Implementation of Risk Management for Insurance Companies, Guarantee Institutions, and Pension Funds

FINANCIAL SERVICES AUTHORITY REGULATION
OF THE REPUBLIC OF INDONESIA
NUMBER 28 OF 2025
CONCERNING
THE IMPLEMENTATION OF RISK MANAGEMENT FOR INSURANCE COMPANIES, GUARANTEE INSTITUTIONS, AND PENSION FUNDS BY THE GRACE OF GOD THE ALMIGHTY

THE COMMISSIONERS OF THE FINANCIAL SERVICES AUTHORITY,

Considering:
a. that the development of insurance companies, guarantee institutions, and pension funds requires the implementation of adequate, effective, and measurable risk management; b. that the implementation of risk management for guarantee institutions is not yet regulated in Financial Services Authority Regulation Number 44/POJK.05/2020 concerning the Implementation of Risk Management for Non-Bank Financial Service Institutions, so it is necessary to regulate again the provisions regarding the implementation of risk management for insurance companies, guarantee institutions, and pension funds;
c. that based on considerations as referred to in letters a and b, and to implement the provisions of Article 11 paragraph (5) of Law Number 40 of 2014 concerning Insurance as amended by Law Number 4 of 2023 concerning Development and Strengthening of the Financial Sector, as well as Article 143 paragraph (4) and Article 269 of Law Number 4 of 2023 concerning Development and Strengthening of the Financial Sector, it is necessary to establish a Financial Services Authority Regulation concerning the Implementation of Risk Management for Insurance Companies, Guarantee Institutions, and Pension Funds;

Recalling:

1. Law Number 21 of 2011 concerning the Financial Services Authority (State Gazette of the Republic of Indonesia Year 2011 Number 111, Supplement to the State Gazette of the Republic of Indonesia Number 5253) as amended by Law Number 4 of 2023 concerning Development and Strengthening of the Financial Sector (State Gazette of the Republic of Indonesia Year 2023 Number 4, Supplement to the State Gazette of the Republic of Indonesia Number 6845);

2. Law Number 40 of 2014 concerning Insurance (State Gazette of the Republic of Indonesia Year 2014 Number 337, Supplement to the State Gazette of the Republic of Indonesia Number 5618) as amended by Law Number 4 of 2023 concerning Development and Strengthening of the Financial Sector (State Gazette of the Republic of Indonesia Year 2023 Number 4, Supplement to the State Gazette of the Republic of Indonesia Number 6845);

3. Law Number 1 of 2016 concerning Guarantee (State Gazette of the Republic of Indonesia Year 2016 Number 9, Supplement to the State Gazette of the Republic of Indonesia Number 5835) as amended by Law Number 4 of 2023 concerning Development and Strengthening of the Financial Sector (State Gazette of the Republic of Indonesia Year 2023 Number 4, Supplement to the State Gazette of the Republic of Indonesia Number 6845);

4. Law Number 4 of 2023 concerning Development and Strengthening of the Financial Sector (State Gazette of the Republic of Indonesia Year 2023 Number 4, Supplement to the State Gazette of the Republic of Indonesia Number 6845);

DECIDING TO:
Establish: A FINANCIAL SERVICES AUTHORITY REGULATION CONCERNING THE IMPLEMENTATION OF RISK MANAGEMENT FOR INSURANCE COMPANIES, GUARANTEE INSTITUTIONS, AND PENSION FUNDS.

CHAPTER I
GENERAL PROVISIONS

Article 1
In this Financial Services Authority Regulation, the following terms are defined as:

1. Insurance Companies, Guarantee Institutions, and Pension Funds, hereinafter referred to as PPDP, are financial service institutions that carry out activities in the insurance, guarantee, and pension fund sectors.
2. Risk is the potential loss that cannot be controlled and/or can be controlled due to the occurrence of a certain event.
3. Risk Management is a series of procedures and methodologies used to identify, measure, monitor, and control Risks arising from all business activities of PPDP.
4. Strategic Risk is Risk due to inaccuracies in making and/or implementing strategic decisions and failures in anticipating changes in the business environment.
5. Operational Risk is Risk due to inadequacy and/or malfunction of internal processes, human error, system failure, and/or external events affecting the operations of PPDP.
6. Insurance Risk is the Risk of failure of insurance companies, reinsurance companies, Islamic insurance companies, and Islamic reinsurance companies to meet obligations to policyholders, insured parties, or participants due to inadequate risk selection (underwriting) processes, premium or contribution setting, use of reinsurance, and/or claims handling.
7. Credit Risk is Risk due to the failure of other parties to meet obligations to PPDP.
8. Guarantee Risk is the Risk of failure of guarantee institutions to meet obligations to guarantee recipients due to inadequate guarantee feasibility analysis processes, inadequate setting of guarantee remuneration, failure of co-guarantors or reinsurers to meet their obligations, inadequate claim reserves, and/or inadequate subrogation handling.
9. Market Risk is Risk on asset, liability, equity, and/or administrative account positions, including derivative transactions, due to overall changes in market conditions.
10. Liquidity Risk is Risk due to the inability of PPDP to meet maturing liabilities from cash flow funding sources and/or from liquid assets that can be easily converted into cash, without disrupting the activities and financial condition of PPDP.
11. Legal Risk is Risk arising from lawsuits or legal claims and/or weaknesses in legal aspects.
12. Compliance Risk is Risk due to PPDP not complying with and/or not implementing applicable laws and regulations and provisions applicable to PPDP.
13. Reputational Risk is Risk due to a decrease in stakeholder trust stemming from negative perceptions of PPDP.
14. Board of Directors is the company organ authorized and fully responsible for managing the company for the benefit of the company, in accordance with the purpose and object of the company and representing the company, both inside and outside court, in accordance with the articles of association for PPDP in the form of a limited liability company, or equivalent to the board of directors for PPDP in the form of a cooperative, joint venture, pension fund, and state-owned enterprise.
15. 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 PPDP in the form of a limited liability company, or equivalent to the board of commissioners for PPDP in the form of a cooperative, joint venture, pension fund, and state-owned enterprise.
16. Sharia Supervisory Board is the party having the task and function of supervising the implementation of PPDP activities to ensure compliance with Sharia principles.
17. Sharia Principles are Islamic legal principles based on fatwas and/or statements of Sharia compliance issued by institutions having authority in determining fatwas in the field of Sharia.

