INTRODUCTION

The Ministry of Law has introduced a new electronic filing requirement for annual reports of Indonesian limited liability companies (“PT”) through the Legal Entity Administration System (Sistem Administrasi Badan Hukum or "SABH"), effective 1 June 2026.

While the obligation to prepare an annual report is not new, the practical consequence now is far more significant: annual report compliance may directly affect a company’s ability to process certain corporate actions through SABH. For companies planning board changes, shareholder updates, share transfers, or restructuring transactions, this is no longer merely an internal compliance matter — it is a filing readiness issue that can impact deal execution and corporate timelines.

INTRODUCTION

On 30 April 2026, just ahead of May Day, the Minister of Manpower enacted Minister of Manpower Regulation No. 7 of 2026 on Outsourcing (“MOM Regulation 7/2026”). The regulation was introduced as a direct response to Constitutional Court Decision No. 168/PUU-XXI/2023, which required the government to clearly define the scope of permissible outsourcing activities following the removal of Article 65 of Law No. 13 of 2003 on Manpower under the Job Creation framework.

CONCLUSION

MOM Regulation 7/2026 represents a major regulatory shift in Indonesia’s outsourcing regime. By narrowing the scope of permissible outsourced activities and introducing broader accountability obligations, the government has signaled a more stringent approach toward outsourcing compliance and worker protection.

While the regulation provides greater clarity in certain areas, significant interpretative and operational risks remain, particularly regarding the broad classification of “operational support services.”

Businesses should therefore move beyond formal job classifications and undertake a substantive review of their outsourcing practices, operational structures, and contractual arrangements. Companies that proactively utilize the transition period to realign their outsourcing models will likely be better positioned to maintain operational continuity while minimizing regulatory and commercial risks.

Regards, 

Pasaka Rievan Smith
Counsellors at Law 

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INTRODUCTION

On 5 December 2025, the Financial Services Authority (Otoritas Jasa Keuangan or “OJK”) issued OJK Regulation No. 32 of 2025 on the Implementation of Buy Now Pay Later (“OJK Reg 32/2025”), which entered into force on 15 December 2025.

This regulation establishes a comprehensive legal framework governing Buy Now Pay Later (“BNPL”) services in Indonesia. Its issuance reflects OJK’s response to the growth of digital financing technology, and the need for a regulation to ensure the implementation of BNPL in the financial services sector is conducted with due regard to prudential, consumer protection, and good governance principals.

CONCLUSION

OJK Reg 32/2025 marks a significant development in Indonesia’s digital financing regulation. By clearly embedding BNPL as a regulated product, OJK has reinforced oversight, improved transparency standards, and enhanced consumer protection safeguards.

For Commercial Banks, Financing Companies, and digital platform partners, this regulation signals a more structured regulatory environment. Timely compliance alignment and strategic reassessment of BNPL frameworks will be essential to ensure continued operation within Indonesia’s evolving financial regulatory framework.

Regards,

Pasaka Rievan Smith 
Counsellors at Law

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