Decree of the Board of Directors of IDX Number Kep-00066/BEI/04-2026 Imposes Stricter Activation Requirements and Mandates Negotiated Market for Gold ETFs
Introduction
On 22 April 2026, PT Bursa Efek Indonesia (“IDX”) issued the Decree of the Board of Directors of PT Bursa Efek Indonesia Number Kep-00066/BEI/04-2026 on Amendments to Regulation Number III-L on Exchange Members as Participating Dealers (“Decree 66/2026”), which will take effect on 11 May 2026. This regulation establishes new requirements for Exchange Members intending to act as Participating Dealers, particularly in relation to technology infrastructure activation procedures and transaction mechanisms for collective investment products.
This regulation responds to the introduction of a new investment instrument, namely Collective Investment Contract-Based Mutual Funds (“ETF”) whose units are traded with underlying assets in the form of gold. The presence of this Gold ETF product encourages IDX to adjust the qualification requirements for Participating Dealers to align with Financial Services Authority Regulation Number 2 of 2026 on Collective Investment Contract-Based Mutual Funds Whose Units are Traded on the Stock Exchange with Underlying Assets in the Form of Gold.
Comparison
Decree 66/2026 revokes and replaces the Decree of the Board of Directors of PT Bursa Efek Indonesia Number Kep-00003/BEI/01-2022 on Regulation Number III-L on Exchange Members as Participating Dealers (“Decree 3/2022”). The following table presents a comparison between Decree 66/2026 and Decree 3/2022:
Key Provisions
Participating Dealer Activation Procedure
Provision III.1 stipulates that all Participating Dealers must undergo an official activation process from the Exchange before obtaining the right to enter sell offers and buy bids into the Jakarta Automated Trading System (JATS). Participating Dealers must submit a written application using Form III-L.1 no later than 10 trading days prior to the listing of ETF units on IDX. Supporting documents for the application include:
- A copy of the official appointment or cooperation agreement with the Investment Manager;
- A copy of the Standard Operating Procedures (SOP) governing unit creation/redemption mechanisms, secondary market liquidity provision, monitoring of unusual transactions, and risk management;
- A copy of the live statement confirming that the Participating Dealer’s technology system is ready to operate and connect ETF transactions to JATS.
Rights of Participating Dealers
Decree 66/2026 regulates the rights of Participating Dealers under Provision IV.1. Exchange Members that meet the requirements as Participating Dealers are entitled to:
- Receive services from the Exchange in relation to their function as Participating Dealers; and
- Conduct the purchase and/or sale of Underlying assets and/or units of Collective Investment Contract-Based Mutual Funds (ETFs) traded on the Exchange.
Obligation to Record Transactions Through the Negotiated Market
Pursuant to Provision IV.2.6, IDX requires Participating Dealers to conduct the creation and redemption of client units directly through the Exchange. Securities companies must follow up the unit formation process by executing Exchange Transactions in the Negotiated Market system in accordance with Regulation Number II-A concerning Trading of Equity Securities. This mechanism ensures that each movement of ETF units is properly recorded within the Exchange’s supervisory system.
Obligation to Use SID and Flexibility in Managing Remaining Underlying (Odd Lot)
Provision IV.2.7.1 stipulates that in the purchase and/or sale of underlying shares in the primary market, the SID used may be the SID of the Participating Dealer or the SID of the Collective Investment Contract-Based Mutual Fund whose units are traded on the Stock Exchange. This constitutes an important expansion from Decree 3/2022, which only permitted the use of the Participating Dealer’s SID.
Meanwhile, Provisions IV.2.7.2 to IV.2.7.4 regulate the management of remaining underlying assets (odd lots), as follows:
- Odd lots are treated in accordance with the agreement between the Participating Dealer and the Investment Manager;
- Participating Dealers may open a special sub-securities account to accommodate odd lots for allocation in subsequent creation/redemption processes; and
- Where odd lots are absorbed as part of the Participating Dealer’s portfolio, the Participating Dealer is entitled to use them in its function as a Participating Dealer or to sell them outside such function.
Obligation for Rebalancing Coordination and Record-Keeping
Provision IV.2.9 requires Participating Dealers to coordinate with the Investment Manager in the event of changes to the composition of the underlying assets (rebalancing), to ensure that adjustment processes comply with applicable regulations, including the rights and obligations of the parties involved. Where more than one Participating Dealer is involved in the same ETF, Provision IV.2.10 allows rebalancing to be conducted jointly based on an agreement among Participating Dealers and the Investment Manager.
Furthermore, Provision IV.2.11 requires Participating Dealers to record all creation/redemption activities in the primary market and transactions in the secondary market in accordance with Financial Services Authority Regulation Number 52/POJK.04/2020 concerning the Maintenance and Reporting of Adjusted Net Working Capital (MKBD), which includes:
- Recording rights and obligations with the Investment Manager regarding ETF underlying assets;
- Recording rights and obligations with counterparties relating to ETF unit transactions;
- Recording odd lots in accordance with the agreement between the Participating Dealer and the Investment Manager; and
- Recording the status and location of funds and/or securities in sub-ledgers for securities or funds in accordance with the relevant book-entry transfers.
Transitional Provisions
Dictum Second stipulates that existing Participating Dealers must complete the activation of system infrastructure (submission of SOP and live statement) no later than 6 December 2027. Meanwhile, with respect to the obligation to record the creation or redemption of units through the Negotiated Market, Dictum Third sets the system implementation deadline as 5 January 2027.
Prior to the full implementation of the Negotiated Market obligation in 2027, Dictum Third letter b provides two interim operational options for Participating Dealers. They may either consistently submit manual reports to IDX for each creation/redemption transaction no later than 17:00 WIB on the same trading day, or accelerate compliance by directly implementing the Exchange Transaction mechanism in the Negotiated Market from the present time.
Closing
Decree 66/2026 accommodates the trading of Gold ETFs by imposing stricter qualification requirements for Participating Dealers. This new regulation requires Participating Dealers to complete formal system infrastructure activation at the outset and to execute and record all creation and redemption transactions of ETF units through the Negotiated Market. It also clarifies technical aspects regarding the expanded use of SID, the management of remaining underlying assets (odd lots), mandatory coordination for rebalancing, and standard MKBD recording obligations. Supported by a phased system implementation period until 2027, this update aims to ensure that every movement of ETF units is validly recorded and more effectively supervised within the Exchange’s monitoring system.
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