensed Separately From Clinical Services?
A hospital operating license under GR 47/2021 covers clinical services. It does not cover the wholesale distribution of pharmaceutical products. That requires a separate license called a PBF (Pedagang Besar Farmasi), authorized under a Pharmaceutical Wholesale Trade License (SIUPBF) issued by the Ministry of Health, typically valid for five years. A PBF company must appoint a licensed pharmacist as its person in charge (Apoteker Penanggung Jawab), and any imported pharmaceutical product must clear BPOM (the food and drug agency) registration before it can be distributed.
This separation matters for structuring. A hospital PMA that wants to also run pharmaceutical distribution, whether to supply its own network or sell to other facilities, needs the PBF license as a distinct approval layered on top of hospital licensing, not something that comes bundled with the hospital’s NIB. Wholesale distribution of pharmaceutical raw materials and healthcare equipment is itself fully open to foreign ownership, which is useful for investors who want to combine a clinical facility with a supply chain arm, but it still runs through its own licensing track.
Also read: Pharmaceutical Industry in Indonesia: Outlook and Opportunities
Do Foreign-Owned Hospitals Need Indonesian Medical Staff?
Ownership and clinical staffing are governed separately. A hospital PMA can be 100% foreign owned, but every doctor, dentist, and specialist practicing inside it, foreign or Indonesian, must hold a Registration Certificate (STR) and a Practice License (SIP). For foreign doctors, the STR is generally valid for two years and can be extended once for an additional two years, regardless of whether they graduated from a local or overseas university. Beyond credentialing, foreign doctors typically face qualification-equivalence checks, language requirements, and knowledge-transfer obligations tied to their practice permit.
In practice, this pushes most foreign-owned hospitals toward a workforce structure where the majority of day-to-day clinical staff are Indonesian, with foreign specialists brought in for defined roles or specialties where local supply is limited. It is a staffing and credentialing requirement, not a mandatory local equity partner, but the effect is similar: you cannot run a foreign-owned hospital in Indonesia with an entirely foreign medical team.
Tips from InvestinAsia consultant team:
- Start STR and SIP applications for foreign specialists well before the hospital’s target opening date. Credential review and knowledge-transfer documentation take longer than most investors initially plan for.
- Map your specialist roles against local supply early. Positions in genuine shortage areas clear faster than roles where an Indonesian equivalent is readily available.
- Build the hospital’s HR compliance file (updated STR, SIP, training records) from day one. Accreditors and BPJS credentialing teams both audit this during their review.
Also read: Pharma and Healthcare Investment Incentives in Indonesia
How Do Private Hospitals Qualify for BPJS Kesehatan Accreditation?
Joining Indonesia’s national health insurance network, BPJS Kesehatan, is not automatic once a hospital opens. A hospital must first complete accreditation through KARS (Komisi Akreditasi Rumah Sakit), which GR 47/2021 requires within two years of first receiving an operating license. Only after accreditation does BPJS run its own credentialing review, assessing the hospital across four technical areas: services and human resources, facilities and infrastructure, systems and procedures, and service commitment. A hospital that passes gets recommended for a BPJS cooperation agreement and is then reimbursed through the Indonesia Case-Based Groups (INA-CBG) tariff system rather than fee-for-service billing.
The payoff for going through this process is real. Private hospitals now make up the majority of facilities contracted under BPJS, giving them access to a patient base that public hospitals alone can’t cover. That’s a different market strategy from projects built around medical tourism and self-pay patients, like the hospitals under development in Batam’s International Tourism and Health SEZ, which are positioned to capture regional patients who would otherwise travel to Singapore or Malaysia rather than to serve the domestic JKN population.
Either path, BPJS integration or a self-pay and medical tourism model, needs its own licensing and operational planning, and the two aren’t mutually exclusive over the life of a facility. Business licensing across both routes, from the initial NIB to sector-specific operational permits, is where a lot of projects lose time. Our business licensing support covers this filing work directly with OSS and the relevant ministries.
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References
1. Republic of Indonesia. (2021). Government Regulation No. 47 of 2021 on the Organization of the Hospital Sector. Retrieved from
https://peraturan.bpk.go.id/Details/161982/pp-no-47-tahun-2021
2. Republic of Indonesia. (2023). Law No. 17 of 2023 on Health. Retrieved from
https://peraturan.go.id/id/uu-no-17-tahun-2023
3. Republic of Indonesia. (2021). Presidential Regulation No. 10 of 2021 on Investment Business Fields. Retrieved from
https://peraturan.bpk.go.id/Details/160222/perpres-no-10-tahun-2021
