30 Sep 2026 · TAMA Insight
New Periodic Reporting Requirements for Guarantee Institutions in Indonesia
Indonesia has introduced a new regulatory framework governing periodic reporting obligations for guarantee institutions through Financial Services Authority Regulation Number 11 of 2026 on Periodic Reports of Guarantee…
Indonesia has introduced a new regulatory framework governing periodic reporting obligations for guarantee institutions through Financial Services Authority Regulation Number 11 of 2026 on Periodic Reports of Guarantee Institutions (“POJK 11/2026”).
POJK 11/2026 was stipulated on 4 September 2026 and promulgated on 17 September 2026. The regulation will come into force on 1 January 2027. It introduces a consolidated framework for monthly reports, annual reports, other regulatory reports, correction of inaccurate reporting information, reporting deadlines, and administrative sanctions applicable to guarantee institutions.
The regulation is particularly relevant to guarantee institutions preparing their reporting and compliance systems for 2027, as it expressly emphasizes the completeness, accuracy, and timeliness of periodic reporting and establishes specific consequences for reporting failures.
1. Mandatory Periodic Reporting Requirements
POJK 11/2026 requires guarantee institutions to prepare and submit periodic reports completely, accurately, and on time. The periodic reporting framework consists of monthly reports, annual reports, and other reports required under applicable laws and regulations.
Article 2 paragraph (1) establishes completeness, accuracy, and timeliness as express requirements for periodic reporting. The regulation is intended to support the availability of reliable information for OJK supervision and to integrate reporting requirements applicable to guarantee institutions.
The framework applies to guarantee institutions within the scope of POJK 11/2026, including guarantee companies, sharia guarantee companies, re-guarantee companies, and sharia re-guarantee companies.
Accordingly, reporting compliance under the new framework should be viewed not merely as an administrative filing obligation, but as part of the institution’s broader prudential and governance responsibilities.
2. Monthly Reporting and Correction of Errors
Monthly reports must contain monthly financial information and other information required under the applicable OJK requirements. Under Article 9 paragraph (1) letter a, monthly reports must be submitted online through the OJK reporting system no later than the 10th day of the following month.
Where the reporting deadline falls on a holiday, the deadline moves to the following working day. Where the deadline falls on a national holiday or collective leave, OJK may determine the applicable reporting deadline.
POJK 11/2026 also establishes a specific mechanism for correcting inaccurate monthly reports identified through OJK supervision. Where OJK identifies errors in information contained in a submitted monthly report, the guarantee institution must submit a correction based on the supervisory findings.
The correction must be submitted no later than 10 working days from the date of OJK’s written notification or the date of the final meeting concerning the supervisory findings, as applicable. A correction is considered submitted on the date it is received by OJK.
The regulation further provides that where the correction function in the OJK reporting system is unavailable, the correction must nevertheless be submitted online through OJK’s mailing-room facility.
In cases involving technical disruption or force majeure, OJK may postpone the applicable reporting deadline. Guarantee institutions affected by force majeure must notify OJK where the circumstances prevent timely submission of reports or corrections.
3. Annual Reporting and Public Disclosure
POJK 11/2026 provides that an annual report consists of audited annual financial statements and a publication report. The annual financial statements must be audited by a public accountant registered with OJK.
Where the public accountant issues a management letter, the guarantee institution must submit the management letter together with the audited annual financial statements. A specific rule also applies where a guarantee institution obtains its business license during the final three months of a financial year, allowing the audit for that year to be conducted together with the following financial year’s audit.
The publication report must contain, at minimum, the balance sheet and profit-and-loss information derived from the audited annual financial statements. The guarantee institution must publicly announce the publication report no later than 30 April of the following year.
The announcement must be made through at least one widely circulated daily newspaper in Indonesia within the institution’s operational area and through the guarantee institution’s website. Proof of the announcement must subsequently be submitted to OJK no later than one month after the publication deadline.
The annual reporting framework therefore connects audited financial reporting, regulatory submission, and public disclosure within a single compliance cycle.
4. Other Regulatory Reporting Obligations
In addition to monthly and annual reports, POJK 11/2026 includes various other reports within the periodic reporting framework. These include reports concerning public accountants and public accounting firms, business plans and their realization, self-assessment of the guarantee institution’s soundness level, implementation of good corporate governance, sustainability reporting, anti-fraud strategy implementation, and other reports determined by OJK.
The deadlines for these reports are generally governed by the specific OJK regulations or other applicable legislation governing each reporting obligation. Accordingly, guarantee institutions will need to maintain reporting calendars that extend beyond the monthly and annual reporting deadlines expressly established by POJK 11/2026.
This requirement is particularly relevant because failure to meet a reporting deadline under another applicable regulation may remain subject to the sanction or enforcement framework provided under that particular regulation.
