The Financial Services Authority (Otoritas Jasa Keuangan "OJK") has now permitted financing companies and sharia financing companies (collectively referred to as "Companies") to organize digital sharia financing services, including so-called Buy Now Pay Later ("BNPL") services. In this regard, financing companies utilize BNPL for multipurpose financing, while sharia financing companies utilize it for sale and purchase financing.
While maintaining Biodiesel (B100) and Bioethanol (E100) on the official list of biofuels (Bahan Bakar Nabati "BBN") permitted for utilization, the new framework of Regulation 4/2025 has now incorporated the following forms of BBN onto the list: 1) Biohydrocarbon Diesel (D100); 2) Bioavtur (J100); and 3) Other types of BBN, as further stipulated by the Minister. Furthermore, Regulation 4/2025 has redefined BBN utilization activities, as originally outlined under the previous framework, through the inclusion of specific categories of both commercial and non-commercial activities relating to BBN.
Exporters are now subject to various clarified requirements regarding the placement of Foreign-Exchange Export Proceeds (Devisa Hasil Ekspor "DHE"), with further Regulations to be determined by the government. Additionally, placement instruments have been expanded to include foreign exchange securities and sukuk issued by Bank Indonesia ("BI"), which can also serve as underlying transactions for hedging swaps. Certain provisions related to placement calculations and voluntary deposits have also now been removed, while exporters operating externally to the oil-and-gas sector have now been granted increased flexibility in terms of their ability to convert proceeds to local currency.
Decree 15/2025 has been issued in a bid to strengthen judicial integrity by requiring judges to disclose any relationships and affiliations that may lead to conflicts of interest, including family ties up to the third degree of separation, as well as social connections and financial interests. Said disclosures must be updated through the Court Information System (Sistem Informasi Pengadilan/SIP). Moreover, if any conflicting personal relationships and affiliations arise during any cases, then the relevant judges must resign from said cases. The Head of the Supreme Court should then appoint a replacement in order to ensure impartiality.
Regulation of the Financial Services Authority (Otoritas Jasa Keuangan "OJK") No. 3 of 2025 on the Implementation of Professional Certification Institutions Within the Financial Services Sector ("Regulation 3/2025") strengthens the governance of Professional Certification Institutions (Lembaga Sertifikasi Profesi "LSP") that deal with finance. This new framework requires LSP to bring their various certification schemes into line with Indonesian National Work Competency Standards (Standar Kompetensi Kerja Nasional Indonesia SKKNI) and the Indonesian National Qualifications Framework (Kerangka Kualifikasi Nasional Indonesia KKNI), requiring them to be updated within six months of any changes being introduced.
While retaining the requirement for all work accidents and occupational illnesses (Penyakit Akibat Kerja "PAK") that involve employees to be reported within 48 hours of the occurrence of any accident or PAK diagnosis by the relevant employer, the Amendment now states that employers will have to assume responsibility for the provision of JKK benefits if such reports are not submitted within the determined timeframe. In this regard, the Amendment requires employers to submit applications for JKK benefit reimbursements to BPJS Ketenagakerjaan upon submission of the above-described work accident and PAK reports.
The Minister of Law has established a procedure for confirming Indonesian citizenship status through SKSK RI, which should now ensure greater legal certainty for Indonesian citizens abroad who lack or possess incomplete citizenship documents. Indonesian citizens abroad, including citizens who lack valid identity documents, must apply in writing through a Representative or KDEI providing their personal details and supporting documents. Applicants without any identifying documents must submit an SPTJM and a declaration that they have never held any foreign citizenship, along with any supporting evidence.
The government has now revised the obligation for all exporters that generate revenue from natural resource (Sumber Daya Alam "SDA") related activities (i.e. mining, farming, forestry and fisheries) (collectively referred to as "SDA Exporters") to deposit their foreign exchange proceeds (Devisa Hasil Ekspor "DHE") into designated monetary and/or financial instruments. The required minimum deposit amounts and holding periods now vary by industry, as follows: 1) All SDA exporters (except those in oil and natural gas): must deposit 100% of their DHE SDA for at least 12 months; and 2) All oil and natural gas exporters: must deposit at least 30% for a minimum period of three months.
The Third Amendment has now introduced the possible use of Quick Response Codes, which can be used to facilitate payments ("QR Codes") in line with national standards ("QRIS") and which can be utilized with or without scanning features. This technology takes the form of technologies that utilize data communications ("Messaging"), including Near-Field Communication (NFC) technology.
Organizers of technological innovations within the financial sector that are registered with and/or licensed under the OJK ("Organizers") must comply with two distinct reporting categories, specifically periodic and incidental reports. Periodic reports include monthly and annual submissions. Monthly reports detail ongoing business activities, while annual reports should include the realization of business plans and audited financial statements.