[Last updated: 1 February 2026, unless otherwise noted]

Periodic reporting obligations

Listed companies are required to submit periodic reports to the OJK and the IDX, including:

• An annual report, that is to be submitted no later than four months after the end of the financial year of the listed company. If the annual report is made available to shareholders before the deadline, the annual report must be submitted to the OJK on the day it becomes available to the shareholders. The annual report must be prepared in two languages, one being the Indonesian language and the other one being English.
• Consolidated financial statements consisting of:
  • An annual financial report audited by an accountant registered with the OJK, to be submitted not later than three months after the date of the report.
  • Any of the following mid-year reports: (a) a mid-year report (unaudited), to be submitted not later than one month after the date of the report; (b) a mid-year report with limited review by an accountant registered with the OJK, to be submitted not later than two months after the date of the report; or (c) a mid-year report audited by an accountant registered with the OJK containing a full opinion on the fairness of the report, to be submitted not later than three months after the date of such report.
  • Quarterly reports, the preparation of which is required by the rules of the IDX, to be submitted to the IDX not later than one month after the date of the report for a non-audited report, two months after the date of the report for a limited audit report, and three months after the date of the report for a fully audited report.
• An explanation of the use of proceeds as stated in the prospectus, or as modified with the approval of a general meeting of shareholders, which will be made in a report that covers the use of net proceeds from the initial public offering every six months until the proceeds have been used.

Non-periodic reporting obligations

Listed companies are also required to disclose to the public and report to the OJK and the IDX any material information or facts (Material Information or Facts) as soon as possible but in any event no later than the start of the next IDX first trading session (09:00 Jakarta). Material Information or Facts is defined as important and relevant information or facts regarding events, occurrences or facts that may affect:

• The valuation of the price of securities at the market organizer in the capital markets.
• The assessment of the price of securities by capitalists, investors, prospective capitalists or prospective investors or other parties that are interested in such events, occurrences or facts.
• The decision of capitalists, investors, prospective capitalists or prospective investors or other parties that are interested in such events, occurrences or facts.

Material Information or Facts may consist of, among other things, merger, acquisition, consolidation, stock split, stock dividend, change in management, labor disputes, replacement of a public accountant or replacements of a trustee and material legal claims.

Reporting obligations related to corporate actions

Listed companies that undertake material corporate actions (unless specifically exempted by the OJK rules) must do one of the following:

• Where the material transaction has a value of more than 50% of the company's equity, among other things, obtain a fairness opinion/valuation report from independent party, make a disclosure of information on the corporate actions, report to the OJK as well as obtain the approval of a general meeting of shareholders.
• Where the material transaction has a value of between 20% and 50% of the company's equity, among other things, obtain a fairness opinion/valuation report from independent party, announce such corporate actions to the public and report to the OJK.

Listed companies that undertake corporate actions that are considered as affiliated party transactions (transactions with an affiliated party) must do one of the following:

• Obtain a fairness opinion/valuation report from independent party, make a disclosure of information on the corporate actions and report to the OJK.
• To the extent a corporate action is, among other things: (i) an affiliated party transaction which is also a material transaction or (ii) a conflict of interest transaction (whether such transaction is done with the affiliated party or not), obtain the approval of the independent shareholders in a general meeting of shareholders in addition to making disclosure of the information to the public and reporting to the OJK.

In addition, if listed companies were to issue new shares, either with or without pre-emptive rights, the companies must issue a circular to their shareholders and make a disclosure of information on the corporate actions in that circular and obtain the approval of a general meeting of shareholders.

Shareholding reporting obligations

Under the Indonesian Capital Market Law (Law No. 8 of 1995 as last amended by Law No. 4 of 2023 on the Development and Strengthening of the Financial Sector) and OJK Rule No. 4 of 2024 on Reports on Ownership of, or Any Change of Ownership of, Shares in Public Companies and Reports on the Activities of Encumbering Public Company Shares (OJK Rule 4/2024), the following parties must report their ownership of voting rights over shares and any changes thereto through the electronic system provided by KSEI (https://akses.ksei.co.id/) within three business days from the transaction date (with the transaction date counted as day one):

• Members of the board of directors and board of commissioners who directly or indirectly hold shares with voting rights.
• Parties (including organized groups) that directly or indirectly hold at least 5% shares with voting rights.
• Parties (including organized groups) that directly or indirectly control a public company.
• Parties that inherit shares with voting rights.

The reporting obligation is not applicable:

• To a change of ownership of shares with voting rights that occurs as a result of corporate actions conducted by public companies (a) in the form of a capital increase either with or without the granting of pre-emptive rights or (b) without any transactions undertaken by shareholders.
• To a change in the decimal places only in the percentage of ownership of shares with voting rights (that is, it does not apply to a change of ownership percentage from 6.1% to 6.99%, but would apply to a change from 6.1% to 7%).
• To holders of shares with no voting rights.

OJK Rule 4/2024 provides a template to report shareholdings to the OJK. The report must include the following details, among others:

• Name, address and nationality of the reporting party.
• Name of the public company.
• Number and percentage of shares with voting rights, both before and after the transaction.
• Type of transaction (for instance, inheritance or grant).
• Number of shares transacted.
• Classification of shares.
• Sale or purchase price.
• Date of transaction.
• Purpose of transaction.
• Status of ownership (for instance, direct or indirect).
• Information whether the shareholder acts for the interest of its beneficial owners, if there is an indirect share ownership.
• Information on the composition and details of members within an organized group, if the report concerns share ownership by such organized group.

Insider trading

Insider trading, fraud and market manipulation of securities are prohibited under Indonesian capital markets laws. Any transaction found to have involved insider trading, fraud or market manipulation may be cancelled or suspended by the IDX, or the OJK may suspend or revoke the license of the capital market supporting institutions and supporting professionals involved. A party that (i) engages in conduct that could affect other parties' decisions on whether or not  to purchase or sell the securities in question, or (ii) provides any insider information to any party who reasonably could use such information to purchase or sell the securities, is liable for the loss incurred and faces a fine of up to IDR 150 billion (approximately US$9 million) and imprisonment for up to 15 years.