Under this newly updated regulatory framework, the obligation to comply with written orders issued by the Financial Services Authority (Otoritas Jasa Keuangan ? ?OJK?) applies to Financial Service Institutions (Lembaga Jasa Keuangan ? ?LJK?) and/or certain parties. The scope of said certain parties has now been expanded to include primary parties, parties who are affiliated with LJK, non-LJK financial business actors, issuers and public companies. The OJK is also authorized to order LJK to undertake or accept corporate actions, which may include mergers, consolidations, acquisitions, integrations and/or conversions, as a part of efforts aimed at resolving various types of institutional issues. Any non-compliance with such written orders may result in the imposition of sanctions, which vary between individuals and corporations.

This new Regulation has now refined and revised a wide array of aspects that specifically relate to privately owned and government-owned pawnbroker companies (?Companies?). These revisions include the removal of the distinction between privately owned and state-owned Companies, an explicit definition of sharia Companies and the introduction of Maximum Loan Limits (Batas Maksimum Pemberian Pinjaman ? BMPP) in order to ensure adequate levels of financial stability. Legal entity and ownership rules also now allow for foreign participation in line with strict conditions, with significantly higher capital requirements and stricter shareholder eligibility criteria being introduced.

In order to ensure compliance with consumer and public protection standards, financial services business actors (pelaku usaha jasa keuangan/PUJK) are required to submit annual self-assessment reports to the Financial Services Authority (Otoritas Jasa Keuangan ? ?OJK?) by 30 September of each year. These reports should be prepared through a set of working papers and should cover key areas such as data protection, disclosures of product information and the handling of complaints. A designated board of directors? member should also be appointed to oversee the preparation and presentation of said reports, which should primarily be submitted via the OJK?s online system.

This Regulation has now strengthened consumer protection within the financial services sector through the establishment of a specific procedural framework for civil actions that are initiated by the Financial Services Authority (Otoritas Jasa Keuangan - ?OJK?). This new framework includes the authority of the OJK to file lawsuits without the need for any power of attorney, and also sets out expedited and simplified electronic court proceedings, as well as mechanisms for judgments, cassation, enforcement and the distribution of compensation by the OJK. The overall goal here is to ensure both legal certainty and accountability in relation to Financial Services Business Actors (Pelaku Usaha Jasa Keuangan/PUJK) and other parties who act in bad faith.

Buy-Now-Pay-Later (?BNPL?) services may be organized by commercial banks (?Banks?) and financing companies, either conventionally or based on sharia principles, in line with six core criteria (e.g. must be used in order to finance non-cash purchases of goods and/or services, must require no collateral, must set a specified limit [ceiling] and so forth). This Regulation also sets a grace period that will last until June 2026 for Banks and financing companies that are already offering BNPL services to bring said services into line with the new framework.

The Financial Services Authority (Otoritas Jasa Keuangan/OJK) has updated the asset and liability management framework for insurance and reinsurance companies (collectively referred to as Companies) by replacing Medium Term Notes (MTN) with Securities in the Form of Bonds and Sukuk (Efek Bersifat Utang dan Sukuk EBUS) without any public offerings. Additionally, Companies are now required to draw up quarterly financial statements in line with Indonesian accounting standards. Furthermore, Companies annual financial statements must be approved through general meetings of shareholders (Rapat Umum Pemegang Saham/RUPS) within six months of the end of the relevant financial year.

This new Regulation establishes a formal financial reporting system for financial sector business actors (Pelaku Usaha Sektor Keuangan/PUSK) and parties that conduct business interactions with financial sector institutions, who are required to prepare and submit financial reports (Reports). Said Reports may be prepared and submitted for general purposes or for specific purposes if this is requested by relevant ministries, agencies or authorities. Furthermore, Reports must be compiled by qualified professionals, signed by authorized representatives and submitted either directly or through a newly established centralized platform known as the Financial Reporting Single Window (Platform Bersama Pelaporan Keuangan/PBPK).

Regulation of the Minister of Finance No. 65 of 2025 (Regulation 65/2025) establishes a set of guidelines that address the organization of interest and margin subsidies through the Housing Credit Program. Credit access has now been expanded for micro-, small- and medium-scale enterprises operating within the housing sector, while the Budget User Authority (Kuasa Pengguna Anggaran KPA) will assume responsibility for the preparation of Annual Distribution Plans (Rencana Target Penyaluran RTP) for the 2025 - 2027 period. Subsequently, financial service institutions or cooperatives that are designated as social distributors under the Housing Credit Program (Distributors) will assume direct responsibility for this area from 2028 onwards.

The new circular introduces an updated framework for consumer complaint services (Complaint Services) in the financial sector. It requires Financial Services Providers (Pelaku Usaha Jasa Keuangan PUJK) to publish information on complaint procedures, in addition to their ongoing obligation to disclose complaint handling, and to appoint a member of the Board of Directors responsible for such publication. PUJK must also submit a Complaint Services Report to the Financial Services Authority (Otoritas Jasa Keuangan/OJK) on a semiannual basis, no later than 10 July of the current year and 10 January of the following year.

This Draft Regulation clarifies that the Financial Services Authority (Otoritas Jasa Keuangan/OJK) has the authority to file lawsuits as a part of its consumer protection mandate whenever regulatory violations that occur within the financial sector cause material losses. Such lawsuits may target licensed financial service business actors or other parties accused of acting in bad faith, with the ultimate aim of recovering consumer assets or securing compensation. Importantly, consumers will not have to shoulder any of the costs that are associated with this process, while any unclaimed compensation will be deposited with the court or designated institution.