5. Board of Directors’ Responsibility
POJK 11/2026 expressly assigns responsibility for the preparation and presentation of periodic reports to the Board of Directors. Article 7 provides that the Board of Directors is responsible for ensuring that periodic reports are prepared and presented completely, accurately, and on time.
This provision reinforces the governance dimension of regulatory reporting. The responsibility of the Board of Directors should therefore be considered together with the existing good corporate governance framework applicable to guarantee institutions.
Under POJK 3/POJK.05/2017 on Good Corporate Governance for Guarantee Institutions, guarantee institutions are also required to prepare an annual report concerning the implementation of good corporate governance. The governance report includes information concerning governance implementation, self-assessment results, and corrective action plans and is generally submitted no later than 30 April of the following year.
The interaction between these requirements means that reporting governance should be incorporated into the institution’s overall internal control and corporate governance framework.
6. Administrative Sanctions
POJK 11/2026 introduces specific administrative sanctions for violations of its periodic reporting requirements. Violations of specified provisions may result in written warnings and/or a reduction in the guarantee institution’s soundness level.
The regulation also establishes monetary sanctions for certain reporting failures. A guarantee institution that is late in submitting a monthly report and/or annual financial statements may be subject to an additional administrative fine of IDR 500,000 per day.
Where the relevant monthly report or annual financial statements remain outstanding for 30 days after the applicable deadline, the guarantee institution is deemed not to have submitted the report and may be subject to an additional administrative fine of IDR 30,000,000.
POJK 11/2026 also introduces a specific additional fine of IDR 2,000,000 per monthly report where OJK identifies information errors through supervision. However, this particular sanction will apply beginning with monthly reports for the January 2028 reporting period.
The imposition of an administrative fine does not replace the underlying reporting obligation. A guarantee institution that has been subject to an additional administrative sanction remains required to submit the outstanding report or correction.
The regulation further provides mechanisms for the termination or revocation of certain administrative sanctions after the relevant violation has been remedied. In addition, Article 14 allows OJK to reassess the main parties of a guarantee institution in connection with violations of the administrative-sanction provisions, in accordance with the applicable fit-and-proper reassessment framework.
7. Transitional and Implementation Provisions
Although POJK 11/2026 was stipulated on 4 September 2026 and promulgated on 17 September 2026, Article 19 provides that the regulation comes into force on 1 January 2027.
This distinction is important for guarantee institutions because the regulation’s publication date does not constitute its effective date. Institutions should therefore use the period before 1 January 2027 to prepare their reporting processes and internal controls for the new framework.
POJK 11/2026 also provides that administrative sanctions imposed before the regulation comes into force remain valid. Where a guarantee institution has previously been sanctioned but has not fulfilled its reporting obligations when the new regulation becomes effective, additional administrative sanctions may apply under the new framework.
The specific fine for inaccurate monthly reporting has a separate implementation timeline and will apply to monthly reports beginning with the January 2028 reporting period.
8. Practical Considerations for Guarantee Institutions
Guarantee institutions should review their reporting arrangements before POJK 11/2026 becomes effective. The review should focus on the institution’s reporting calendar, internal verification procedures, management oversight, correction mechanisms, annual audit process, public disclosure procedures, and coordination between regulatory reporting and governance reporting.
Particular attention should be given to the accuracy of monthly reporting because the regulation establishes a specific correction mechanism following OJK supervisory findings and introduces a monetary sanction for reporting errors beginning with the January 2028 reporting period.
Institutions should also ensure that responsibilities for preparation, review, approval, and submission of regulatory reports are clearly allocated within the organization. This is particularly relevant given the express responsibility imposed on the Board of Directors for the completeness, accuracy, and timeliness of periodic reports.
9. Conclusion
POJK 11/2026 establishes a consolidated periodic reporting framework for guarantee institutions in Indonesia and places greater emphasis on the quality, accuracy, and timeliness of regulatory reporting.
The principal requirements concern monthly reporting, annual audited financial statements, publication reports, other regulatory reports, correction of inaccurate monthly information, and Board of Directors’ responsibility for periodic reporting.
The regulation also establishes a more detailed administrative sanction framework, including written warnings and/or reductions in soundness level, daily fines of IDR 500,000 for specified late reports, an additional IDR 30,000,000 fine where reports remain outstanding for 30 days, and an IDR 2,000,000 fine for specified inaccurate monthly reporting beginning with the January 2028 reporting period.
As POJK 11/2026 will become effective on 1 January 2027, guarantee institutions should consider using the period before its effective date to assess their reporting systems, governance arrangements, internal controls, and regulatory compliance calendars.
This alert is intended for general information purposes only and does not constitute legal advice. Businesses should assess the application of POJK 11/2026 based on their specific circumstances and the other regulations applicable to their activities.
Please feel free to contact us should you wish to discuss the implications of POJK 11/2026 for your business, including periodic reporting obligations, regulatory compliance, and the preparation of internal reporting and governance procedures.
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