Indonesia's health-insurance framework became more detailed in 2026. OJK Regulation No. 36 of 2025, effective from 22 March 2026, covers medical and digital capabilities, utilisation review and coordination among health-coverage providers. It also requires health insurers to prepare and provide a coverage summary to make the policy easier for prospective policyholders, insured persons or participants to study.
The requirement points to an issue that extends beyond health insurance. An insurance product can be contractually valid, provide genuine protection and comply with regulation while still creating a poor customer experience if it is purchased with a mental model that differs from how the product actually works.
The problem becomes visible during a claim.
It may have been designed into the experience much earlier.
Product Complexity Is Also a Design Problem
Insurance has an unusual structure. Customers pay today for a benefit they may use months or years later—and perhaps never use during the policy period.
At purchase, some information is relatively easy to remember: premium, coverage limit, key benefits, provider network or whether a service is cashless. Yet the actual experience may also depend on exclusions, deductibles, co-payments, sublimits, waiting periods, definitions, claims procedures and renewal conditions.
Under Indonesia's current health-insurance rules, for example, insurers may offer products with risk-sharing features subject to specified conditions. Where the regulated co-payment structure is used, the customer portion is 5% of the submitted claim, capped at IDR300,000 for an outpatient claim and IDR3 million for an inpatient claim. Companies must also offer health-insurance products without risk-sharing features.
Terms like these are not minor details if the customer discovers them only when the policy is used.
Product comprehension should therefore be treated as part of product design, not simply as communication added after the product has been completed.
Making Information Shorter Is Not the Same as Removing What Matters
Financial products face a genuine tension. Complete documentation is necessary, yet customers may not have the time, expertise or motivation to read a lengthy contract before buying.
The answer is not to hide complexity.
It is to give complexity a better information hierarchy.
OJK Regulation No. 22 of 2023 places market conduct across the lifecycle of product design, information provision, marketing, agreements, service delivery, complaints and dispute handling. OJK requirements also state that product information should be clear, accurate, correct, accessible and not potentially misleading, covering matters such as benefits, costs, risks, rights, obligations and applicable procedures.
In December 2025, OJK issued PADK No. 37/PADK.08/2025 to provide more standardised guidance on product information, marketing communication and Product and/or Service Information Summaries.
The distinction is important: simplification is not omission.
A useful summary does not need to reproduce an entire policy on one screen. But customers should be able to build a reasonably accurate picture of what is covered, what is not, what costs may remain theirs, what they need to do when a claim occurs and what may change later.
Digital Insurance Raises the Standard
Insurance is also becoming increasingly digital.
OJK Regulation No. 36 of 2024 expanded the framework for Digital Insurance Services. Its scope includes digital product closing, while product development, underwriting and claims handling may also be conducted digitally subject to applicable requirements.
That speed is convenient. But smaller screens, shorter flows and conversion targets can also create pressure to compress information too aggressively.
A customer pressing “agree” does not demonstrate understanding.
Nor does making a PDF available for download automatically mean that material information has been communicated effectively.
The UX challenge in insurance is therefore not simply to move customers through a purchase flow as quickly as possible. It is to help them make decisions efficiently without removing information that could materially change those decisions.
Design Understanding Before Designing the Sale
A practical way to approach insurance communication is to organise the product around questions that resemble the customer's own mental model.
What am I covered for?
Key events, benefits and limits should be visible.
What am I not covered for?
Material exclusions should not become surprises at claim time.
What might I still have to pay?
Deductibles, co-payments and other relevant customer costs need context.
What do I need to do when something happens?
Documents, timing, channels and claim steps should be easy to locate.
What can change later?
This may include renewal conditions, premium review or other product-specific changes.
This is a GATICORP editorial framework, not an official OJK format.
The full policy remains essential. A summary does not replace it. But companies need to recognise the distinction between legal completeness and customer understanding.
Trust Is Built Before the Claim
No insurer can promise that every claim will be paid. Coverage still depends on policy terms, conditions, facts and the circumstances of each event.
What insurers can do is reduce the gap between what customers believe they purchased and what the product actually provides.
That is why market conduct does not end with advertising. OJK explicitly places product design, information, marketing, agreements, service and complaints within the same consumer-protection continuum.
For insurers, brokers, agents and digital-platform developers, the implication is significant.
A product that is easy to sell but difficult to understand may improve conversion today while transferring complexity into customer service, claims, complaints and reputation later.
Insurance is ultimately a promise about an event that has not yet happened.
The more complex that promise becomes, the more important it is for the customer to understand it before the moment they need that promise to perform.
- OJK — Regulation No. 36 of 2025 on Strengthening the Health Insurance Ecosystem. Effective from 22 March 2026. Used for the requirement to provide coverage summaries, medical and digital capabilities, utilisation review, coordination among health-coverage providers and risk-sharing provisions. This regulation specifically concerns health insurance and is not generalised to every insurance line.
- OJK — Press Release on Regulation 36/2025. Used to cross-check the current risk-sharing structure: insurers must provide health products without risk-sharing, while products containing the feature may apply a 5% co-payment subject to specified caps and/or an annual deductible under the regulation.
- OJK — Regulation No. 22 of 2023 on Consumer and Public Protection in the Financial Services Sector. Used for the market-conduct framework covering product design, information provision and communication, marketing, agreements, service, complaints and dispute handling.
- OJK — PADK No. 37/PADK.08/2025. Used for developments in the standardisation of product information and Product and/or Service Information Summaries. The regulation was issued on 2 December 2025.
- OJK — Regulation No. 36 of 2024. Used for the Digital Insurance Services context, including digital product closing and the ability to conduct product development, underwriting and claims handling digitally subject to applicable requirements.
- This article does not suggest that a complex policy automatically violates regulation or that every insurance product should use the same simplified format.
- The five-question framework covering coverage, exclusions, customer cost, claims process and renewal is a GATICORP editorial framework, not an OJK-prescribed format.
- This is an editorial article and not legal, actuarial or underwriting advice, nor a recommendation regarding any particular insurance product.
Published: October 8, 2026
