09 Jun 2020
Covid-19 in Indonesia: Protocols Established for Reopening of Retail and Services Sectors


The Ministry of Health (“MOH”) has recently issued guidelines for the reopening of businesses during the current winding down of partial lockdowns around the country and subsequent transition to the much vaunted “New Normal.” The guidelines for offices and industrial workplaces are provided in MOH Decree No. HK.01.07/MENKES/328/2020[1] (for an ABNR Legal Update on this regulation, click here), while those for the retail and services sectors are set out in a Ministry of Health Circular (“MOH Circular”).[2]


The Ministry of Trade has now acted on the MOH Circular by issuing its own circular (“MOT Circular”)[3] setting out specific protocols to be applied by particular types of businesses when they reopen.  


As may be expected, there is quite a lot of overlap between the MOH Circular and the MOT Circular. The key difference, however, is that the protocol set out in the MOH Circular applies to all public areas of workplaces in the retail and services sectors, while the MOT Circular sets out a series of separate, more detailed protocols for specific types of businesses.


A. MOH Circular


Under the MOH Circular, the following protocol must be applied in public areas of workplaces in the retail and services sectors:


  1. Workplaces and public areas must be cleaned every 4 hours using disinfectant;
  2. Readily accessible and adequate handwashing facilities must be provided;
  3. Employees must be educated about the importance of protecting themselves from Covid-19 by practicing clean and healthy behaviors;
  4. Temperatures of all employees and visitors must be regularly checked, and entry denied to any person with a temperature of above 37.3 Celsius;
  5. Employees and visitors must wear face coverings;
  6. Readily accessible public information must be provided on physical distancing requirements and handwashing and face-covering discipline;
  7. Physical distancing should be applied by: (i) displaying distancing marks on floors, particularly in elevators, changing rooms, etc.; (ii) limiting the number of people in an area; (iii) ensuring appropriately distanced seating arrangements;
  8. Contact with customers should be minimized by: (i) installing barriers or glass screens; and (ii) using non-cash payment methods;
  9. Aggregations of people must be avoided by: (i) implementing a queuing system that complies with physical distancing requirements; (ii) minimizing direct meetings with customers by prioritizing online or phone interaction and, where possible, delivery or takeaway services; (iii) restricting service hours.


B. MOT Circular


The MOT Circular establishes specific health protocols for the following types of business:


  1. Traditional Markets;
  2. Convenience Stores (minimarkets, supermarkets, hypermarkets and department stores);
  3. Restaurants, diners, eating venues and cafes;
  4. Pharmacies, drugstores and medical equipment stores;
  5. Malls and shopping centers;
  6. Restaurants in expressway rest areas;
  7. Salons, spas, and recreation and tourism sites:
  8. Recreation facilities such as zoos, museums and art galleries.


The MOT Circular requires businesses to report on the application of the protocols to the head of the relevant local Covid-19 taskforce, with copies to the local government trade agency. However, no reporting deadlines or procedures are specified.


On enforcement and punishment for those who flout the protocols, the MOT Circular merely states that violations will be subject to appropriate action and sanctions in accordance with the prevailing laws and regulations.


For more information on the MOH Circular, the MOT Circular and what specific steps your business needs to take in order to reopen and comply with health protocols looking ahead, please contact any of the persons below, call us on +6221-2505125, or email us at


Mr. Emir Nurmansyah (

Mr. Nafis Adwani (

Mr. Agus Ahadi Deradjat (


[1] Minister of Health Decree No. HK.01.07/MENKES/328/2020 on Guidelines for the Prevention and Control of Corona Virus Disease 2019 (COVID-19) within Offices and Industrial Workplaces to Support Business Continuity during the Pandemic Emergency (“Decree 328/2020”), (Keputusan Menteri Kesehatan Nomor HK.01.07/MENKES/328/2020 tentang Panduan Pencegahan dan Pengendalian Corona Virus Disease 2019 (Covid-19) di Tempat Kerja Perkantoran Dan Industri dalam Mendukung Keberlangsungan Usaha Pada Situasi Pandemi).

[2] MOH Circular No. HK.02.01/MENKES/335/2020 (Surat Edaran Nomor Hk.02.01/Menkes/335/2020 Tentang

Protokol Pencegahan Penularan Corona Virus Disease (Covid-19) Di Tempat Kerja Sektor Jasa Dan Perdagangan (Area Publik) Dalam Mendukung Keberlangsungan Usaha)

[3] Ministry of Trade Circular No. 12 of 2020 on the Resumption of Trading Operations during the Corona Virus Disease 2019 (Covid-19) Pandemic and the New Normal (Surat Edaran No. 12 Tahun 2020 Tentang Pemulihan Aktivitas Perdagangan Yang Dilakukan Pada Masa Pandemi Corina Virus Disease 2019 (Covid-19) dan New Normal)


This edition of ABNR News and the contents hereof are intended solely to provide a general overview, for informational purposes, of selected recent developments in Indonesian law. They do not constitute legal advice and should not be relied upon as such. Accordingly, ABNR accepts no liability of any kind in respect of any statement, opinion, view, error, or omission that may be contained herein. In all circumstances, you are strongly advised to consult a licensed Indonesian legal practitioner before taking any action that could adversely affect your rights and obligations under Indonesian law.