The Government of Indonesia has enacted Government Regulation No. 43 of 2025 on Financial Reporting (“GR 43/2025”). GR 43/2025 serves as an implementing regulation of Law No. 4 of 2023 concerning the Development and Strengthening of the Financial Sector (“P2SK Law”). GR 43/2025 specifically governs the provisions on financial reporting obligations applicable to financial sector business actors or the other entities that engage in activity related to financial sector business actors.
Pursuant to Article 271 of the P2SK Law, financial sector business actors, as well as other parties engaging in business activities related to the financial sector, are required to submit financial reports. Furthermore, such financial reports must be prepared in accordance with applicable reporting standards and submitted through a financial reporting single window.
The detailed provisions regarding the applicable financial reporting standards and the establishment and operation of the financial reporting single window are set out under GR 43/2025. According to Article 2 of GR 43/2025, the scope of the regulation encompasses: (i) financial reporting; (ii) the establishment and role of the financial reporting standards committee; (iii) the financial reporting single window or joint financial reporting platform (Platform Bersama Pelaporan Keuangan or “PBPK”); (iv) support mechanisms for the financial reporting ecosystem; and (v) administrative sanctions. The following section will elaborate on the provisions stipulated in GR 43/2025.
Financial Reporting
Article 3 of GR 43/2025 stipulates that entity which bound to the obligation of financial reporting are: (i) the financial sector business actors and (ii) the parties engaging in business activities related to the financial sector (“Financial Reporter”).
Furthermore, the scope of the “financial sector business actors” under GR 43/2025 broadly includes:
- institutions operating in the industry of banking, capital markets, insurance, pension fund, and financing institution;
- pawn companies, guarantee institutions, the Indonesian export financing agency (Lembaga Pembiayaan Ekspor Indonesia), secondary mortgage companies, information technology-based peer-to-peer lending service providers (Peer to Peer Company), and entities administering mandatory public fund management schemes; and
- financial market infrastructure providers, payment system operators, financial sector supporting institutions, and other business actors in the financial sector, whether operating under conventional business practices or based on Sharia principles.
Article 3 paragraph (3) of GR 43/2025 also elaborates that other parties engaging in business activities related to the financial sector include:
- entities that maintain accounting records;
- individuals who are required to submit financial statements in the context of business interactions with the financial sector; and/or
- individuals who are obligated to submit financial statements under applicable tax laws and regulations.
As for the other parties engaging in business activities related to the financial sector, GR 43/2025 provides examples of such entities as follows:
- parties that are debtors of banks;
- parties that are debtors of financing companies or institutions;
- parties that are issuers and/or public companies in the capital market;
- parties that are issuers in the money market; and
- parties that engage in other business interactions with the financial sector.
With respect to financial reporting, GR 43/2025 mandates that financial reports shall be prepared in accordance with the Financial Reporting Standards. GR 43/2025 distinguishes between Financial Reporting Standards into General Financial Reporting Standards and Sharia Financial Reporting Standards. In addition, such Financial Reporting Standards will be established by the Standard Committee which is an independent institution under the President of Indonesia. Aside from that, the preparation of the report shall be conducted by a preparer (i.e., a Financial Reporter employee) who possesses both competence and integrity. Furthermore, according to GR 43/2025, competence in financial statement preparation may be evidenced through a formal education diploma, a professional certification in the field of accounting, or a chartered accountant. In addition, competence requirements may also be determined by the relevant ministry, institution, and/or authority.
GR 43/2025 also sets forth the mechanism for the submission of financial reports, which includes requirements on the declaratory statement of the Financial Reporter. Under GR 43/2025, financial reports prepared by the Financial Reporter shall be accompanied by a statement signed by the business owner or the highest authorized official within the business entity.
Furthermore, pursuant to Article 7, financial reports shall be submitted to the relevant ministry, institution, or authorized agency (i.e. financial reporting obligation for peer-to-peer company shall be submitted to the Financial Service Authority (Otoritas Jasa Keuangan)). Furthermore, such submission shall be conducted through the PBPK and from PBPK such financial report will be forwarded to relevant ministry, institution, or authorized agency.
Regarding the submission of financial reports, GR 43/2025 also differentiates the content of the financial reports based on the type of reporting entity. Such categorization is made according to whether such entity is a parent company or an entity which subject to mandatory audit requirements.
The Financial Reporting Single Window (Platform Bersama Pelaporan Keuangan /PBPK)
The PBPK, as the platform for financial reporting, shall be organized by the Ministry of Finance. However, the PBPK has not yet been established. Pursuant to Article 39 of GR 43/2025, the implementation of the PBPK will be conducted gradually, with the following provisions: for reporters that are public companies in the capital market sector, the platform shall be fully operational no later than 2027; for other reporters, the timeline will be determined by the Ministry of Finance based on the Minister’s phased approach and operational needs.
Support Mechanisms for The Financial Reporting Ecosystem
GR 43/2025 regulates the provision of assistance to the Financial Reporters to enhance their compliance in the preparation and submission of financial reports as required under GR 43/2025. Such assistance may include the implementation of socialization activities and/or other forms of support. Furthermore, the government may subsequently regulate the implementation of internal control systems that can serve as a reference for reporting entities.
Administrative Sanction
In relation to financial reporting regulated under GR 43/2025, sanctions may be imposed if a financial reporter fails to comply with the financial reporting obligations as set forth in GR 43/2025. However, GR 43/2025 does not explicitly specify the administrative sanctions that may be imposed towards such financial reporters.
CONCLUSION
The enactment of GR 43/2025 introduces a new mechanism for financial reporting applicable to financial sector business actors as well as companies affiliated with financial sector business actors. The key provisions of GR 43/2025 requires the Financial Reporters to prepare their financial statements in compliance with mandatory Financial Reporting Standards and to submit these reports through a designated platform. However, as of now, both of the Financial Reporting Standards and the Financial Reporting Single Window is not yet established. Nonetheless, for the Financial Reporters that are public companies, these provisions will be implemented no later than 2027.
For further information, please contact:
MetaLAW, Legal Consultant, Jakarta, Indonesia
general@metalaw.id
