Electronic Licensing, Approval, and Reporting for Pawnshop and Sharia Pawnshop Companies

To:

1. The Board of Directors of Pawnshop Companies; and
2. The Board of Directors of Sharia Pawnshop Companies,
   At their respective locations.

COPY

CIRCULAR LETTER OF THE FINANCIAL SERVICES AUTHORITY REPUBLIC OF INDONESIA NUMBER 30/SEOJK.06/2025

CONCERNING

ELECTRONIC LICENSING, APPROVAL, AND REPORTING
FOR PAWNSHOP AND SHARIA PAWNSHOP COMPANIES

In accordance with the mandate of Article 11 paragraph (9) and Article 226 paragraph (5) of Financial Services Authority Regulation Number 39 of 2024 concerning Pawnshops (State Gazette of the Republic of Indonesia Year 2024 Number 52/OJK, Supplement to the State Gazette of the Republic of Indonesia Number 120/OJK), it is necessary to regulate business licensing, institutional matters, and the submission of reports by pawnshop and Sharia pawnshop companies in this Financial Services Authority Circular Letter as follows:

I. GENERAL PROVISIONS

In this Financial Services Authority Circular Letter, the following terms are defined:

1. Pawnshop Company is a legal entity that conducts conventional business activities of providing loans secured by movable property.
2. Sharia Pawnshop Company is a legal entity that conducts all business activities of providing loans secured by movable property based on Sharia principles.
3. Company refers to Pawnshop Companies and Sharia Pawnshop Companies.
4. Sharia Principles are Islamic legal principles based on fatwas and/or Sharia compliance statements issued by institutions having authority in setting fatwas in the Sharia field.
5. Sharia Business Unit, hereinafter abbreviated as UUS, is a work unit of the Head Office of a Pawnshop Company that carries out part of its business activities based on Sharia Principles and/or functions as the head office of offices conducting business based on Sharia Principles.
6. Controlling Shareholder, hereinafter abbreviated as PSP, is a legal entity, individual, and/or business group that directly or indirectly holds shares or shares equivalent to shares in the Company and/or has the ability to exercise control over the said Company.
7. General Meeting of Shareholders, hereinafter abbreviated as RUPS, is a corporate organ that has authority not granted to the Board of Directors or Board of Commissioners within the limits determined by laws regulating limited liability companies and/or the articles of association for companies in the form of limited liability companies or equivalent for companies in the form of cooperatives.
8. Board of Directors is the Company organ authorized and fully responsible for the management of the Company for the benefit of the Company, in accordance with the Company's purpose and objectives, and represents the Company, both inside and outside of court, in accordance with the provisions of the articles of association for companies in the form of limited liability companies or equivalent to the Board of Directors for companies in the form of cooperative legal entities.
9. Board of Commissioners is the Company organ tasked with conducting general and/or specific supervision in accordance with the articles of association and providing advice to the Board of Directors for companies in the form of limited liability companies or equivalent to the Board of Commissioners for companies in the form of cooperative legal entities.
10. Sharia Supervisory Board, hereinafter abbreviated as DPS, is a party having the task and function of supervising the implementation of the Company's activities to ensure compliance with Sharia Principles.
11. Paid-up Capital is paid-up capital as referred to in laws regarding limited liability companies for Companies in the form of limited liability legal entities or the sum of basic savings, mandatory savings, and donations as referred to in legislation regarding cooperatives for Companies in the form of cooperative legal entities.
12. Equity is equity based on applicable financial accounting standards in Indonesia.
13. Merger is a legal act performed by one (1) or more Company(ies) to merge with an existing Company, resulting in the assets, liabilities, and Equity of the merging Company transferring by operation of law to the receiving Company, and subsequently the legal status of the merging Company ends by operation of law.
14. Consolidation is a legal act performed by two (2) or more Company(ies) to consolidate by establishing one (1) new Company, which by operation of law acquires the assets, liabilities, and Equity of the consolidating Company, and the legal status of the consolidating Company ends by operation of law.
15. Separation is a legal act performed by a Company to separate business operations, resulting in all assets, liabilities, and Equity of the Company transferring by operation of law to two (2) or more Company(ies) or part of the assets, liabilities, and Equity of the Company transferring by operation of law to one (1) or more Company(ies).
16. Pawn is a right obtained by the Company over a movable property, which is handed over to it by the customer or their proxy, as security for their loan, and which gives the Company the authority to take loan repayment from that property prior to other creditors, with the exception of costs for auctioning or selling the property and costs for preserving the property incurred after the property was handed over as pawn, which costs must be prioritized.
17. Collateral Property is any movable property pledged by the customer to the Company.
18. Appraiser is a person holding certification in the field of appraisal from an appraiser certification body registered with the Financial Services Authority.
19. Pawn Certificate is a document evidencing a loan agreement with Collateral Property based on Pawn law, signed by the Company and the customer.
20. Customer is an individual or business entity that receives a Loan with Collateral Property and/or utilizes other services available at the Company.
21. Branch Office is an office other than the Company's Head Office that has the authority to grant approval and sign the Company's business activity agreements.

