Regulatory Alert I: Financial Services Governance
OJK Regulation No. 1 of 2026: Utilization of Foreign Workers by Banks
Regulation: OJK Regulation (POJK) No. 1 Year 2026 (Full implementation May 2026).
Summary: This regulation mandates that the majority of a bank's Board of Directors and at least 50% of its Board of Commissioners must be Indonesian citizens. It further restricts foreign workers (TKA) to specific advisory or executive roles with a maximum cumulative duration of five years.
Legal Implication: Foreign financial institutions must review board composition and TKA succession plans. Non-compliance may lead to administrative sanctions and restrictions on new foreign personnel approvals in the annual business plan.
Regulatory Alert II: Foreign Investment (FDI)
BKPM Regulation No. 5 of 2025/2026: PT PMA Paid-Up Capital Shift
Regulation: BKPM/Ministry of Investment Regulation No. 5 Year 2025 (Effective implementation June 2026).
Summary: The minimum paid-up capital for foreign investment companies (PT PMA) has been lowered to IDR 2.5 Billion, down from the previous IDR 10 Billion requirement. Simultaneously, the Ministry is strictly enforcing legacy divestment obligations for companies established prior to 2020.
Legal Implication: New investors benefit from lower entry costs, while existing PMA companies must audit their original licenses (IP/IUT) to ensure compliance with divestment clauses, as BKPM has initiated systemic monitoring via OSS RBA.
Regulatory Alert III: Corporate Compliance
MOL Regulation No. 2 of 2025: UBO Annual Verification Mandate
Regulation: Ministry of Law (MOL) Regulation No. 2 Year 2025 on Verification and Supervision of Beneficial Owners.
Summary: All corporations are now required to perform annual data verification and risk assessments of their Ultimate Beneficial Owners (UBO) regarding AML/CFT standards. The MOL now possesses direct authority to ascertain UBO status through independent verification.
Legal Implication: General Counsel should ensure that UBO data is updated in the AHU Online system by the June 2026 deadline. Failure to comply results in blacklisting and blocking of access to the corporate administration system (AHU Online).