Abstract The COVID-19 pandemic that struck Indonesia in early 2020 created a national emergency that forced the government to make rapid decisions in procuring health facilities and distributing social assistance. This situation simultaneously opened loopholes for corrupt practices, as evidenced in the procurement case of Personal Protective Equipment (PPE) involving Ministry of Health officials, resulting in state losses of hundreds of billions of rupiah. This study aims to analyze whether the defendants' actions in the COVID-19 PPE corruption case can be qualified as corruption under Law Number 31 of 1999 in conjunction with Law Number 20 of 2001, and to analyze the criminal sanctions imposed. The method used is normative legal research with statutory and case approaches. The results show that the defendants' actions fulfill all elements of corruption under Article 2 paragraph (1) in conjunction with Article 2 paragraph (2), namely unlawful acts, self-enrichment, and state financial loss committed under certain conditions of national disaster. The criminal sanctions imposed are assessed as not yet reflecting proportional punishment given the magnitude of state losses and social impact. This study recommends strengthening emergency procurement oversight mechanisms and consistent application of maximum criminal penalties for corruption during disasters.