This newsletter focuses only on three key developments under POJK No. 5 of 2026 on the Conduct of Investment Manager Business: first, the introduction of a new business-activity-based classification for investment managers; second, the updated minimum paid-up capital and adjusted net working capital (Modal Kerja Bersih Disesuaikan or “MKBD”) requirements for MIKU 1 and MIKU 2; and third, the transition rules for investment managers that had already obtained their business licences from OJK before the regulation was promulgated.
At the centre of the new framework is MIKU (Manajer Investasi berdasarkan Kegiatan Usaha), which classifies investment managers by reference to the scope of their business activities. POJK No. 5 of 2026 divides the industry into MIKU 1 and MIKU 2, signalling a move away from a single licensing model toward a more differentiated structure. In practical terms, OJK is no longer treating all investment managers as operating within the same perimeter or subject to the same prudential expectations.
That distinction is substantive. MIKU 1 is limited to a narrower set of permitted activities, including individual discretionary portfolio management and certain collective investment products specifically enumerated in the regulation. MIKU 2, by contrast, may carry out the full range of investment manager business activities permitted under POJK No. 5 of 2026. The new regime therefore creates a lighter category for more limited business models, while reserving the broader platform for firms able to meet a higher regulatory threshold.
The prudential consequences are equally significant. MIKU 1 must have minimum paid-up capital of IDR25 billion and maintain minimum MKBD of IDR5 billion plus 0.1% of assets under management. MIKU 2 faces a higher threshold: minimum paid-up capital of IDR50 billion and minimum MKBD of IDR10 billion plus 0.1% of assets under management. In effect, the regulation aligns business scope with capital strength, reinforcing OJK’s emphasis on resilience, operational capacity, and market discipline.
For existing investment managers, the transition framework is one of the regulation’s most commercially significant features. Any investment manager that had already obtained its business licence from OJK before POJK No. 5 of 2026 was promulgated must choose whether it will be classified as MIKU 1 or MIKU 2, and must submit to OJK a follow-up action plan reflecting that choice within six months from promulgation. As the regulation was promulgated on 29 April 2026, the relevant deadline falls on 29 October 2026.
The consequence of inaction is addressed with unusual clarity. If an existing investment manager does not submit its classification choice by that deadline, it will be deemed to have chosen MIKU 2. Even then, it must still submit a follow-up action plan to comply with the requirements applicable to MIKU 2. Silence, therefore, does not preserve flexibility; it results in automatic placement into the more demanding category.
The transition is not merely procedural. Existing investment managers that elect MIKU 1 must satisfy the applicable MKBD and assets under management requirements within three years after promulgation. Those that elect MIKU 2 must, within the same period, meet the higher paid-up capital, MKBD, and assets under management thresholds, as well as the requirement to have a director overseeing the compliance function. In that sense, POJK No. 5 of 2026 is likely to influence not only compliance planning, but also capital allocation and business positioning across Indonesia’s investment management industry.