Financial service institutions (Lembaga Jasa Keuangan "LJK") are required to submit three types of documents to the Financial Services Authority (Otoritas Jasa Keuangan "OJK"), specifically documents that address anti-fraud strategies, anti-fraud strategy implementation reports and reports on acts of fraud that have a significant impact (collectively referred to as "Reports"). The timeframes for the submission of these Reports vary based on LJK type. The obligation to submit anti-fraud strategy implementation reports is also dependent on the capital and assets of the relevant LJK, while said reports should be submitted by one of the following dates: 1) 31 January 2025; or 2) 23 July 2025.

Participants in the trial mechanism that has been created in order to assess the feasibility and reliability of Technological Innovations Within the Financial Sector (Inovasi Teknologi Sektor Keuangan "ITSK") ("Sandbox") are first required to submit enrolment applications for the Sandbox mechanism. Said applications should be accompanied by the relevant testing plan concepts in order for assessments to be made of the readiness and innovative aspects of prospective participants. Moreover, the previously featured Digital Financial Innovations (Inovasi Keuangan Digital "IKD") criteria have now been redefined as criteria for innovations that are eligible to participate in the Sandbox mechanism, which now include: 1) Must have scope within the financial services sector; 2) Must be innovations that are ready to be tested and developed; and 3) Must provide benefits, improve services and provide added value to consumers, society and/or the financial-sector ecosystem.

Prospective organizers of Technological Innovations Within the Financial Sector (Inovasi Teknologi Sektor Keuangan "ITSK") are required to register themselves with the Financial Services Authority (Otoritas Jasa Keuangan "OJK") once they have shown that they are in compliance with the mechanism that is currently facilitating trials aimed at assessing the feasibility and reliability of the ITSK (Sandbox) phase or have been recommended by the OJK for such registrations. The registration of organizers of ITSK ("Organizers") commences with the submission of registration forms, along with four classifications of required data and information, including those that relate to information technology. These documents may include certificates from the International Organization for Standardization/International Electrotechnical Commission Standard 27001 on Information Security, Cybersecurity and Privacy Protection Information Security Management Systems Requirements (ISO/IEC 27001)

The Financial Services Authority (OJK) is preparing to introduce the Financial Services Actor Information System (Sistem Informasi Pelaku di Sektor Jasa Keuangan/SIPELAKU) in order to make a shared database available on fraudulent activities that take place within the financial sector, with the ultimate goal of minimizing any potential risks and ensuring stability across the sector

The Draft Regulation encompasses 103 articles spanning 19 chapters, including revised criteria for and structures of financial conglomerates, as well as provisions on the establishment and business activities of PIKK

This new Regulation has been drafted with a significant contribution being made by relevant stakeholders, resulting in a more comprehensive and promising consumer and public protection infrastructure. Despite the broad scope of this new framework, the public focus has been on provisions that set limits and requirements in relation to the carrying out of debt collection activities in an effort to prevent the violence and threats that are commonly associated with these activities

The scope of the specific audits that are required to be outlined within the aforementioned work agreements has also now been redefined, while the specific audit aspects have been classified into three main sectors (e.g. banking, capital market and non-banking financial institutions). While the scope of specific audits is quite broad, depending on the Parties themselves, each of said Parties specific audits include assessments of management assertions.

It is essential to note that, in preparation for the new regulation, companies are required to complete trial submissions of monthly reports from January 2024 until March 2024. This will help to ensure a smooth transition to the new reporting system.

The following obligations must be fulfilled by no later than 31 December 2023: 1) AP must secure sharia accounting knowledge certification; and/or 2) KAP must submit their cooperation agreements with any foreign KAP or foreign auditor organizations

Whereas previously, PJK were divided into three main parties, specifically those that were grouped under the banking sector, the capital-market sector and the non-bank sector, this new regulation states that there are now 18 types of PJK (conventional/sharia) that are subject to mandatory compliance with the various provisions addressed therein, including: 1) Banks; 2) Custodians; 3) Trustees; 4) IT-based crowdfunding services; 5) IT-based transaction services and financial sector technology innovation organizers; and so forth