Article 2
(1) This Financial Services Authority Regulation governs the implementation of Risk Management for PPDP.
(2) PPDP as referred to in paragraph (1) includes:
a. insurance companies, consisting of:
1. insurance companies, including those conducting part of their business based on Sharia Principles;
2. reinsurance companies, including those conducting part of their business based on Sharia Principles;
3. Islamic insurance companies;
4. Islamic reinsurance companies;
5. insurance brokerage companies;
6. reinsurance brokerage companies; and
7. insurance loss assessor companies, as referred to in provisions of legislation concerning insurance;
b. guarantee institutions, consisting of:
1. guarantee companies, including those conducting part of their business based on Sharia Principles;
2. reinsurance guarantee companies;
3. Islamic guarantee companies; and
4. Islamic reinsurance guarantee companies, as referred to in provisions of legislation concerning guarantees; and
c. pension funds as referred to in provisions of legislation concerning pension funds, including those conducting all or part of their business based on Sharia Principles.

CHAPTER II
IMPLEMENTATION OF RISK MANAGEMENT
First Section
General

Article 3
(1) PPDP must implement Risk Management effectively.
(2) The implementation of Risk Management as referred to in paragraph (1) must at least include:
a. active supervision by the Board of Directors, Board of Commissioners, and Sharia Supervisory Board; b. adequacy of Risk Management policies and procedures as well as the establishment of Risk limits;
c. adequacy of the process for identifying, measuring, monitoring, and controlling Risk, as well as the Risk Management information system; and
d. a comprehensive internal control system.
(3) In implementing Risk Management as referred to in paragraph (1), PPDP must have guidelines for the implementation of Risk Management.
(4) Provisions regarding the implementation of Risk Management as referred to in paragraph (1) are established by the Financial Services Authority.

Article 4
The implementation of Risk Management as referred to in Article 3 must be adjusted to the objectives, business policies, size, business complexity, and capabilities of PPDP.

Article 5
(1) Insurance companies, reinsurance companies, Islamic insurance companies, and Islamic reinsurance companies as referred to in Article 2 paragraph (2) letter a numbers 1 through 4 must implement Risk Management for:
a. Strategic Risk; b. Operational Risk;
c. Insurance Risk;
d. Credit Risk; e. Market Risk; f. Liquidity Risk; g. Legal Risk; h. Compliance Risk; and
i. Reputational Risk.
(2) Insurance brokerage companies, reinsurance brokerage companies, and insurance loss assessor companies as referred to in Article 2 paragraph (2) letter a numbers 5 through 7 must implement Risk Management for:
a. Strategic Risk; b. Operational Risk;
c. Legal Risk;
d. Compliance Risk; and e. Reputational Risk.
(3) Guarantee companies, reinsurance guarantee companies, Islamic guarantee companies, and Islamic reinsurance guarantee companies as referred to in Article 2 paragraph (2) letter b numbers 1 through 4 must implement Risk Management for:
a. Strategic Risk; b. Operational Risk;
c. Guarantee Risk;
d. Credit Risk; e. Market Risk; f. Liquidity Risk; g. Legal Risk; h. Compliance Risk; and
i. Reputational Risk.
(4) Pension funds as referred to in Article 2 paragraph (2) letter c must implement Risk Management for:
a. Strategic Risk; b. Operational Risk;
c. Credit Risk;
d. Market Risk; e. Liquidity Risk; f. Legal Risk; g. Compliance Risk; and h. Reputational Risk.
(5) PPDP conducting part of its business based on Sharia Principles must implement Risk Management for Sharia business units.

Second Section
Active Supervision by the Board of Directors, Board of Commissioners, and Sharia Supervisory Board Paragraph 1 General

Article 6
PPDP must establish authority and responsibility at every job level related to the implementation of Risk Management as referred to in Article 3.

Paragraph 2
Authority and Responsibility of the Board of Directors

Article 7
(1) The authority and responsibility as referred to in Article 6 for the Board of Directors must at least include:
a. drafting and establishing written and comprehensive Risk Management policies and strategies; b. being responsible for the implementation of Risk Management policies and the Risk exposure taken by PPDP as a whole;
c. evaluating and deciding on transactions and Risk limits requiring Board of Directors approval;
d. developing a Risk Management culture throughout all levels of the organization; e. ensuring the improvement of competence of human resources related to Risk Management; f. ensuring that the Risk Management function operates independently; and g. carrying out periodic reviews to ensure:
1. the accuracy of Risk assessment methodologies;
2. the adequacy of the implementation of the Risk Management information system; and
3. the appropriateness of Risk Management policies and procedures as well as the establishment of Risk limits.
(2) The responsibility of the Board of Directors for the implementation of Risk Management policies as referred to in paragraph (1) letter b includes:
a. evaluating and providing direction based on reports submitted by the Risk Management function; and b. submitting accountability reports to the Board of Commissioners and/or the Sharia Supervisory Board at least once within a period of 6 (six) months. (3) To execute the authority and responsibility as referred to in paragraph (1), the Board of Directors must have an understanding of the Risks inherent in all functional activities of PPDP and be able to take necessary actions according to the Risk profile of PPDP.

Paragraph 3
Authority and Responsibility of the Board of Commissioners

Article 8
(1) The authority and responsibility as referred to in Article 6 for the Board of Commissioners must at least include:
a. approving and evaluating Risk Management policies; b. evaluating the accountability of the Board of Directors for the implementation of Risk Management policies as referred to in letter a; and
c. evaluating and deciding on requests from the Board of Directors related to transactions and Risk limits requiring Board of Commissioners approval.
(2) The evaluation of Risk Management policies as referred to in paragraph (1) letter a must be conducted at least once within a period of 1 (one) year. (3) The evaluation of the accountability of the Board of Directors for the implementation of Risk Management policies as referred to in paragraph (1) letter b must be conducted at least once within a period of 6 (six) months.

Paragraph 4
Authority and Responsibility of the Sharia Supervisory Board

Article 9
(1) The authority and responsibility as referred to in Article 6 for the Sharia Supervisory Board must at least include:
a. evaluating Risk Management policies related to the fulfillment of Sharia Principles; and b. evaluating the accountability of the Board of Directors for the implementation of Risk Management policies related to the fulfillment of Sharia Principles as referred to in letter a. (2) The evaluation of Risk Management policies as referred to in paragraph (1) letter a must be conducted at least once within a period of 1 (one) year. (3) The evaluation of the accountability of the Board of Directors for the implementation of Risk Management policies related to the fulfillment of Sharia Principles as referred to in paragraph (1) letter b must be conducted at least once within a period of 6 (six) months.

