Indonesia to upgrade system for electronic reporting on ownership and encumbrance of shares in public companies

Under its Regulation No. 4 of 2024, Indonesia’s Financial Services Authority (OJK) issued tighter and more extensive requirements for disclosure of share ownership and encumbrance of shares in Indonesian public companies with effect from 28 August 2024. See our May 2024 bulletin on this topic.

Regulation 4 also foreshadowed the creation of a new electronic reporting system to be used for submission of the required disclosure reports on share ownership/encumbrance. To provide more details of the new electronic system, OJK has now issued Circular Letter No. 10/SEOJK.04/2025 (OJK Circular 10). These changes will come into effect on 5 December 2025.

Under OJK Circular 10, Indonesia’s Central Securities Depository (KSEI) will serve as the electronic reporting system provider and the Indonesia Stock Exchange (IDX) will serve as the electronic publication system provider. At the time of writing, the two required new systems had not yet been established. 

Key Points under OJK Circular 10

Once the electronic reporting system is in place, the following requirements will apply:

• Shorter reporting deadline –The deadline for submitting disclosure reports on share ownership/encumbrance will be shortened from five to three working days.
• Share ownership report publication – Share ownership reports will be published via the IDX’s website using its electronic publication system.
• Electronic submission – The reports will be submitted to OJK through the electronic reporting system provided by KSEI. KSEI will then transmit the reports to OJK (for disclosure purposes) and to IDX (for publication).

Reporting Procedures under Force Majeure

The updated reporting deadline and electronic submission mechanisms under OJK Circular 10 may be temporarily suspended if OJK announces on its website that the electronic reporting system is experiencing disruption due to certain force majeure events or technical issues and/or if the reporting party experiences force majeure impeding its ability to submit the electronic reports.

If any of these circumstances arise, the reporting party may submit its reports in electronic document format by direct submission to the head office of OJK or by email to [email protected] and [email protected]. Once the force majeure or other impediment to electronic submission has been resolved, the reports must be re-submitted through the electronic reporting system no later than five working days after the resolution of the relevant force majeure or other impediment.

Conclusion

As the reporting deadline will be shortened once the electronic reporting system becomes operational, it is essential to closely monitor developments. OJK Circular 10 requires that KSEI issue detailed user guidelines for the new system.