SMK3 Meets ISO 45001

The draft revision of ISO 45001 (ISO/DIS 45001) is in its ballot among national standards bodies, which closes on 8 September 2026 (International Organization for Standardization [ISO], 2026). The draft grew out of a first committee draft in July 2025 and a revised draft in January 2026, and the final edition is expected in 2027, probably with a three-year transition period (DQS, 2026).

For many companies in Indonesia, this news touches two systems at once. The occupational safety and health management system known as SMK3 is mandatory under Government Regulation 50 of 2012 for companies that employ at least 100 workers or have a high hazard potential (Pemerintah Republik Indonesia, 2012). ISO 45001 is voluntary, and is often adopted because customers or parent companies ask for it. This article compares the three references, SMK3, ISO 45001:2018 and the draft, so that preparing for the revision does not turn into another pile of documents.

Four Comparison Criteria

We compare them on four criteria: the nature of the obligation, the structure of requirements, the hazards covered, and how conformity is assessed. These four tend to decide how much work an HSE team carries when two systems run side by side.

SMK3 Under Regulation 50/2012

SMK3 is mandatory. Article 5 of the regulation sets out who must apply it, and paragraph (4) states that employers must follow the regulation and may take international conventions or standards into account. Article 6 lists five stages: setting the policy, planning, implementing the plan, monitoring and evaluating performance, and reviewing and improving the system (Pemerintah Republik Indonesia, 2012).

Assessment is highly structured. Article 16 assigns it to independent audit bodies appointed by the Minister, auditing 12 elements, and Annex II sets three levels of 64 (initial), 122 (transitional) and 166 (advanced) criteria. Scores of 0 to 59 percent are rated poor, 60 to 84 percent good, and 85 to 100 percent satisfactory. Criterion 1.4 links worker consultation to the joint OHS committee (P2K3), and criterion 7.2.2 requires monitoring of the work environment covering physical, chemical, biological, ergonomic and psychological factors (Pemerintah Republik Indonesia, 2012).

The ISO 45001 Draft

ISO 45001:2018 uses the same high-level structure as other ISO management system standards, with clauses on context, leadership and worker participation, planning, support, operation, performance evaluation and improvement (ISO, 2018). The 2024 amendment added a requirement to determine whether climate change is a relevant issue for the organisation (ISO, 2024).

According to a certification body's summary published while the draft was being finalised, the revision focuses on mental health and psychosocial risk, working conditions that support well-being, hybrid and mobile work, climate risk and organisational resilience, the needs of a diverse workforce, and greater involvement of external providers and supply chains. The basic structure is expected to stay (DQS, 2026). Because it is still a draft, wording and clause numbers may change before publication (ISO, 2026).

Strengths and Weaknesses

SMK3's strength is legal certainty and detailed criteria. Auditors and companies read from the same list, and audit results are reported to the Minister. Its weakness is that a detailed checklist is easy to answer with documents, and the 2012 text does not describe psychosocial risk or remote work as explicitly as the ISO draft, even though psychological factors are mentioned.

ISO 45001 is more flexible because it is built on risk and organisational context, and it is recognised by international customers. An ISO certificate does not, however, replace the SMK3 obligation, since the regulation treats international standards only as something employers may take into account.

Field evidence suggests that existing systems make integration easier. A gap analysis at a garment manufacturer found a 12 percent gap against ISO 45001:2018, which was small because the company already ran ISO 9001:2015; the remaining gaps sat in clauses 4.1, 5.2, 6.2.1 and 6.2.2 (Yoshana et al., 2022). It is a single-company study and its figure cannot be generalised, but the pattern is familiar: gaps usually lie in context, policy and objectives rather than in operating procedures.

In our view, most themes in the ISO draft are not new to companies that run SMK3 seriously. What is often missing is a single integrated system. A company that keeps two sets of documents for the same risks carries a double audit burden and loses the overall picture of its risks.

Steps Toward Integration

Several steps can start before the final edition:

• Merge hazard and risk registers so they meet both the SMK3 criteria and the ISO planning clauses, and make sure the psychological factors already required by the 2012 regulation are actually assessed.
• Map the 166 SMK3 criteria to ISO 45001 clauses and run one internal audit programme for both.
• Use the P2K3 committee as the channel for the worker consultation and participation that ISO also requires.
• Review controls over contractors and external providers, since this theme is expected to carry more weight.
• Do not rewrite the system against a draft. Wait for the final text, but build the data and processes both references need.

Nusa Safety helps companies align these two systems. Through SMK3 and ISO 45001 Implementation, the Nusa Safety team builds an integrated system referenced to Regulation 50/2012 and ISO 45001. The SMK3 Internal Audit and ISO Gap Assessment and Internal Audit help companies see their gaps before an external audit or a transition to the new edition. Nusa Safety is not an SMK3 audit body appointed by the Minister and does not issue ISO certificates.

This article is general information and not legal or professional advice for any specific case.

References

1. DQS. (2026, June 12). The most important facts about the revision of ISO 45001 at a glance. DQS Holding GmbH. https://www.dqsglobal.com/en/about/newsroom/the-most-important-facts-about-the-revision-of-iso-45001-at-a-glance
2. International Organization for Standardization. (2018). Occupational health and safety management systems - Requirements with guidance for use (ISO Standard No. 45001:2018). https://www.iso.org/standard/63787.html
3. International Organization for Standardization. (2024). Occupational health and safety management systems - Requirements with guidance for use - Amendment 1: Climate action changes (ISO Standard No. 45001:2018/Amd 1:2024). https://www.iso.org/standard/88428.html
4. International Organization for Standardization. (2026). Occupational health and safety management systems - Requirements with guidance for use (Draft International Standard ISO/DIS 45001). https://www.iso.org/standard/89698.html
5. Pemerintah Republik Indonesia. (2012). Peraturan Pemerintah Nomor 50 Tahun 2012 tentang Penerapan Sistem Manajemen Keselamatan dan Kesehatan Kerja [Government Regulation No. 50 of 2012 on the implementation of occupational safety and health management systems]. https://jdih.kemnaker.go.id/peraturan/detail/58/peraturan-pemerintah-nomor-50-tahun-2012
6. Yoshana, A., Putra, M. F., & Setiowati, R. (2022). Gap analysis penerapan sistem manajemen K3 ISO 45001:2018 di PT. Citra Abadi Sejati (CAS) [Gap analysis of ISO 45001:2018 OHS management system implementation at PT Citra Abadi Sejati]. Jurnal Teknologi dan Manajemen, 20(1), 17-26. https://doi.org/10.52330/jtm.v20i1.52