II. SCOPE OF ELECTRONIC LICENSING, APPROVAL, AND REPORTING REQUESTS

1. Requests for licensing, approval, and reporting as regulated in Financial Services Authority Regulation Number 39 of 2024 concerning Pawnshops, submitted to the Financial Services Authority, are grouped as follows:
   a. licensing requests; b. approval requests; and
   c. reporting.

2. Licensing requests as referred to in item 1 letter a include requests for:
   a. Company business license; b. license for conversion of a Pawnshop Company into a Sharia Pawnshop Company;
   c. license for the establishment of a UUS;
   d. license for the establishment of a UUS for a Company receiving a Merger; and e. license for the establishment of a UUS for a Company resulting from a Consolidation.

3. Approval requests as referred to in item 1 letter b include requests for:
   a. approval for the separation plan of a UUS based on self-request; b. approval for the closure of a UUS;
   c. approval for the use of foreign workers;
   d. approval for ownership changes; e. approval for Merger or Consolidation; f. approval for changes in business area scope; g. approval for association; h. approval for revocation of business license based on self-request;
   i. approval for other business activities; and
   j. approval for other agreements.

4. Reporting as referred to in item 1 letter c includes reporting on:
   a. changes in UUS leadership; b. implementation of business activities of Pawnshop Companies and Sharia Pawnshop Companies;
   c. implementation of RUPS approving the conversion of a Pawnshop Company into a Sharia Pawnshop Company;
   d. implementation of conversion by the converted Pawnshop Company; e. UUS separation plans meeting certain criteria; f. UUS separation plans ordered by the Financial Services Authority; g. implementation of RUPS approving UUS separation; h. implementation of UUS separation;
   i. cessation of UUS business activities;
   j. changes to specific articles of association; k. opening of Branch Offices;
   l. changes to the address of the Head Office and Branch Offices;
   m. closure of Branch Offices; n. implementation of RUPS approving ownership changes; o. implementation of ownership changes; p. determination of business area scope resulting from expansion; q. changes to members of the Board of Directors, members of the Board of Commissioners, and/or members of the DPS; r. implementation of RUPS approving Merger or Consolidation; s. implementation of Merger; t. implementation of Consolidation; u. realization of changes in business area scope;
   v. changes in management, articles of association, and/or house rules, code of ethics, and/or association work programs;
   w. determination of PSP;
   x. determination or changes to beneficial owners;
   y. business activities utilizing information technology; z. activities providing income based on commissions; and aa. implementation of obligations after approval for revocation of business license.

III. PROCEDURE FOR SUBMISSION AND REQUIREMENTS FOR ELECTRONIC LICENSING, APPROVAL, AND REPORTING REQUESTS

1. Companies are required to submit requests for licensing, approval, and reporting to the Financial Services Authority in accordance with the requirements stipulated in Financial Services Authority Regulation Number 39 of 2024 concerning Pawnshops and accompanied by required supporting documents.

2. Submission of requests for licensing, approval, and reporting as referred to in item 1 is submitted by the Company to the Financial Services Authority online via the Financial Services Authority's data communication network system.

3. Submission of requests for licensing, approval, and reporting as referred to in item 1 is accompanied by a self-assessment form signed by the Company's Board of Directors after being verified by a different official/Board of Directors member, evidenced by initials on each page of the self-assessment form and next to the Company's Board of Directors' signature, as stated in the Appendix which is an integral part of this Financial Services Authority Circular Letter.

4. In the event that:
   a. the Financial Services Authority's data communication network system as referred to in item 2 is not yet available; and/or b. the Financial Services Authority's data communication network system and/or the Company experiences technical disturbances or force majeure, the Company submits requests for licensing, approval, and reporting online in the form of electronic documents via the email address determined by the Financial Services Authority.

5. With the submission of requests for licensing, approval, and reporting to the Financial Services Authority online as referred to in item 4, the Company does not need to submit printed documents.

6. Documents for licensing, approval, and reporting requests submitted online are color scans of the original documents.

7. In the event that the Financial Services Authority's data communication network system is not available, or technical disturbances or force majeure occur as referred to in item 4, the Financial Services Authority issues notifications or announcements on the Financial Services Authority website and/or via email to the Company.

8. Force majeure as referred to in item 4 letter b includes, among others, fire, mass riots, war, armed conflict, sabotage, pandemic, cyber attacks, as well as natural disasters, non-natural disasters, and/or social disasters that disrupt the Company's operational activities, which can be evidenced by a statement from the competent official of the relevant agency.