Third Section
Adequacy of Risk Management Policies and Procedures as well as Establishment of Risk Limits Paragraph 1 Risk Management Policy

Article 10
Risk Management policies as referred to in Article 3 paragraph (2) letter b must at least contain:
a. the determination of Risks related to the business activities of PPDP; b. the determination of the use of measurement methods and the Risk Management information system;
c. the determination of the level of Risk to be taken, the determination of Risk tolerance, and the determination of Risk limits;
d. the determination of Risk rating assessments; e. the preparation of contingency plans in worst-case scenarios; and f. the determination of the internal control system in the implementation of Risk Management.

Paragraph 2
Risk Management Procedures and Establishment of Risk Limits

Article 11
(1) Risk Management procedures and the establishment of Risk limits as referred to in Article 3 paragraph (2) letter b must be adjusted to the level of Risk to be taken against PPDP's Risks. (2) Risk Management procedures and the establishment of Risk limits as referred to in paragraph (1) must at least include:
a. clear accountability and levels of delegation of authority; b. the execution of periodic reviews of Risk Management procedures and the establishment of Risk limits at least once within a period of 1 (one) year; and
c. adequate documentation of Risk Management procedures and the establishment of Risk limits.
(3) The establishment of Risk limits as referred to in paragraph (2) must cover:
a. overall limits; b. limits per type of Risk; and
c. limits per functional activity and specific transactions having Risk exposure.

Fourth Section
Adequacy of the Process for Identifying, Measuring, Monitoring, and Controlling Risk, as well as the Risk Management Information System Paragraph 1 General

Article 12
(1) PPDP must conduct the process of identifying, measuring, monitoring, and controlling Risk as referred to in Article 3 paragraph (2) letter c against material Risk factors. (2) The execution of the process of identifying, measuring, monitoring, and controlling Risk as referred to in paragraph (1) must be supported by:
a. reliable and timely management information systems; b. accurate and informative reports regarding the financial condition, performance of functional activities, and Risk exposure of PPDP; and
c. human resources possessing competence in the field of Risk Management.

Paragraph 2
Process for Identifying, Measuring, Monitoring, and Controlling Risk

Article 13
(1) To execute the Risk identification process, PPDP must conduct analysis at least against:
a. the characteristics of Risks inherent in PPDP; and b. Risks from the business activities of PPDP.
(2) To execute Risk measurement, PPDP must conduct at least:
a. periodic evaluations at least once within a period of 1 (one) year, regarding the suitability of assumptions, data sources, and procedures used to measure Risk; and b. adjustments to the Risk measurement process in the event of changes in the business activities of PPDP and material Risk factors. (3) To execute Risk monitoring, PPDP must conduct at least:
a. evaluations of Risk exposure; and b. adjustments to the reporting process regarding material changes to:
1. business activities;
2. Risk factors;
3. information technology; and
4. the Risk Management information system of PPDP.
(4) PPDP must execute the Risk control process to manage specific Risks that endanger the continuity of the business of PPDP.

Paragraph 3
Risk Management Information System

Article 14
(1) The Risk Management information system as referred to in Article 3 paragraph (2) letter c must be supported by human resources possessing competence in the field of Risk Management information systems. (2) The Risk Management information system as referred to in Article 3 paragraph (2) letter c must include reports or information at least regarding:
a. Risk exposure; b. compliance with Risk Management policies and procedures as well as the establishment of Risk limits as referred to in Article 10 and Article 11; and
c. the realization of Risk Management implementation compared to established targets.
(3) Reports or information as referred to in paragraph (2) must be submitted periodically to the Board of Directors.

Fifth Section
Internal Control System
Paragraph 1
General

Article 15
PPDP must implement an internal control system effectively against Risks inherent in the execution of business activities and operations at all levels of the organization of PPDP.

Article 16
(1) The implementation of the internal control system as referred to in Article 15 must at least be able to detect weaknesses and deviations causing or influencing Risk exposure in a timely manner. (2) The internal control system as referred to in paragraph (1) must ensure:
a. compliance of PPDP management levels with provisions of laws and regulations, Risk Management policies and procedures, and internal policies or provisions of PPDP; b. compliance and effectiveness of the Risk Management function in designing and implementing Risk Management strategies and policies;
c. the availability of complete, accurate, relevant, and timely financial and management information;
d. effectiveness and efficiency in business and operational activities; and e. the effectiveness of the Risk culture throughout the PPDP organization.

Paragraph 2
Internal Control System in the Implementation of Risk Management

Article 17
(1) The comprehensive internal control system as referred to in Article 3 paragraph (2) letter d in the implementation of Risk Management must at least include:
a. the suitability of the internal control system with the type and level of Risks inherent in the business activities of PPDP; b. the establishment of authority and responsibility for monitoring compliance with Risk Management policies and procedures, as well as the establishment of Risk limits as referred to in Article 10 and Article 11;
c. the establishment of clear reporting lines and separation of functions from operational functions to Risk control functions;
d. an organizational structure clearly depicting the business activities of PPDP; e. accurate and timely financial and operational activity reporting; f. adequate procedures to ensure PPDP compliance with legislative provisions and provisions applicable to PPDP; g. effective, independent, and objective review of procedures for assessing PPDP operational activities; h. adequate testing and review of the Risk Management information system;
i. complete and adequate documentation of operational procedures, scope, audit findings, and responses from the Board of Directors, Board of Commissioners, and Sharia Supervisory Board of PPDP based on audit results; and
j. periodic and continuous verification and review of the handling of material weaknesses of PPDP and actions taken by the Board of Directors, Board of Commissioners, and Sharia Supervisory Board of PPDP to correct deviations that occurred. (2) The assessment of the internal control system in the implementation of Risk Management as referred to in paragraph (1) must be conducted by the internal audit function.

Sixth Section
Administrative Sanctions

Article 18
(1) PPDP violating provisions as referred to in Article 3 paragraph (1), paragraph (3), Article 4, Article 5, Article 6, Article 11 paragraph (1), paragraph (3), Article 12, Article 13, Article 14 paragraph (1), Article 15, Article 16 paragraph (2), and/or Article 17 paragraph (2) shall be subject to administrative sanctions in the form of:

a. written warning; b. restriction of business activities in part or in whole;
c. suspension of business activities;
d. prohibition on conducting certain programs; and/or e. downgrade of health level.

(2) In the event of a violation of the provisions as referred to in paragraph (1) and the violation has been rectified, the Financial Services Authority imposes an administrative sanction in the form of a written warning that ends automatically.

