New Provisions on Periodic Reports of Guarantee Institutions under POJK 11/2026

Introduction
On 4 September 2026, the Financial Services Authority issued Financial Services Authority Regulation Number 11 of 2026 on Periodic Reports of Guarantee Institutions (“POJK 11/2026”), which took effect on 17 September 2026. POJK 11/2026 regulates periodic reporting obligations for Guarantee Institutions, comprising guarantee companies, sharia guarantee companies, re-guarantee companies, and sharia re-guarantee companies. POJK 11/2026 was issued to integrate provisions concerning periodic reporting that were previously set out in several OJK regulations, thereby reducing the potential for duplication in data requests and facilitating Guarantee Institutions in preparing reports and OJK in conducting analyses.

POJK 11/2026 also constitutes the implementation of Article 28 paragraph (3) of Law Number 1 of 2016 concerning Guaranteeing as most recently amended by Law Number 4 of 2026. In addition, the reporting framework under POJK 11/2026 supports the development of the guarantee industry, particularly the transition in the supervisory method from compliance-based to risk-based supervision. In this context, POJK 11/2026 promotes the availability of higher-quality and validated reporting data through OJK's online reporting system.

Key Provisions

• Types of and Obligations to Prepare Periodic Reports

As stipulated in Article 2, each Guarantee Institution is required to prepare and submit Periodic Reports completely, accurately, and in a timely manner, consisting of three types, namely:

• • Monthly Report

The Monthly Report as stipulated in Article 3 contains monthly financial statement information and other required information.

• • Annual Report

a. Annual financial statements

The annual financial statements must be audited by a public accountant registered with OJK. In the event that the public accountant issues a management letter, the Guarantee Institution must include such management letter in the submission of the annual financial statements. Specifically for Guarantee Institutions that obtain a business licence from OJK within 3 (three) months prior to the end of the annual financial reporting period, the audit of the financial statements for the period in which the business licence is obtained may be conducted concurrently with the audit for the following annual financial reporting period.

b. Publication report

The publication report must contain information on the balance sheet, comprising assets, liabilities, and equity, as well as the calculation of the Guarantee Institution's profit and loss, derived from the audited annual financial statements. The publication report must be announced to the public no later than 30 April of the following year through at least one daily newspaper with wide circulation in the operational area of the Guarantee Institution and through the company's website.

• • Other Reports

The Other Reports as stipulated in Article 6 consist of 10 (ten) reporting categories, including reports concerning the appointment and realization of the use of public accountant services, business plans and their realization and supervision, self-assessment results of the soundness level, implementation of good corporate governance, sustainability reports, reports on the implementation of anti-fraud strategies, and other reports as may be determined by OJK from time to time.

• Procedures and Submission Deadlines

As stipulated in Article 9, Guarantee Institutions must submit Periodic Reports to OJK online through the OJK reporting system, subject to the following deadlines:

1. 1. Monthly Reports must be submitted no later than the 10th day of the following month;

   2. Annual financial statements must be submitted no later than 30 April of the following year;

   3. Proof of publication of the publication report must be submitted no later than 1 (one) month after the deadline for publication of the publication report; and

   4. Other Reports must be submitted in accordance with the deadlines stipulated in OJK regulations or other laws and regulations.

If the submission deadline falls on a public holiday, the submission deadline shall become the first following working day. If the deadline falls on a national holiday or collective leave day, OJK shall have the authority to determine the due date for submission of the report.

In the event that OJK's supervisory review of a Monthly Report identifies any information errors, the Guarantee Institution must submit a correction no later than 10 (ten) working days from the date of OJK's notification or the date of the final meeting discussing the results of the supervisory review. If the OJK reporting system for submitting corrections is not yet available, the correction shall be submitted online through OJK's mailing room service.

In the event of a technical disruption to the OJK reporting system or a force majeure event that prevents the Guarantee Institution from submitting Periodic Reports and/or corrections to Monthly Reports, OJK may determine a postponement of the submission deadline. A Guarantee Institution experiencing a force majeure event must notify OJK of such condition. The procedures for submitting Periodic Reports, submitting corrections, and postponing submission deadlines shall be further determined by OJK as stipulated in Article 12.

• Administrative Sanctions

Article 13 stipulates that violations of the obligations to prepare, submit, and correct Periodic Reports, including the obligation to include management letters and publish publication reports, shall be subject to administrative sanctions in the form of:

1. 1. written warning and/or

   2. reduction in the soundness level.

Late submission of Monthly Reports and/or annual financial statements shall be subject to a fine of Rp500,000.00 per day. If the report has not been submitted within 30 (thirty) days from the submission deadline, the Guarantee Institution shall be deemed not to have submitted the report and shall be subject to a fine of Rp30,000,000.00.

Information errors in Monthly Reports based on the results of OJK's supervisory review shall be subject to a fine of Rp2,000,000.00 per report. The imposition of a fine does not eliminate the obligation to submit Periodic Reports and/or corrections. After the violation has been remedied, the written warning sanction shall automatically cease to apply and OJK shall revoke the administrative sanction. Furthermore, pursuant to Article 14, OJK may conduct a reassessment of the principal parties of the Guarantee Institution for violations of the administrative sanction provisions.

• OJK Authority and Application of Sanctions

Article 15 grants OJK the authority to grant approval or adopt policies that differ from the provisions of POJK 11/2026 based on certain considerations. Furthermore, Article 16 stipulates that the imposition of fines for information errors in Monthly Reports as referred to in Article 13 paragraph (4) shall take effect for the submission of Monthly Reports for the January 2028 period.

Transitional Provisions

Article 17 stipulates that administrative sanctions imposed on Guarantee Institutions prior to the entry into force of POJK 11/2026 shall remain in effect. In addition, Guarantee Institutions that have been subject to administrative sanctions but have not yet fulfilled their reporting obligations shall be subject to additional administrative sanctions in accordance with the provisions of POJK 11/2026.

Closing

POJK 11/2026 integrates and simplifies the periodic reporting provisions applicable to Guarantee Institutions by regulating the types of reports, procedures and submission deadlines, correction mechanisms, and administrative sanctions within a single integrated framework. Guarantee Institutions must ensure that reports are prepared and submitted completely, accurately, and in a timely manner, including fulfilling the obligation to publish publication reports and making corrections where information errors are identified. With these provisions, POJK 11/2026 serves as one of the instruments supporting the quality of reporting data and the implementation of OJK supervision over the guarantee industry.