Breaking Down the New Electronic Reporting System: Share Ownership and Share Pledges under SEOJK 10/2025

Following the issuance of the Indonesia Financial Services Authority/Otoritas Jasa Keuangan (“OJK”) Regulation No. 4 of 2024 on Reports on Ownership of or Any Changes in Shares Ownership in Public Companies and Reports on Pledge over Public Companies Shares (“POJK 4/2024”), which we covered in our previous article, OJK has now issued Circular Letter No. 10/SEOJK.04/2025 on Electronic Submission of Reports on Ownership or Any Changes in Share Ownership in Public Companies and Reports on Activities of Pledging Public Company Shares (“SEOJK 10/2025”).  SEOJK 10/2025, issued on 5 July 2025, implements the provisions under POJK 4/2024, specifically regarding: (i) the implementation of report submissions through an electronic system; and (ii) the publication of reports on share ownership and share pledge activities. This will take effect six months after its issuance date, which means it will be effective starting 5 January 2026.

So, what exactly does SEOJK 10/2025 cover?

Below are the key points to note:

• Mandatory Use of The Electronic System

Under the POJK 4/2025, it is governed that once OJK has established an electronic reporting system, any reports for changes in shares ownership and on pledges over public companies’ shares must be carried out through such system. This obligation applies to:

1. members of the board of directors or board of commissioners holding voting shares, directly or indirectly;
2. any party holding at least 5% of voting shares, directly or indirectly;
3. the controlling shareholder; and
4. any party whose shareholding drops below 5%.

In addition, any shareholder who pledges public company shares must also submit a report through the same system if the shares pledged represent at least 5% of shares with voting rights, whether through a single transaction or a series of encumbering activities. (These parties are collectively referred to in this article as “Reporting Parties.”)

To support this reporting mechanism, OJK appoints the PT Kustodian Sentral Efek Indonesia (“KSEI”) as the Electronic Reporting System Provider. KSEI is responsible for receiving reports from Reporting Parties and forwarding them to OJK for compliance monitoring, as well as to the Bursa Efek Indonesia (“IDX”) for publication to the public.

KSEI must ensure the system is secure, reliable, and properly connected to the publication platform. This includes setting clear user guidelines, protecting access rights, maintaining audit trails for all reporting activities, safeguarding personal data, and storing submitted reports for a minimum of five years. KSEI must maintain adequate backup and disaster recovery infrastructure in Indonesia and comply with OJK’s minimum technical and security standards.

• Reporting Deadlines

SEOJK 10/2025 confirms that the reports must be submitted no later than three business days after:

1. the date of acquiring shares with voting rights or any change in shares with voting rights; or
2. the date when the share pledge agreement is signed.

This new deadline shortens the previous timeline under POJK 4/2024 which governs reports to be submitted within five-business-days before the electronic system was implemented.

• Publication of Reports

As discussed under point A above, after submission through the electronic system, each report will be forwarded by KSEI to OJK and then published by IDX as the appointed Electronic Publication System Provider through a connected electronic publication system. This ensures that updated information on share ownership and pledges remains accessible to the public.

IDX as the Electronic Publication System Provider is responsible for making the reports publicly available on its website, managing access to data received from KSEI, setting clear guidelines for publication procedures, and storing the published reports for at least five years from the date of submission.

Similar to KSEI’s responsibilities described above, the IDX’s publication system must remain directly connected to the electronic reporting system, maintain a complete audit trail for monitoring and verification, and have secure backup and disaster recovery facilities located in Indonesia. The system must also meet minimum standards for IT security, system reliability, and data management as required by OJK.

• Exceptions and Manual Back-Up Reporting

Under SEOJK 10/2025, it governs that reports may be submitted manually if:

1. OJK announces that the electronic reporting system and /or the electronic publication system cannot operate due to force majeure event such as natural disaster, war, civil unrest, fire, strike and other major incident or significant technical disruption;
2. there is a condition beyond the control and capacity of the Reporting Parties, including:
3. natural disaster, war, civil unrest, fire, strike, or other events that significantly affect the reporting party’s ability to submit the report through the electronic system; and/or
4. other significant events proven to prevent the reporting party from submitting the report through the electronic system, including verifiable technical disruptions.

In such cases, the report must be submitted manually by delivering them directly to OJK’s head office as an electronic document or sending it by email to mailingroomsumitro@ojk.go.id and helpdesk@ksei.co.id.

Once the issue has been resolved and OJK declares the system or condition back to normal, the Reporting Parties must resubmit the report through the electronic system no later than five business days after OJK announces or confirms that the situation has been resolved.

This requirement is important for any shareholders, company officers, and parties that pledge public company shares as collateral. Reporting processes must fully comply with the electronic submission and publication requirements under POJK 4/2024 and SEOJK 10/2025, including the stricter three-business-day deadline. Failure to comply with the timeline and system procedures may result in administrative sanctions, including written warnings, fines, or other measures as regulated under POJK 4/2024.

By: Nabilla Syahdinda Putri