(3) In the event that the PPDP has fulfilled the provisions as referred to in paragraph (1) letters a through d, the Financial Services Authority revokes the administrative sanction.

Article 19

In the event of a violation of the provisions regarding administrative sanctions as referred to in Article 18 paragraph (1), the Financial Services Authority may conduct a re-evaluation of the main party of the PPDP in accordance with the Financial Services Authority Regulation regarding re-evaluation for main parties of financial service institutions.

CHAPTER III
ORGANIZATION AND RISK MANAGEMENT FUNCTIONS

First Section
General

Article 20

(1) To implement an effective Risk Management process and system, the PPDP is required to form:
a. a Risk Management Committee; and b. a Risk Management Work Unit or Risk Management Function.

(2) The obligation to form a Risk Management Committee as referred to in paragraph (1) letter a is exempted for:
a. insurance broker companies, reinsurance broker companies, and insurance loss assessor companies with total equity less than Rp1,000,000,000,000.00 (one trillion rupiah); b. guarantee institutions with total assets less than Rp500,000,000,000.00 (five hundred billion rupiah); and
c. employer pension funds with total available assets less than Rp1,000,000,000,000.00 (one trillion rupiah).

(3) The calculation of total equity, total assets, or total available assets as referred to in paragraph (2) is determined based on the annual financial statements of the PPDP that have been audited by a public accountant.

(4) PPDPs that, based on annual financial statements audited by a public accountant, experience an increase in total equity, total assets, or total available assets are required to make adjustments to comply with the provisions as referred to in paragraph (1) based on the new total equity, total assets, or total available assets no later than 1 (one) year after the date of the annual financial statements audited by a public accountant.

Second Section
Risk Management Committee

Article 21

(1) The Risk Management Committee as referred to in Article 20 paragraph (1) letter a consists of at least:
a. half of the Board of Directors members; and b. relevant executive officials.

(2) One of the Board of Directors members as referred to in paragraph (1) letter a is a Board of Directors member who oversees the Risk Management Work Unit or Risk Management Function.

(3) The Risk Management Committee as referred to in paragraph (1) has the authority and responsibility to provide recommendations to the Chief Executive Officer or equivalent, at least containing:
a. the formulation of policies, strategies, and guidelines for the implementation of Risk Management; b. improvement or adjustment of Risk Management implementation based on the results of Risk Management implementation evaluation; and
c. the determination of matters related to business decisions that deviate from normal procedures.

(4) Provisions regarding the organizational structure of the Risk Management Committee as referred to in paragraph (1) are determined by the Financial Services Authority.

Third Section
Risk Management Work Unit or Risk Management Function

Article 22

(1) The organizational structure of the Risk Management Work Unit or Risk Management Function as referred to in Article 20 paragraph (1) letter b is adjusted to the size and complexity of the PPDP's business and the Risks inherent in the PPDP.

(2) The Risk Management Work Unit or Risk Management Function as referred to in paragraph (1) must be independent from business and operational functions as well as from internal control functions.

(3) The Risk Management Work Unit or Risk Management Function as referred to in paragraph (1) reports directly to the Chief Executive Officer or equivalent, or to a Board of Directors member who oversees the Risk Management Work Unit or Risk Management Function.

(4) The Risk Management Function as referred to in paragraph (1) may be carried out by 1 (one) or more PPDP employees.

(5) The Risk Management Work Unit or Risk Management Function has authority and responsibility including:
a. identifying Risks, including Risks inherent in the PPDP's business activities; b. formulating Risk measurement methods;
c. monitoring the implementation of the Risk Management strategy formulated by the Board of Directors;
d. monitoring the overall Risk position, per Risk type, and per functional activity type, and conducting testing using scenario/assumption of abnormal conditions and testing using historical data; e. conducting periodic reviews of the Risk Management process; f. reviewing proposals for business activity development or expansion; g. evaluating the accuracy of models and validity of data used to measure Risks, for PPDPs using models for internal purposes; h. providing recommendations to business and operational functions and/or to the Risk Management Committee, according to their respective authorities; and
i. formulating and submitting Risk Profile reports to the Chief Executive Officer or equivalent, or to the Board of Directors member who oversees the Risk Management Work Unit or Risk Management Function and the Risk Management Committee on a periodic basis.

(6) The Financial Services Authority may request the PPDP to adjust the form of the Risk Management Work Unit or Risk Management Function based on the results of the Financial Services Authority's assessment.

(7) Based on the request from the Financial Services Authority as referred to in paragraph (6), the PPDP is required to fulfill the Financial Services Authority's request.

(8) Provisions regarding the organizational structure of the Risk Management Work Unit or Risk Management Function as referred to in paragraph (1) are determined by the Financial Services Authority.

Fourth Section
Relationship Between Business and Operational Functions and Risk Management Work Unit or Risk Management Function

Article 23

(1) Business and operational functions as referred to in Article 22 paragraph (2) are required to inform the Risk Management Work Unit or Risk Management Function of inherent Risk exposures on a periodic basis.

(2) Provisions regarding the relationship between business and operational functions and the Risk Management Work Unit or Risk Management Function as referred to in paragraph (1) are determined by the Financial Services Authority.

Fifth Section
Administrative Sanctions

Article 24

(1) PPDPs that violate the provisions as referred to in Article 20 paragraph (1), paragraph (4), Article 22 paragraph (7), and/or Article 23 paragraph (1) are subject to administrative sanctions in the form of:
a. written warning; b. restriction of business activities in part or in whole;
c. suspension of business activities;
d. prohibition on conducting certain programs; and/or e. downgrade of health level.

(2) In the event of a violation of the provisions as referred to in paragraph (1) and the violation has been rectified, the Financial Services Authority imposes a written warning sanction that ends automatically.

(3) In the event that the PPDP has fulfilled the provisions as referred to in paragraph (1) letters a through d, the Financial Services Authority revokes the administrative sanction.

Article 25

In the event of a violation of the provisions regarding administrative sanctions as referred to in Article 24 paragraph (1), the Financial Services Authority may conduct a re-evaluation of the main party of the PPDP in accordance with the Financial Services Authority Regulation regarding re-evaluation for main parties of financial service institutions.

CHAPTER IV
RISK MANAGEMENT FOR BUSINESS DEVELOPMENT OR EXPANSION

First Section
General

Article 26

(1) PPDPs are required to have written policies and procedures to manage Risks inherent in the development or expansion of the PPDP's business activities.

