News & Announcements

W&P Newsletter – Electronic Reporting for Shares Ownership and Shares Pledge in Tbk Companies

September 17, 2025 News

On 5 June 2025, the Indonesian Financial Services Authority (Otoritas Jasa Keuangan – “OJK”) issued OJK Circular Letter No. 10/SEOJK.04/2025 (“SEOJK 10/2025”), establishing new electronic platforms for Tbk Companies’ shareholders to report his/her/its shareholding and any creation of pledge over the voting shares. The key takeaways are as follows:

  1. SEOJK 10/2025 will take effect on 6 December 2025, from which date:
    • the report must be submitted electronically through Indonesia Central Securities Depository (“KSEI”). KSEI’s electronic reporting platform will be connected to a publication platform operated by Indonesian Stock Exchange (IDX) where the submitted reports will be available to public; and
    • the deadline for report submission will be shortened from 5 to 3 business days from the mandatory reporting triggering event.
  1. Highlights of the reporting requirements:
No. Matter Brief explanation
1. Subjects of the mandatory reporting on ownership
  1. Directors or Commissioners of a Tbk Company who hold voting shares in their Tbk Company, regardless the %.
  2. Any party (directly or indirectly) holding at least 5% of the Tbk Company’s voting shares.
  3. Controllers of a Tbk Company.

Note that subsequent reports are mandatory every time there is a change in voting shares ownership percentage, after rounding down the decimal fraction.*

*) For example, a change from 6.1% to 6.99% will not trigger the reporting requirement, since both are rounded down to 6% (shares percentage remains the same). However, a change from 6.9% to 7.1% will trigger the reporting requirement, since the rounded percentage changes from 6% to 7%.
2. Mandatory reporting on pledges Reporting requirement kicks in when:

  1. a shareholder pledges its/his/her shares in a Tbk Company amounting to at least 5% of voting shares (whether in one instance or cumulatively).
  2. there is a change in the percentage of pledged voting shares after rounding down the decimal fraction.*

If you have additional inquiries about this newsletter or would like a further guidance on navigating these regulatory changes, please contact us at info@wplaws.com or reach out to any of our lawyers.