Strengthening Bank Financial Report Transparency under Financial Services Authority (OJK) Regulation Number 18 of 2025
Summary
Financial Services Authority Regulation [Peraturan Otoritas Jasa Keuangan (POJK)] Number 18 of 2025 on Transparency and Publication of Bank Reports (“Regulation 18/2025”) was issued on August 4, 2025, and promulgated on August 8, 2025. This POJK takes effect 6 (six) months after its date of promulgation.
The main objective of the issuance of this Regulation is to enhance market discipline and reduce information asymmetry in the banking sector by requiring Banks to prepare, announce, and submit Publication Reports that are comprehensive, complete, accurate, current, intact, timely, and comparable.
Formally, this regulation revokes and replaces Financial Services Authority Regulation Number 37/POJK.03/2019 on Transparency and Publication of Bank Reports (“Regulation 37/POJK.03/2019”) as it was deemed no longer in line with international standards and recent legal developments.
Background and Context
The issuance of Regulation 18/2025 is based on the recognition that complete, accurate, current, and comparable banking information on financial condition, performance, risk exposure, and capitalization is essential to strengthen public confidence and maintain the stability of the banking system.
This Regulation also expands the scope of transparency to include information from parent entities, subsidiaries, related companies, and business groups. The broader coverage reflects the increasingly complex structure of banking conglomerates and the need to better understand potential risk exposures arising from various business activities.
From a regulatory standpoint, Regulation 37/POJK.03/2019 was deemed no longer aligned with international best practices and domestic regulatory developments. The Financial Services Authority (OJK) therefore introduced this updated framework to enhance the quality, consistency, and accountability of bank disclosures.
Comparison with the Previous Regulation
Regulation 18/2025 officially revokes and declares Financial Services Authority Regulation [Peraturan Otoritas Jasa Keuangan (POJK)] Number 37/POJK.03/2019 on Transparency and Publication of Bank Reports no longer valid.
The main fundamental changes are found in the following table:
| Aspect | Regulation 37/POJK.03/2019 | Regulation 18/2025 |
| Report Publication Obligation (Quality) | Obligation to prepare, announce, and/or submit Publication Reports (general in nature). | Must be prepared in a complete, accurate, current, intact, timely, and comparable manner. |
| Competence of Report Preparers | Executive Officers must be appointed and must possess knowledge and/or experience in accounting, without a mandatory CA certification requirement. | Executive Officers or at least 1 (one) member of the report preparation team from the Bank's internal staff must be competent, having passed the chartered accountant certification exam, with different levels according to the Bank Group Based on Core Capital [Kelompok Bank Berdasarkan Modal Inti (KBMI)]. |
| Monetary Sanctions (Preparation Violations) | Violations of financial report preparation were subject to administrative sanctions in the form of written warnings, as well as a fine of IDR 100,000,000.00 (one hundred million rupiah) for financial report preparation violations (Article 4 paragraph 1) and IDR 50,000,000.00 (fifty million rupiah) for violations of the December report audit (Article 4 paragraph 2). | Introduces substantial monetary sanctions (ranging from IDR 2 billion to IDR 50 billion) for violations of Financial Report Preparation Provisions. |
Key Provisions
The main substance of this Regulation, including other important practical provisions, is presented in the following table:
| Aspect | Regulation | Article |
| Report Responsibility & Oversight | The Board of Directors [Direksi] is fully responsible for the Publication Report, and the Board of Commissioners [Dewan Komisaris] (as well as the Sharia Supervisory Board [Dewan Pengawas Syariah] for Sharia Banks/Sharia Business Units [Unit Usaha Syariah (UUS)]) is responsible for conducting oversight of the implementation of the Board of Directors' duties and responsibilities. | Article 5 Paragraphs (1), (2), (3) |
| Financial Statement Consolidation Obligation | Banks exercising Control over Subsidiary Entities are required to prepare consolidated financial statements. | Article 6 Paragraph (4) |
| Competence of Report Preparers | Executive Officers or at least 1 (one) member of the report preparation team from the Bank's internal staff must be competent, having passed the chartered accountant certification exam, with different levels according to the Bank Group Based on Core Capital [Kelompok Bank Berdasarkan Modal Inti (KBMI)]. | Article 7 Paragraph (4) |
| Quarterly Announcement Deadlines |
Announcement on the website must be made no later than:
for the data position reports for March, June, and September, while the December data position report must be announced no later than the end of March of the following year. |
Article 13 Paragraph (2) |
| Annual Report Deadlines | The annual financial Publication Report and financial performance information must be announced on the website no later than 4 (four) months after the end of the Financial Year [Tahun Buku]. | Article 18 Paragraph (2) |
| Scope of Annual Report | The annual report must contain, among other things: general information, financial performance information, risk exposure and capitalization, Bank governance, audited annual financial statements, the internal control report on the Bank's financial reporting process, and information related to the Bank's business group. | Article 17 Paragraph (3) |
| Risk Exposure Report Format | The Risk Exposure and Capitalization Report must be prepared and announced Quarterly and Annually in a separate document. | Article 22 Paragraphs (1), (5) |
| Deadline for Material Facts (Incidental) | Announcement and submission of the Publication Report on material information or facts must be carried out no later than 2 (two) working days after the existence of the material information or fact. | Article 28 Paragraph (2) |
| Website Maintenance Obligation | Banks must maintain announcements of periodic Publication Reports (monthly, quarterly, annual, risk) on the Bank's website for at least the last 5 (five) years of reports. | Article 11 Paragraph (3), Article 13 Paragraph (6), Article 18 Paragraph (3), Article 24 Paragraph (4), Article 26 Paragraph (4) |
| Monetary Sanctions for Financial Report Violations | A monetary fine is imposed on Banks that violate the Financial Report Preparation Provisions as referred to in Article 6 paragraph (1), in an amount of at least IDR 2,000,000,000.00 (two billion rupiah) and at most IDR 50,000,000,000.00 (fifty billion rupiah). | Article 8 Paragraph (2) |
| Follow-up Administrative Sanctions | Repeated violations may be subject to sanctions in the form of a prohibition on issuing new products, a freeze on certain business activities, a prohibition on expansion, and/or a downgrade in the governance factor assessment. | Article 8 Paragraph (4), Article 34 Paragraph (2) |
| Sanctions for Main Parties | If the Bank continues to violate after being subject to administrative sanctions (fines and/or follow-up sanctions), the Bank's main parties may be subject to a sanction prohibiting them from acting as main parties. | Article 8 Paragraph (5), Article 34 Paragraph (4) |
| Transitional Provisions (HR Competence) | Fulfillment of chartered accountant competence must be implemented no later than 24 (twenty-four) months after this Regulation takes effect. | Article 36 |
| Transitional Provisions (New Report Implementation) | The quarterly publication obligation applies for the first time to the September 2026 data position, while the annual publication obligation applies for the first time to the December 2025 data position. | Article 37 Paragraphs (1), (2) |
Conclusion
Regulation 18/2025 strengthens transparency and market discipline in Indonesia’s banking sector through several key measures:
-
Enhanced Human Resource Competence and Accountability
The Regulation requires Executive Officers or members of the report preparation team to hold chartered accountant certification and reaffirms the Board of Directors’ full responsibility for the accuracy of published reports. -
Clearer Sanctions and Enforcement Mechanisms
The Regulation introduces monetary fines of up to IDR 50 billion for non-compliance, supported by follow-up sanctions such as restrictions on business activities or a downgrade in the Bank’s governance factor rating.
Banks are encouraged to strengthen internal reporting systems and allocate sufficient resources to ensure compliance with the implementation timelines stipulated under this Regulation.
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