(2) The policies and procedures as referred to in paragraph (1) must at least cover:
a. systems, procedures, and authorities in the management of business development or expansion; b. identification of all Risks inherent in business development or expansion, both related to the PPDP and consumers;
c. trial period for Risk measurement and monitoring methods regarding business development or expansion;
d. accounting information systems for business development or expansion; e. legal aspect analysis for business development or expansion; and f. transparency of information to consumers.

(3) PPDP business activities constitute a form of business development or expansion as referred to in paragraph (1) if they meet the criteria:
a. have never been conducted previously by the PPDP; or b. have been conducted previously by the PPDP but involve development that changes or increases specific Risk exposures on the PPDP.

(4) Provisions regarding the management of Risks for PPDP business development or expansion as referred to in paragraph (1) are determined by the Financial Services Authority.

Article 27

PPDPs are prohibited from assigning or approving the Board of Directors, Board of Commissioners, Sharia Supervisory Board, and/or PPDP employees to carry out activities that are not the PPDP's business activities using PPDP facilities or assets.

Second Section
Administrative Sanctions

Article 28

(1) PPDPs that violate the provisions as referred to in Article 26 paragraph (1) and/or Article 27 are subject to administrative sanctions in the form of:
a. written warning; b. restriction of business activities in part or in whole;
c. suspension of business activities;
d. prohibition on conducting certain programs; and/or e. downgrade of health level.

(2) In the event of a violation of the provisions as referred to in paragraph (1) and the violation has been rectified, the Financial Services Authority imposes a written warning sanction that ends automatically.

(3) In the event that the PPDP has fulfilled the provisions as referred to in paragraph (1) letters a through d, the Financial Services Authority revokes the administrative sanction.

Article 29

In the event of a violation of the provisions regarding administrative sanctions as referred to in Article 28 paragraph (1), the Financial Services Authority may conduct a re-evaluation of the main party of the PPDP in accordance with the Financial Services Authority Regulation regarding re-evaluation for main parties of financial service institutions.

CHAPTER V
SELF-ASSESSMENT AND RISK PROFILE REPORTING

First Section
General

Article 30

(1) PPDPs are required to conduct an annual self-assessment of the Risk profile for the position at the end of December.

(2) If necessary, the Financial Services Authority may request the PPDP to conduct a self-assessment of the Risk profile at any time.

(3) PPDPs are required to conduct self-assessments of the Risk profile at any time as requested by the Financial Services Authority as referred to in paragraph (2).

(4) The results of the self-assessment of the Risk profile as referred to in paragraph (1) and paragraph (3) must receive approval from the Board of Directors.

(5) The results of the self-assessment of the Risk profile as referred to in paragraph (1) and paragraph (3) must be submitted to the Board of Commissioners.

(6) Provisions regarding the self-assessment of the Risk profile as referred to in paragraph (1) through paragraph (5) are determined by the Financial Services Authority.

Article 31

(1) PPDPs are required to submit the results of the self-assessment of the Risk profile as referred to in Article 30 paragraph (1) in the Risk Profile report to the Financial Services Authority.

(2) The PPDP Risk Profile report as referred to in paragraph (1) is part of the health level assessment results report for PPDPs that conduct health level assessments.

(3) The PPDP Risk Profile report as referred to in paragraph (1) must be submitted no later than February 15 of the following year.

(4) If the deadline for submitting the PPDP Risk Profile report as referred to in paragraph (3) falls on a holiday, the submission deadline is on the next working day.

(5) PPDPs are required to submit Risk Profile reports for self-assessments of Risk levels at any time as referred to in Article 30 paragraph (3) according to the time limits determined by the Financial Services Authority.

(6) Under certain conditions, the Financial Services Authority has the authority to set submission deadlines for reports that differ from the provisions as referred to in paragraph (3).

Article 32

(1) Submission of the Risk Profile report as referred to in Article 31 paragraph (1) and paragraph (5) is conducted online through the Financial Services Authority's data communication network system.

(2) In the event that the Financial Services Authority's data communication network system as referred to in paragraph (1) is not yet available or experiences disruption, submission is conducted online through the Financial Services Authority's email address.

(3) In the event of a disruption to the Financial Services Authority's email, report submission is conducted offline through the Financial Services Authority's office.

(4) Provisions regarding the procedure for submitting Risk Profile reports are determined by the Financial Services Authority.

Second Section
Administrative Sanctions

Article 33

(1) PPDPs that violate the provisions as referred to in Article 30 paragraph (1), paragraph (3), paragraph (4), paragraph (5), and/or Article 31 paragraph (1), paragraph (5) are subject to administrative sanctions in the form of:
a. written warning; b. restriction of business activities in part or in whole;
c. suspension of business activities;
d. prohibition on conducting certain programs; and/or e. downgrade of health level.

(2) In the event of a violation of the provisions as referred to in paragraph (1) and the violation has been rectified, the Financial Services Authority imposes a written warning sanction that ends automatically.

(3) In the event that the PPDP has fulfilled the provisions as referred to in paragraph (1) letters a through d, the Financial Services Authority revokes the administrative sanction.

Article 34

In the event of a violation of the provisions regarding administrative sanctions as referred to in Article 33 paragraph (1), the Financial Services Authority may conduct a re-evaluation of the main party of the PPDP in accordance with the Financial Services Authority Regulation regarding re-evaluation for main parties of financial service institutions.

CHAPTER VI
OTHER PROVISIONS

Article 35

(1) In the event that the PPDP applies Integrated Risk Management as referred to in the Financial Services Authority Regulation regarding the application of Integrated Risk Management for financial conglomerates, the Risk Management Work Unit or Risk Management Function as referred to in Article 20 paragraph (1) letter b may be combined with the Risk Management Work Unit or Risk Management Function in the structure of the PPDP's financial conglomerate.

(2) The application of Risk Management for financial institution pension funds may be combined with the application of Risk Management by the founder.

Article 36

Guarantee institutions, insurance broker companies, reinsurance broker companies, and insurance loss assessor companies submit the results of their first self-assessment of the Risk profile for the 2026 period no later than February 15, 2027.

Article 37

The Financial Services Authority may grant approval or policies that differ from this Financial Services Authority Regulation based on specific considerations.

CHAPTER VII
CLOSING PROVISIONS

Article 38

Upon the commencement of this Financial Services Authority Regulation, the implementation provisions of Financial Services Authority Regulation Number 44/POJK.05/2020 regarding the Application of Risk Management for Non-Bank Financial Service Institutions (State Gazette of the Republic of Indonesia Year 2020 Number 200, Supplement to the State Gazette of the Republic of Indonesia Number 6552) for Insurance Companies and Pension Funds, are declared to remain in force insofar as they do not conflict with the provisions in this Financial Services Authority Regulation.

