The Financial Services Actors Information System (Sistem Informasi Pelaku "SIPELAKU") is provided by the Financial Services Authority (Otoritas Jasa Keuangan "OJK") and allows financial institutions and relevant stakeholders ("Users") to access the track records of individuals or entities involved in fraudulent or harmful practices for specific purposes, such as employee decisions and consumer profiling. In order to gain access to the system, Users must apply electronically to the OJK and must meet various anti-fraud reporting obligations. Meanwhile, the number of access rights that are granted for the system will be based on business complexity. In addition, Users are also required to maintain and track the confidentiality of their records through processes of internal governance, as well as through annual audits, with any non-compliance potentially resulting in fines of up to Rp. 6 billion.

The Financial Services Authority (Otoritas Jasa Keuangan "OJK") has revised the regulatory framework for Sharia Securities Lists by introducing a clearer set of classifications. The first category refers to the Sharia Securities List, which now includes sharia securities that are traded in Indonesia and that are issued by the OJK. Meanwhile, the second category covers the Foreign Sharia Securities List, which comprises sharia securities that are exclusively traded overseas and that are issued by designated issuers (Pihak Penerbit Daftar Efek Syariah "PPDES"). PPDES that were designated prior to the enactment of this updated Regulation will have to submit a report to the OJK within three months of its effective date in order to retain their status. Any failure to do so will be considered voluntary resignation and will lead to the revocation of their approvals.

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.

This Circular outlines six detailed aspects that relate to trade of digital financial asset, including crypto assets (collectively referred to as "Assets"), including: 1) Procedures for the notification of crypto-asset trade; 2) Procedures and mechanism for the submission of evaluation result of crypto assets in the crypto asset list ("Crypto List"); 3) Business plan of digital financial asset trading organizers ("Organizers"); and 4) The scope, procedures and mechanisms for the submission of periodic and incidental reports by Organizers.

The maximum funding limits for Information Technology-Based Joint Funding Services (Layanan Pendanaan bersama Berbasis Teknologi Informasi "P2P Lending") have been updated and now stand at the following values: 1) A maximum consumption funding limit of up to Rp. 2 billion and 2) A maximum productive funding limit of up to Rp. 5 billion. Moreover, any organizers of P2P Lending services ("Organizers") who offer productive funding levels of between Rp. 2 billion and Rp. 5 billion will be required to ensure that their non-performing loans do not exceed 5% over the previous six months and must not currently be subject to any OJK sanctions in the form of business restrictions or suspensions.

In addition to the already mandatory monthly and annual reports, this new framework has now also reinstated the mandatory quarterly insurance company reports that had previously been suspended. Moreover, this Regulation has also expanded the list of other miscellaneous reports (laporan lain) that must be submitted by insurance companies to now include: 1) Business plans; 2) Financial soundness self-assessments; 2) Anti-fraud measures; 3) Money laundering risk assessments; 4) Data updates; 4) Sustainability; and 5) Actuarial ownership.

Any discontinued insurance product, whether discontinued on the initiative of the relevant insurance company or based on an order issued by the Financial Services Authority (Otoritas Jasa Keuangan "OJK"), must now be reported within 10 business days. All such reports must be submitted by the directors of the relevant company and must provide a reason for the products discontinuation, as well as data on any active insurance policies. It should also be noted that the OJK may order the temporary or permanent discontinuation of insurance products if certain conditions are met, such as a product being declared harmful to policyholders, insured parties or participants.

The OJK will stipulate the following supervision statuses for certain types of PVML: 1) Normal supervision; 2) Intensive supervision; or 3) Special supervision. The Draft Regulation sets certain criteria for certain types of PVML and periods, which fall under certain statuses, specifically intensive and special supervision.

Organizers of Asset trading may only commence business operations after the relevant board of directors has first secured a business license by submitting an application to the OJK. However, it should be noted that the documents required to be submitted with all applications differ significantly depending on organizer type. Said requirements are broadly summarized in this edition of Indonesian Legal Brief.

The new framework on the approval and reporting of insurance products introduces detailed provisions on the termination of insurance products, either on the initiative of insurance companies or as ordered by the OJK. Insurance companies must halt marketing and notify policyholders and the OJK if any such terminations occur. Reports must include reasons for termination and data on active policies. These measures are designed to ensure the orderly discontinuation of products and the maintenance of regulatory oversight during transitions.