Almost all P2K3 guidelines circulating on the internet still reference Minister of Manpower Regulation Number PER.04/MEN/1987. That regulation has been revoked. Its replacement, Minister of Manpower Regulation Number 13 of 2025, was enacted on November 19, 2025, and takes effect on the same date. Several figures that have been used to form committees have also changed.
Mandatory Threshold
Article 3 paragraph (2) states that the obligation to form a P2K3 applies to workplaces or companies employing at least 100 workers or those with a high-risk level. The figure of 100 remains unchanged. What has changed is the method of determining high risk: paragraph (3) delegates this to business licensing provisions, no longer relying on lists of hazardous materials, processes, and installations as outlined in 1987. Your reference now is the risk classification in business licensing, not internal assessments.
How Many Members
The structure of the P2K3 consists of a chairperson, a secretary, and members. The chairperson is the top leader or management at the workplace. The secretary must be held by a designated K3 expert. Members must be balanced, and Article 6 provides the minimum numbers:
- companies with a maximum of 100 workers and high risk: at least 3 representatives from employers and 3 representatives from workers
- companies with at least 100 workers: at least 6 representatives from employers and 6 representatives from workers
Members are drawn from units handling K3, human resources, and production processes. If one area or building contains more than one workplace, membership must consider representation from each.
Deadlines to Note
The P2K3 is established by the Head of the Provincial Regional Office upon the proposal of the employer. The application must include three items: a proposal for membership along with the organizational structure, a copy of the decision appointing the K3 expert, and a description of the duties and responsibilities of each member. Document verification takes a maximum of 3 working days, and if it exceeds that, the documents are considered verified. The establishment is issued within a maximum of 5 working days.
This establishment remains valid as long as the membership does not change. A change in chairperson or secretary requires a renewal application within a maximum of 2 working days after the change occurs. Changes in ordinary members can be determined by the chairperson of the P2K3 and then communicated to the Head of the Office.
Six-Month Reports, Not Three
This is the change that is easiest to overlook. Article 11 requires the chairperson of the P2K3 to submit activity reports to the Head of the Provincial Regional Office with a copy to the Minister, once every 6 months or as needed. The 1987 regulation stipulated three months. Reporting is done electronically through the Ministry of Manpower's information system, and as long as that system is not available, manual reporting remains in effect. Article 15 sets the limit: the information system must be established no later than one year from its enactment, which is November 19, 2026.
Small Sanctions, Pressure Comes from Elsewhere
Article 14 delegates sanctions to the legislation regarding occupational safety. The reference is Law Number 1 of 1970 Article 15 paragraph (2), which threatens imprisonment for up to 3 months or a fine of up to Rp100,000, and describes the act as a violation. This amount has not been adjusted since 1970. Therefore, real pressure usually comes from SMK3 audits, inspections by labor supervisors, and requirements for cooperation contracts, not from the amount of the fine.
It should also be separated: P2K3 is the body, SMK3 is the system. Government Regulation Number 50 of 2012 Article 5 uses a similar threshold, namely at least 100 workers or a high potential hazard level, but the resulting obligations differ. The explanation of that article defines high potential hazards as those that can result in accidents causing loss of human life, disruption of production processes, and environmental pollution.
One thing that is not regulated that you should pay attention to. Permenaker 13/2025 does not contain transitional provisions for P2K3 establishment letters issued under the old regulations. If your company holds an old establishment, inquire about its status and renewal needs directly with the local provincial office, do not assume it will automatically continue.
Sources
- Minister of Manpower Regulation No. 13 of 2025 on the Committee for Occupational Safety and Health, JDIH BPK
- Copy of Minister of Manpower Regulation Number 13 of 2025, State Gazette of the Republic of Indonesia Year 2025 Number 954
- Law Number 1 of 1970 on Occupational Safety, JDIH Ministry of Manpower
- Government Regulation No. 50 of 2012 on the Implementation of SMK3, JDIH BPK
- Explanation of Government Regulation No. 50 of 2012, Supplement to State Gazette Number 5309