Article 39

Upon the commencement of this Financial Services Authority Regulation, Financial Services Authority Regulation Number 44/POJK.05/2020 regarding the Application of Risk Management for Non-Bank Financial Service Institutions (State Gazette of the Republic of Indonesia Year 2020 Number 200, Supplement to the State Gazette of the Republic of Indonesia Number 6552), is repealed and declared invalid.

Article 40

This Financial Services Authority Regulation takes effect on January 1, 2026.

To ensure that everyone is aware of it, the promulgation of this Financial Services Authority Regulation is ordered by placing it in the State Gazette of the Republic of Indonesia.

Determined in Jakarta on November 10, 2025

CHAIRMAN OF THE BOARD OF COMMISSIONERS
FINANCIAL SERVICES AUTHORITY
REPUBLIC OF INDONESIA,

MAHENDRA SIREGAR

Promulgated in Jakarta on [Date]

MINISTER OF LAW
REPUBLIC OF INDONESIA,

SUPRATMAN ANDI AGTAS

STATE GAZETTE OF THE REPUBLIC OF INDONESIA YEAR 2025 NUMBER [Number]

EXPLANATION
OF
DRAFT FINANCIAL SERVICES AUTHORITY REGULATION
NUMBER 28 OF 2025
REGARDING
THE APPLICATION OF RISK MANAGEMENT FOR INSURANCE COMPANIES, GUARANTEE INSTITUTIONS, AND PENSION FUNDS

I. GENERAL

To address the development of the insurance, guarantee, and pension fund industries which are continuously faced with various challenges and Risks, PPDPs require the application of adequate, effective, and measurable Risk Management.

The application of Risk Management for PPDPs is reflected in 4 (four) main pillars, namely:
a. active supervision by the Board of Directors, Board of Commissioners, and Sharia Supervisory Board; b. adequacy of Risk Management policies and procedures and the determination of Risk limits;
c. adequacy of the process for Risk identification, measurement, monitoring, and control; and
d. Risk Management information systems, and good internal control systems.

With the issuance of Law Number 4 of 2023 regarding the Development and Strengthening of the Financial Sector, the supervision field for Non-Bank Financial Service Institutions is divided into 2 (two), namely the supervision field for insurance, pension funds, and guarantees; and the supervision field for financing institutions, venture capital companies, microfinance institutions, and other financial service institutions.

To implement the mandate of Article 11 paragraph (5) of Law Number 40 of 2014 regarding Insurance as amended by Law Number 4 of 2023 regarding the Development and Strengthening of the Financial Sector, as well as Article 143 paragraph (4) and Article 269 of Law Number 4 of 2023 regarding the Development and Strengthening of the Financial Sector, the Financial Services Authority issues provisions regarding the application of Risk Management for PPDPs with the aim of ensuring that PPDP Risk Management runs effectively.

Furthermore, the Financial Services Authority has also launched a roadmap for the development and strengthening of the guarantee industry in 2024, which aims to specifically develop guarantee companies regarding the application of Risk-based supervision for guarantee institutions. Supervision of guarantee institutions, which currently still uses compliance-based supervision, will shift to Risk-based supervision.

Generally, this Financial Services Authority Regulation contains main materials including the application of Risk Management, organization and Risk Management functions, management of Risks for business development or expansion, self-assessment and Risk Profile reporting, other provisions, and closing provisions.

Based on the above, it is necessary to refine the provisions by establishing regulations regarding Risk Management in the PPDP sector.

II. ARTICLE BY ARTICLE

Article 1

It is clear enough.

Article 2

It is clear enough.

Article 3

Paragraph (1)

The application of Risk Management includes the application of anti-money laundering programs, counter-terrorism financing, and counter-proliferation financing of weapons of mass destruction as regulated in the Financial Services Authority Regulation regarding the application of anti-money laundering, counter-terrorism financing, and counter-proliferation financing of weapons of mass destruction programs in the financial service sector.

To ensure the effective application of Risk Management, the Board of Directors, Board of Commissioners, and Sharia Supervisory Board refer to the duties and responsibilities of the Board of Directors, Board of Commissioners, and Sharia Supervisory Board.

Paragraph (2)

Letter a

Active supervision by the Sharia Supervisory Board is conducted for PPDPs that conduct all or part of their business based on Sharia Principles.

Letter b

It is clear enough.

Letter c

It is clear enough.

Letter d

It is clear enough.

Paragraph (3)

It is clear enough.

Paragraph (4)

It is clear enough.

Article 4

Business complexity is reflected, among others, in the diversity of business activities, products and/or services, branch office networks or distribution channels, and/or supporting technologies used.

PPDP capability includes, among others, financial capability, supporting infrastructure, and human resource capability.

Article 5

Paragraph (1)

Letter a

Strategic Risk arises, among others, because:
a. the PPDP sets strategies that are not aligned with the PPDP's vision and mission; b. the PPDP conducts strategic environment analysis that is not comprehensive;
c. there is a mismatch of strategic plans (strategic plan) among strategic levels; and
d. failure to anticipate changes in the business environment such as changes in technology, changes in macroeconomic conditions, market competition, and changes in relevant authority policies.

Letter b

Operational Risk includes, among others, the potential for fraud to arise, high complexity of the PPDP's business, ineffective human resource management, and inadequate information technology systems.

Letter c

It is clear enough.

Letter d

Credit Risk, among others, includes credit concentration Risk, counterparty credit Risk, and settlement Risk.

What is meant by "credit concentration Risk" is the Risk arising from the concentration of fund provision to 1 (one) party or a group of parties, industry, sector, and/or specific geographical area that has the potential to cause significant losses that can threaten the continuity of the PPDP's business.

What is meant by "counterparty credit Risk" is the Risk arising from the failure of the counterparty to fulfill its obligations and arises from transaction types that have specific characteristics, for example, transactions influenced by fair value or market value movements.

What is meant by "settlement Risk" is the Risk arising from the failure to deliver cash and/or financial instruments on the agreed settlement date of the sale and/or purchase transaction of financial instruments.

Letter e

Market Risk includes, among others, interest rate Risk, exchange rate Risk, commodity Risk, and equity Risk.

Letter f

It is clear enough.

Letter g

Legal Risk arises, among others, due to the absence of supporting legislation regulations or weaknesses in agreements such as the non-fulfillment of contract validity requirements or imperfect collateral binding.

Letter h

It is clear enough.