9. The Company must declare that documents submitted online or via email are true and identical to the original documents.

10. Submission of requests for licensing, approval, and reporting in the form of electronic documents via email as referred to in item 4 is submitted via the address mailingroomwismul@ojk.go.id or other addresses established by the Financial Services Authority and addressed to:
    Executive Head of Supervision for Financing Institutions, Venture Capital Companies, Microfinance Institutions, and Other Financial Service Institutions u.p. Director of Licensing for Financing Institutions, Venture Capital Companies, Microfinance Institutions, and Other Financial Service Institutions; or via Financial Services Authority Offices according to the Company's domicile.

11. In the event that the email address determined by the Financial Services Authority as referred to in item 4 experiences technical disturbances, the Company submits requests for licensing, approval, and reporting offline in the form of electronic documents using electronic data storage media sent offline to the Financial Services Authority via a letter signed by the Board of Directors and addressed to:
    Financial Services Authority u.p. Director of Licensing for Financing Institutions, Venture Capital Companies, Microfinance Institutions, and Other Financial Service Institutions; or via Financial Services Authority Offices according to the Company's domicile.

12. Submission of requests for licensing, approval, and reporting offline as referred to in item 11 is done as follows:
    a. handed in directly; or b. sent via a courier service company, to the Financial Services Authority office, according to the address as referred to in item 10.

13. In the event of a change in the address of the Financial Services Authority office for the submission of requests for licensing, approval, and reporting as referred to in item 11, the Financial Services Authority issues notifications or announcements regarding the address change on the Financial Services Authority website and/or via email to the Company.

14. The Company is deemed to have submitted requests for licensing, approval, and reporting with the following provisions:
    a. for online submission via:

1. the Financial Services Authority's data communication network system, evidenced by a receipt from the Financial Services Authority's data communication network system; or
2. email to the Financial Services Authority, evidenced by proof of email transmission and/or receipt from the Financial Services Authority's email, in the event that submission via the Financial Services Authority's data communication network system is not yet available, experiences technical disturbances, or force majeure occurs; or
   b. for offline submission in the form of electronic documents using electronic data storage media, evidenced by a receipt from the Financial Services Authority.

IV. DOCUMENT STORAGE

1. Companies are required to store printed documents of licensing and approval documents that have been submitted via the Financial Services Authority's data communication network system or via email to the Financial Services Authority for as long as such licensing and approval remain valid.

2. Storage of printed documents of reporting documents that have been submitted via the Financial Services Authority's data communication network system or via email to the Financial Services Authority by the Company is done for a period in accordance with the provisions of legislation.

3. The Financial Services Authority may conduct verification and/or validation of the truthfulness and reasonableness of printed documents as referred to in item 1 and/or item 2.

4. Companies must provide printed documents as referred to in item 1 and/or item 2 to the Financial Services Authority during the implementation of verification and/or validation by the Financial Services Authority.

This copy is consistent with the original
Head of Legal Development Directorate
Legal Department signed.
Aat Windradi

V. CLOSING

1. At the time this Financial Services Authority Circular Letter takes effect, Financial Services Authority Circular Letter Number 51/SEOJK.05/2017 concerning Registration, Business Licensing, and Institutional Matters of Pawnshop Companies is revoked and declared invalid.

2. The provisions in this Financial Services Authority Circular Letter take effect on the date of establishment.

Established in Jakarta on 26 November 2025

EXECUTIVE HEAD OF SUPERVISION FOR FINANCING INSTITUTIONS, VENTURE CAPITAL COMPANIES, MICROFINANCE INSTITUTIONS, AND OTHER FINANCIAL SERVICE INSTITUTIONS FINANCIAL SERVICES AUTHORITY REPUBLIC OF INDONESIA,

AGUSMAN signed.

APPENDIX
CIRCULAR LETTER OF THE FINANCIAL SERVICES AUTHORITY REPUBLIC OF INDONESIA NUMBER 30/SEOJK.06/2025 CONCERNING ELECTRONIC LICENSING, APPROVAL, AND REPORTING FOR PAWNSHOP AND SHARIA PAWNSHOP COMPANIES

FORM 1: SELF-ASSESSMENT FORM FOR COMPANY BUSINESS LICENSE REQUEST SELF-ASSESSMENT FORM COMPANY BUSINESS LICENSE REQUEST

Company Name :
Request Letter Number :
Request Letter Date :
Brief Description of
Activities Conducted :
Contact Person (Name, Phone/email) :

Article 10 of Financial Services Authority Regulation Number 39 of 2024 concerning Pawnshops
NO. DESCRIPTION YES NO LEGAL BASIS NOTES

