Regulation on Financial Reporting under Government Regulation Number 43 of 2025

Summary

Government Regulation Number 43 of 2025 on Financial Reporting (“GR 43/2025”) took effect on 19 September 2025. GR 43/2025 was enacted to implement the provisions of Article 273 of Law Number 4 of 2023 on the Development and Strengthening of the Financial Sector (“P2SK Law”). GR 43/2025 harmonizes financial reporting policies to create a more cohesive ecosystem, reduce the compliance burden on reporting entities, and enhance corporate governance in Indonesia.

Background and Context

Previously, the regulatory framework for financial reporting in Indonesia was scattered across various regulations, creating potential uncertainty for companies. Accordingly, GR 43/2025 was formulated to promote harmonization and establish a “robust financial reporting ecosystem.” This ecosystem is supported by four key pillars:

1. The establishment of the Joint Financial Reporting Platform (“PBPK”) as a single reporting window;
2. The formation of a Standards Committee as an independent standard-setting body;
3. The harmonization of financial reporting obligations to ensure preparation and submission by competent and ethical professionals; and
4. The strengthening of the supporting ecosystem through assistance and supervision.

Key Provisions

Who Is Required to Report?

Article 3 paragraph (1) of GR 43/2025 requires “Reporters” to prepare and submit Financial Statements. “Reporters” are divided into two main categories:

1. Business Actors in the Financial Sector

These are companies or institutions whose core business operates in the financial sector. Article 3 paragraph (2) specifies the following:

• Banking, capital markets, insurance, pension funds, and financing institutions;
• Pawn companies, guarantee institutions, the Indonesia Eximbank (LPEI), secondary housing finance companies (SMF), and peer-to-peer (P2P) lending operators;
• Institutions managing mandatory public funds (e.g., social security, pension, and welfare program administrators);
• Financial market infrastructure providers, payment system operators, supporting institutions in the financial sector, and other financial sector entities.

2. Parties Conducting Business Interactions with the Financial Sector

This category covers non-financial companies. The main criteria are set forth in Article 3 paragraph (3):

• Entities (with or without legal status) that maintain bookkeeping in accordance with laws and regulations;
• Individuals required to submit Financial Statements when engaging in business interactions with the financial sector;
• Individuals required to maintain bookkeeping under taxation laws and regulations.

Article 3 paragraph (4) further clarifies that “business interactions with the financial sector” include parties that:

• Banking debtors;
• Debtors of financing companies or institutions;
• Issuers and/or public companies in the capital market;
• Issuers in the money market;
• Engage in other business interactions with the financial sector.

Example of a Reporter required to submit Financial Statements:

PT A is a state-owned enterprise (BUMN) listed as a public company in the capital market sector. Under applicable laws and regulations, PT A is required to maintain bookkeeping. Therefore, PT A meets the criteria as a Reporter and must submit its Financial Statements to the relevant Ministries, Institutions, and/or Authorities through PBPK.

Example of a Reporter eligible to submit Financial Statements voluntarily:

CV B is a business actor categorized as a micro and small enterprise. Under the laws and regulations, CV B is not required to maintain bookkeeping. Therefore, CV B does not meet the criteria as a Reporter. However, CV B may still voluntarily submit its Financial Statements through PBPK.

Other Key Provisions

Sanctions: Ministries, Institutions, and/or Authorities (M/I/A) are authorized to impose administrative sanctions on Reporters who violate the obligations to prepare (Article 4) or submit (Article 7) Financial Statements. The mechanism for imposing sanctions will be further regulated by the respective M/I/A in accordance with their authority.

Transitional Provisions: Financial accounting standards previously established by professional accounting associations remain valid. Such associations may continue to issue financial accounting standards until members of the newly formed Standards Committee are appointed. The current standards will be replaced once the Standards Committee established under GR 43/2025 formally assumes its duties and issues new Financial Reporting Standards.

Conclusion

GR 43/2025 introduces several key provisions, including:

1. The mandatory submission of Financial Statements through PBPK (single window) by Business Actors in the Financial Sector and Parties Conducting Business Interactions with the Financial Sector; and
2. The establishment of a Standards Committee to draft and determine Financial Reporting Standards (both conventional and sharia-based).