Letter i

Reputational Risk arises, among others, due to negative media coverage and/or rumors regarding the PPDP, and ineffective PPDP communication strategies.

Paragraph (2)

Letter a

See explanation of paragraph (1) letter a.

Letter b

See explanation of paragraph (1) letter b.

Letter c

See explanation of paragraph (1) letter g.

Letter d

It is clear enough.

Letter e

See explanation of paragraph (1) letter i.

Paragraph (3)

Letter a

See explanation of paragraph (1) letter a.

Letter b

See explanation of paragraph (1) letter b.

Letter c

It is clear enough.

Letter d

See explanation of paragraph (1) letter d.

Letter e

See explanation of paragraph (1) letter e.

Letter f

It is clear enough.

Letter g

See explanation of paragraph (1) letter g.

Letter h

It is clear enough.

Letter i

See explanation of paragraph (1) letter i.

Paragraph (4)

Letter a

See explanation of paragraph (1) letter a.

Letter b

See explanation of paragraph (1) letter b.

Letter c

See explanation of paragraph (1) letter d.

Letter d

See explanation of paragraph (1) letter e.

Letter e

It is clear enough.

Letter f

See explanation of paragraph (1) letter g.

Letter g
Clearly stated.
Letter h
See the explanation in paragraph (1) letter i.
Paragraph (5)
Clearly stated.
Article 6
Each level of position includes, among others, the Board of Directors, Board of Commissioners, Sharia Supervisory Board, and other positions related to the implementation of Risk Management.

Article 7
Paragraph (1)
Letter a
Included in the Risk Management policy and strategy are, among others, the determination and approval of the level of Risk taken (risk appetite) along with Risk limits, whether for Risk as a whole (composite), per type of Risk, per functional activity, or per material/significant transaction. Letter b Clearly stated. Letter c Transactions and Risk limits requiring Board of Directors approval include transactions and Risk limits that have exceeded the authority of the PPDP official one level below the Board of Directors, in accordance with the applicable internal PPDP policies and procedures. Letter d The development of a Risk Management culture includes, among others, adequate communication to all organizational levels regarding Risk Management principles, including developing a risk-aware culture and the importance of effective internal controls. Letter e The improvement of human resource competence includes, among others, through continuous education and training programs regarding the implementation of Risk Management. Letter f The term "independent" includes, among others, the separation of functions between the Risk Management function, which performs risk identification, measurement, monitoring, and control, and the function that conducts and completes business and operational activities. Letter g Periodic reviews include, among others, to anticipate changes in external and internal factors. Paragraph (2) Clearly stated. Paragraph (3) Inherent risk is known as the risk that is embedded.

Article 8
Paragraph (1)
Letter a
Clearly stated.
Letter b
Clearly stated.
Letter c
Transactions requiring Board of Commissioners approval include business or operational activities that have exceeded the Board of Directors' authority to make such decisions, in accordance with the applicable internal PPDP policies and procedures. Paragraph (2) Clearly stated. Paragraph (3) Clearly stated.

Article 9
Clearly stated.

Article 10
Risk Management policies are established, among others, by formulating a Risk Management strategy to ensure that:
a. PPDP maintains Risk exposure in accordance with internal PPDP policies and procedures, legislation, and other regulations; and b. PPDP is managed by human resources possessing knowledge, experience, and expertise in Risk Management commensurate with the complexity of PPDP's business. The formulation of the Risk Management strategy is conducted by considering PPDP's financial conditions, organizational structure, and Risks arising from changes in external and internal factors. Letter a Clearly stated. Letter b Clearly stated. Letter c The level of Risk to be taken (risk appetite) considers PPDP's experience in managing Risk and PPDP's capital capacity to absorb Risk. Risk tolerance (risk tolerance) is the potential loss that can be absorbed by PPDP's capital. Letter d The determination of Risk rating assessment serves as the basis for PPDP to categorize its Risk rating. PPDP's Risk ratings are categorized into 5 (five) levels, namely:
a. level 1 (low); b. level 2 (relatively low);
c. level 3 (medium);
d. level 4 (relatively high); and e. level 5 (high).

Letter e
The term "contingency plan" refers to a plan for developing scenarios to anticipate internal disruptions, including system failures, and external disruptions that cause emergency conditions leading to operational disruptions for PPDP. The formulation of a contingency plan is known as a contingency plan. The worst-case scenario is known as a worst case scenario. Letter f Clearly stated.

Article 11
Paragraph (1)
Clearly stated.
Paragraph (2)
Letter a
Clearly stated.
Letter b
Clearly stated.
Letter c
Adequate documentation is conducted through written, complete, accurate, current, and intact documentation, thereby facilitating audit trails for the purposes of PPDP's internal control. Paragraph (3) Letter a The term "overall limit" refers to the Risk limit that can be tolerated by PPDP for all Risks applied. Letter b The term "limit per type of Risk" refers to the Risk limit that can be tolerated by PPDP for each type of Risk. Letter c The term "limit per specific functional activity" refers to the Risk limit that can be tolerated by PPDP for each functional activity.

Article 12
Paragraph (1)
The term "Risk factor" refers to various parameters that influence Risk exposure.
The term "material Risk factor" refers to Risk factors, both quantitative and qualitative, that significantly affect PPDP's financial conditions.
Paragraph (2)
Letter a
Clearly stated.

Letter b
The term "informative" includes, among others, being easy to understand.
Letter c
Possessing competence in Risk Management includes, among others:
a. possessing professional certification in risk management, prioritizing risk management certification for each respective PPDP industry from a professional certification body registered with the Financial Services Authority; b. possessing experience in Risk Management; and/or
c. possessing adequate experience in financial service institutions related to the industry.

Article 13
Paragraph (1)
The Risk identification process can be based, among others, on PPDP's past loss experience.
Paragraph (2)
To implement Risk measurement, PPDP may use various approaches, both qualitative and quantitative, adjusted to the business objectives and complexity of PPDP's business. Letter a Clearly stated. Letter b The term "changes in PPDP's business activities and material Risk factors" refers to changes in PPDP's business activities and Risk factors that are quantitative or qualitative, which can affect PPDP's financial conditions. Paragraph (3) Letter a Evaluation of Risk exposure is conducted through monitoring and reporting of material Risks or Risks impacting PPDP's capital/funding conditions, which is based, among others, on the assessment of potential Risk using historical trends. Letter b Clearly stated. Paragraph (4) Risk control can be conducted, among others, through hedging, Risk mitigation methods, and capital addition to absorb potential losses.