1. Is the request letter signed by the Board of Directors?
   Name of signatory: ...
2. Has the request attached a photocopy of proof of payment of OJK levies related to the business license?
   Government Regulation regarding the work plan and budget of the Financial Services Authority and levies in the Financial Services Sector Proof of payment includes reference number and payment date
3. Has the request attached a copy of the Deed of Establishment of the Legal Entity approved by the competent authority?
   Article 10 of Financial Services Authority Regulation Number 39 of 2024 concerning Pawnshops (POJK 39/2024)
   Deed Number:
   Deed Date:
   Ministry of Law and Human Rights Approval Number: Ministry of Law and Human Rights Approval Date:
4. Does the company name meet the provisions regarding Names as referred to in Article 8 of POJK 39/2024?
5. Does the deed of establishment contain a description of capital?
   Article:
   Authorized Capital:
   Paid-up Capital:
6. Does the minimum paid-up capital amount comply with the provisions of Article 6 of POJK 39/2024?
7. Has the request attached a copy of the latest deed of amendment to the articles of association accompanied by proof of approval, proof of consent, and/or letter of acceptance of notification from the competent authority?
   ?
   Number of last Articles of Association amendment (If any):
   Date of last Articles of Association amendment (If any) Ministry of Law and Human Rights Approval Number: Ministry of Law and Human Rights Approval Date: Ministry of Law and Human Rights Approval Date:
   For Pawnshop Companies intending to conduct business activities based on Sharia Principles, the articles of association must state:
8. One of the purposes and objectives of the company is to conduct business activities based on Sharia principles; and
9. Authority and responsibility of the DPS.
10. Does the deed of establishment contain a description of share ownership?
    Article:
    Shareholder structure and composition:
11. Is there foreign ownership, either directly or indirectly?
12. Does the deed of establishment contain a description of the authority, responsibility, and term of office of Board of Directors members, Board of Commissioners members, and/or DPS members?
    Article:
    Description of authority, responsibility, and term of office of Board of Directors members, Board of Commissioners members, and/or DPS members
13. Has the request attached a list of shareholders including details of each share ownership up to the last shareholder and/or beneficial owner, and a list of other companies owned by the shareholders?
    If there is no information up to the last shareholder, describe the reason.
14. Has the request attached a statement letter from the Company's Board of Directors signed on stamped paper stating who the beneficial owner of the said company is?
    Based on legislation regulating the application of the beneficial owner principle in the context of prevention and eradication of money laundering and terrorism financing crimes and prevention of proliferation financing of weapons of mass destruction in the Financial Services Sector, every corporation is required to submit beneficial owner data on the General Legal Administration (AHU) online System managed by the Ministry of Law and Human Rights. Information regarding the Company's beneficial owner/BO is taken from reports submitted to the AHU online System. Describe the brief profile of the beneficial owner/BO and the form of control of the beneficial owner/BO over the Company.
15. Has the request attached a statement letter from the Company's shareholders or founding members signed on stamped paper stating that:
    a. the source of investment funds does not come from loans; and b. the source of investment funds does not come from money laundering, terrorism financing, proliferation financing of weapons of mass destruction, and other financial crimes, accompanied by an explanation of the flow of capital deposits of shareholders or founding members.
16. Has the request attached Shareholder Data other than Controlling Shareholders or founding members, namely:
    Data submitted is for shareholders with ownership of less than 25%.
    Shareholder Name: … a. copy of the deed of establishment of the legal entity, including the articles of association including amendments to the articles of association regarding business activities, capital, shareholder structure, and management, accompanied by proof of approval, proof of consent, recording, and/or letter of acceptance of notification from the competent authority; (Only for shareholders in the form of Limited Liability Companies) ; Deed Title:
    Deed Number:
    Deed Date:
    Name and Domicile of the Notary Making the Deed:
    Content of Consent in the Deed:
    Number of letter of acceptance of notification from the competent authority:
    Date of letter of acceptance of notification from the competent authority:
    b. financial reports audited by public accountants and the latest non-consolidated financial reports before capital deposit, signed by the directors or equivalent of the shareholder; (Only for shareholders in the form of Limited Liability Companies) ; Audit Report of PT … year … Non-consolidated Report of PT … month … Include explanation regarding which assets are in the latest monthly financial report (before capital deposit) used to make capital deposits to the Company.
    c. photocopy of identification cards in the form of ID cards or valid passports; (Applies to individual shareholders.
    Name: ID Number:
    For shareholders in the form of Limited Liability Companies, attach photocopy of identification for all Directors listed in the latest articles of association ; d. photocopy of tax identification numbers; (Applies to individual shareholders. For shareholders in the form of Limited Liability Companies, include Corporate Tax Identification Number and Director Tax Identification Number) ; Name:
    Tax ID:
    Issued on date:
    e. photocopy of tax notification letter for 1 (one) year prior to the investment and other documents showing

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