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Legal Updates

Financial Services Authority Regulation Number 9 of 2026 Establishes the Mechanism for Incidental Reporting through the Financial Services Authority Reporting System

16 July 2026
Yumna Nafisah, S.H.
Legal Updates
Peraturan Otoritas Jasa Keuangan Nomor 9 Tahun 2026 Atur Mekanisme Pelaporan Insidental melalui Sistem Pelaporan OJK

Introduction

On 15 June 2026, the Financial Services Authority (Otoritas Jasa Keuangan or OJK) enacted Financial Services Authority Regulation Number 9 of 2026 on Incidental Reporting through the Financial Services Authority Reporting System in the Capital Market, Financial Derivatives, and Carbon Exchange Sectors ("POJK 9/2026"), which took effect on 1 October 2026. POJK 9/2026 regulates the digitalization of the mechanism for submitting incidental reports for all entities and professions in the capital market sector through a centralized reporting system, with the objective of enhancing the efficiency, speed, accuracy, and integration of electronic reporting processes.

Furthermore, POJK 9/2026 is intended to strengthen the effectiveness of technology-based supervision over all participants in the capital market, financial derivatives, and carbon exchange sectors. The digitalization of this reporting mechanism is designed to ensure the availability of complete, accurate, and timely data and information submitted to OJK, thereby serving as a basis for policy formulation and strategic decision-making.

An incidental report is a report prepared and submitted to OJK for supervisory purposes under certain circumstances or at a specific time outside the scope of periodic reporting obligations. The obligation to submit such reports applies to every party conducting activities in the capital market, financial derivatives, and carbon exchange sectors that is required under prevailing laws and regulations to submit incidental reports to OJK.

Circumstances requiring the submission of incidental reports include:

  • Special/Material Events: Material information or facts that may affect the financial condition of a company or the market price of its securities.
  • Regulatory Violations: The discovery of violations of laws and regulations in the financial sector or circumstances that endanger the business continuity of a bank or financial institution.
  • Information Technology (IT) Incidents: System disruptions or incidents that have caused or have the potential to cause significant losses and disrupt operations.
  • Structural Changes: Changes in authorized capital, temporary or permanent relocation of office addresses, or action plans relating to violations of the Legal Lending Limit (BMPK) or the Maximum Fund Distribution Limit (BMPD).

Key Provisions

Centralized Online Reporting Obligation

Pursuant to Article 2 paragraphs (1) and (2), every reporting party is required to prepare and submit incidental reports completely, accurately, and in a timely manner through an online platform, namely the Financial Services Authority Reporting System.

The Financial Services Authority Reporting System is an electronic reporting system administered by OJK and accessible through https://apolo.ojk.go.id.

This obligation applies to various entities and professions in the capital market, financial derivatives, and carbon exchange sectors, including:

  • stock exchanges;
  • clearing and guarantee institutions;
  • central securities depositories and settlement institutions;
  • securities companies;
  • custodian banks;
  • securities financing institutions;
  • securities crowdfunding service providers;
  • public accountants; and
  • members of the board of directors and board of commissioners of parties subject to reporting obligations.

Furthermore, Article 3 stipulates that the information submitted to the OJK system must be identical to the records retained by the Reporting Party. If any discrepancy is subsequently identified, the OJK database shall serve as the primary legal reference.

Deadline for Applying for User Access Rights and Mitigation of System Disruptions

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Pursuant to Article 8 paragraphs (1) and (2), every Reporting Party must submit an application for user access rights to OJK no later than two (2) business days after obtaining a business license, registration letter, or approval from OJK.

Furthermore, Article 8 paragraph (3) and Article 10 provide an alternative mechanism in the event that the OJK Reporting System experiences technical disruptions, is undergoing system development, or the Reporting Party has not yet obtained user access rights. Under such circumstances, the Reporting Party remains obligated to submit reports to OJK through offline means in accordance with the prevailing provisions, thereby ensuring continued compliance with reporting obligations and submission deadlines.

Mechanism for Correcting Reporting Errors

Article 5 regulates the correction mechanism for incidental reports where, after the expiry of the reporting deadline, inaccuracies in the reported data are identified, whether independently by the Reporting Party or as a result of OJK's supervisory activities.

In such circumstances, the Reporting Party must immediately notify OJK in writing of the identified error via electronic mail and/or through offline submission in accordance with the applicable provisions.

Where OJK identifies inaccuracies in the contents of an incidental report, OJK shall issue a written request for correction to the Reporting Party through OJK's official electronic mail address and/or by offline means.

Subsequently, pursuant to Article 6, the Reporting Party must submit the corrected Incidental Report through the Financial Services Authority Reporting System within no later than five (5) business days after receiving OJK's request for correction.

Extension of Time in Force Majeure Circumstances

To accommodate extraordinary circumstances beyond the Reporting Party's control (force majeure), such as natural disasters, Article 11 grants Reporting Parties the opportunity to obtain an extension or postponement of the deadline for submitting incidental reports.

Such relief may be granted provided that the Reporting Party submits a written application to OJK through offline (physical) submission no later than two (2) business days after the occurrence of the force majeure event.

Obligation to Provide Supervisory Data

For the purpose of carrying out its supervisory functions, Article 14 requires every Reporting Party to cooperate by providing any information and/or documentary data relating to an Incidental Report as requested by OJK.

In addition, where reporting data stored in the OJK system is subsequently damaged due to internal technical disruptions, Article 12 authorizes OJK to require the Reporting Party to resubmit the relevant incidental report.

Transitional Provisions

Article 19 provides that all provisions concerning the submission of Incidental Reports previously regulated under numerous OJK regulations, including regulations governing settlement institutions, investment managers, securities companies, and securities crowdfunding service providers, shall remain effective insofar as they do not conflict with the centralized online reporting obligations introduced under POJK 9/2026.

POJK 9/2026 establishes a graduated administrative sanctions regime. Pursuant to Articles 4, 7, 13, and 15, any party that fails to submit reports electronically, fails to comply with the five (5) business-day deadline for correcting reporting errors, or refuses to provide information during supervisory activities shall be subject to administrative sanctions. These sanctions range from written warnings, monetary fines, and restrictions or suspension of business activities, to the most severe penalties of revocation of business licenses and cancellation of the entity's registration with OJK.

Closing

POJK 9/2026 seeks to strengthen the governance of incidental reporting in the capital market, financial derivatives, and carbon exchange sectors through the implementation of a centralized and digitalized reporting mechanism utilizing the Financial Services Authority Reporting System.

In addition to requiring the electronic submission of reports, POJK 9/2026 introduces more comprehensive provisions concerning applications for system access rights, mechanisms for correcting reports, reporting procedures in the event of system disruptions or force majeure, and the obligation of Reporting Parties to provide data and information for supervisory purposes.

These provisions are complemented by a graduated administrative sanctions mechanism intended to promote compliance among all parties subject to reporting obligations.

With the entry into force of POJK 9/2026, all participants in the capital market, financial derivatives, and carbon exchange sectors must ensure that their internal systems, operational procedures, and reporting governance are aligned with the electronic reporting mechanism established by OJK. Compliance with POJK 9/2026 constitutes not only the fulfilment of regulatory obligations but also an essential component in supporting more effective, transparent, and technology-driven supervision within the financial services sector.

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