On 5 June 2025, the Financial Services Authority (Otoritas Jasa Keuangan or “OJK”) issued a new Circular Letter* , which serves as the implementing guideline for OJK Regulation No. 4 of 2024. This new Circular Letter introduces a mandatory electronic reporting system for share ownership and share pledging activities of public companies.
Under this new regulatory framework, several parties are obligated to submit reports to OJK. These include members of the Board of Directors and Board of Commissioners who, either directly or indirectly, own voting shares in a public company. The obligation also applies to any party holding at least 5% of the voting shares, controlling shareholders who possess voting rights, and any party whose ownership falls below the 5% threshold as a result of a sale or other reduction in shareholding. In addition, shareholders who engage in share pledging transactions are also subject to the same reporting requirement.
All reports must be submitted electronically through the system provided by the Indonesian Central Securities Depository (Kustodian Sentral Efek Indonesia or “KSEI”), within a maximum of three business days after the transaction occurs or upon signing the relevant share pledge agreement.
The Circular further outlines procedures to follow in the event of system disruptions or force majeure situations, such as natural disasters or technical failures that prevent timely submission. If such circumstances occur, OJK will issue an official announcement through its website. During the disruption, the affected parties may submit their reports in electronic format either via email or directly to OJK’s headquarters. Once OJK announces that the system is operational again, the parties concerned must resubmit their reports through the electronic system no later than five business days from the announcement date.
*Circular Letter of the Financial Services Authority No. 10/SEOJK.04/2025 on Submission of Reports on Share Ownership or Any Changes in Share Ownership of Public Companies and Share Pledging Activities.
**Financial Services Authority Regulation Number 4 of 2024 concerning Reports on Share Ownership or Any Change in Share Ownership of Public Companies and Reports on the Pledging Activities of Public Company Shares