Indonesia’s Financial Services Authority (Otoritas Jasa Keuangan – OJK) has issued Regulation No. 7 of 2025 (“POJK No. 7/2025”), introducing a more structured and technology-driven for commercial banks acting as custodian banks reporting. POJK No. 7/2025 replaces the framework under OJK Regulation No. 24 of 2017 (“POJK No. 24/2017”), signaling a shift toward digital supervision and improved data accuracy, completeness, and timeliness.
Under POJK No. 24/2017, commercial banks who also acts as custodian banks were required to submit only two types of reports: a monthly activity report in printed form, accompanied by an electronic copy, and an annual operational audit report prepared by a Registered Public Accountant. POJK No. 7/2025 expands these requirements to include periodic reports—comprising monthly and annual submissions with more detailed content—and a new category of incidental reports, which must be filed in specific situations such as branch openings, changes in responsible custodian officers, or organizational adjustments.
POJK No. 7/2025 also revises the reporting timelines to provide greater flexibility while maintaining supervisory oversight. The monthly filing deadline has been extended from 12 days after month-end to the 15th of the following month, while the 90-day deadline for annual filings remains unchanged. In addition, custodian banks must now submit incidental reports within seven business days of the triggering event, a new requirement not previously found in the 2017 regulation.
A key modernization lies in the method of submission. All reports must now be submitted electronically through the OJK Reporting System, reflecting OJK’s push toward digital regulatory compliance. Offline submission is permitted only under limited circumstances—such as temporary system disruptions or when newly licensed custodian banks have yet to gain access to the system.
The sanctions framework has also been refined to promote compliance and accountability. While the previous regulation allowed OJK broad discretion in imposing administrative sanctions, POJK 7/2025 introduces a defined penalty structure of IDR 100,000 per erroneous data entry, capped at IDR 10,000,000 per report. Custodian banks are required to submit corrected filings within five business days of receiving OJK’s request.
Through these updates, OJK aims to strengthen data governance, enhance supervisory efficiency, and align Indonesia’s financial reporting framework with international best practices—ensuring that custodian banks operate with greater transparency, discipline, and technological integration.
