The integration of electronic medical records (EMRs) with the SATUSEHAT Platform is a crucial part of Indonesia’s digital health transformation because patient data increasingly determines service quality, patient safety, and continuity of care. However, existing legal arrangements have not yet provided an operational framework for determining liability when data processing or interoperability failures occur, such as inaccurate, delayed, unreadable, unsynchronized, or unavailable health data during healthcare services. This study aims to analyze the legal construction of EMR integration with SATUSEHAT within Indonesia’s health law and personal data protection regimes, and to formulate a legal liability model that supports service continuity, interoperability, data quality, and patient rights recovery. This research uses a normative legal method with statutory, conceptual, and functional comparative approaches. The findings show that EMR-SATUSEHAT integration constitutes a multi-actor legal construction involving healthcare facilities, electronic system providers, platform managers, and the state. This study proposes a liability model based on points of control and service-data risk, implemented through data recording and validation standards, interoperability audits, health data protection impact assessments, continuity procedures, cross-system data correction, complaint mechanisms, and patient rights recovery.
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