Article 14
Paragraph (1)
Competence in Risk Management information systems includes, among others, professional certificates and/or proof of having undergone training in Risk Management information systems. The term "Risk Management information system" refers to a system using information technology and data processing to support decision-making in Risk Management. Paragraph (2) Letter a Reports or information on Risk exposure cover quantitative and qualitative exposure, both overall (composite) and detailed by type of Risk and type of functional activity. Letter b Clearly stated. Letter c Clearly stated. Paragraph (3) The term "periodically" refers to the frequency of reports or information submitted to the Board of Directors, adjusted to PPDP's needs.

Article 15
Clearly stated.

Article 16
Paragraph (1)
Clearly stated.
Paragraph (2)
Letter a
Clearly stated.
Letter b
Clearly stated.
Letter c
Complete, accurate, relevant, and timely financial and management information is required for making appropriate and accountable decisions, and communicated to interested parties. Letter d Effectiveness and efficiency in business and operational activities are necessary, among others, to protect PPDP's assets and other resources from related Risks. Letter e The purpose of Risk culture (risk culture) effectiveness is to identify weaknesses and deviations earlier and to continuously reassess the fairness of existing policies and procedures at PPDP.

Article 17
Clearly stated.

Article 18
Clearly stated.

Article 19
Clearly stated.

Article 20
Paragraph (1)
Letter a
The Risk Management Committee must be non-structural.
Letter b
Clearly stated.
Paragraph (2)
Clearly stated.
Paragraph (3)
Clearly stated.
Paragraph (4)
Clearly stated.

Article 21
Paragraph (1)
Letter a
Clearly stated.
Letter b
The term "relevant executive official" refers to an official directly responsible to the Board of Directors or having significant influence over PPDP's policies and/or operations related to the implementation of Risk Management, including division heads, branch heads, heads of Risk Management work units, heads of compliance work units, and heads of internal audit work units. Paragraph (2) Clearly stated. Paragraph (3) Letter a Clearly stated. Letter b Clearly stated. Letter c Decisions on business activities deviating from normal procedures include, among others, significant expansion of business beyond PPDP's business plan and taking positions or Risk exposures that deviate from established limits and exceed PPDP's capital capacity to absorb Risk. Paragraph (4) Clearly stated.

Article 22
Paragraph (1)
PPDP determines an appropriate organizational structure suitable for PPDP's conditions, including financial capacity and human resources.
Paragraph (2)
The concept of independence is reflected, among others, in:

1. the separation of functions and tasks between the Risk Management function and the business and operational functions (risk-taking function) and the internal control function; and
2. a decision-making process that is impartial or does not favor specific business and operational functions or ignore other operational functions.
   Paragraph (3)
   Clearly stated.
   Paragraph (4)
   Clearly stated.
   Paragraph (5)
   The authority and responsibility of the Risk Management work unit or Risk Management function are adjusted to PPDP's business objectives and complexity. Letter a Risk identification includes coordinating with all work units within PPDP. Letter b Clearly stated. Letter c Clearly stated. Letter d Overall Risk, known as "composite risk," is the Risk faced by PPDP considering all types of Risk at PPDP. Testing using assumptions of abnormal conditions, known as "stress testing," is a test of Risk positions using several assumptions of abnormal conditions to determine the impact of such abnormal conditions on PPDP's Risk positions. Testing using historical data, known as "back testing," is a test of Risk positions using historical data to determine the effectiveness of Risk Management. Letter e Reviews are conducted, among others, based on internal audit findings and/or developments in Risk Management practices applied internationally. Letter f Included in such reviews are, among others, the assessment of PPDP's ability to develop or expand business activities and the review of proposed system and procedure changes. Letter g Models for internal use are known as internal models.

Letter h
Recommendations include, among others, recommendations related to the magnitude or maximum Risk exposure that must be maintained by PPDP.
Letter i
Risk profile is a comprehensive overview of the magnitude of potential Risk embedded in the entire portfolio or PPDP's exposure.
The frequency of report submission can be increased if market conditions change rapidly.
Paragraph (6)
Clearly stated.
Paragraph (7)
Clearly stated.
Paragraph (8)
Clearly stated.

Article 23
Paragraph (1)
The frequency of submitting Risk exposure information is adjusted to the characteristics of the type of Risk.
Paragraph (2)
Clearly stated.

Article 24
Clearly stated.

Article 25
Clearly stated.

Article 26
Paragraph (1)
Clearly stated.
Paragraph (2)
Letter a
Clearly stated.
Letter b
Clearly stated.
Letter c
The trial period is intended to ensure that Risk measurement and monitoring methods have been tested.
Letter d
Accounting information systems include, among others, describing the Risk profile and profit or loss levels for the development or expansion of business activities accurately. Letter e Legal aspects and consumer protection analysis cover the possibility of Legal Risks arising from the development or expansion of business activities and compliance with legislation and regulations.

Letter f
Aspects in applying information transparency to consumers consider regulations regarding consumer and public protection, which include, among others:
a. information provided is clear, accurate, correct, and not misleading to consumers; b. balanced information between potential benefits that may be obtained and Risks that may arise for consumers; and
c. information provided does not obscure, reduce, or conceal important matters related to potential Risks.
Paragraph (3)
Letter a
Criteria for activities never previously conducted include business activities conducted by other PPDPs but never conducted by the PPDP in question, referring to the respective PPDP's legislation. Letter b Clearly stated. Paragraph (4) Clearly stated.

Article 27
Actions deemed as approval include, among others, knowing but not prohibiting or allowing activities that are not PPDP business activities to occur using PPDP facilities by the Board of Directors, Board of Commissioners, Sharia Supervisory Board, and/or employees.

Article 28
Clearly stated.

Article 29
Clearly stated.

Article 30
Clearly stated.

Article 31
Paragraph (1)
Clearly stated.
Paragraph (2)
Example: For Pension Fund ABC, which has implemented health level assessments covering the Risk profile, the Risk profile report resulting from Pension Fund ABC's own Risk level assessment is part of the health level assessment results report. Thus, Pension Fund ABC does not submit a separate Risk profile report.

Paragraph (3)
Clearly stated.
Paragraph (4)
Clearly stated.
Paragraph (5)
Clearly stated.
Paragraph (6)
Specific conditions include, among others, the existence of a catastrophe condition.

Article 32
Clearly stated.

Article 33
Clearly stated.

Article 34
Clearly stated.

Article 35
Clearly stated.

Article 36
Clearly stated.

Article 37
The granting of different approvals or policies is intended, among others, to:
a. support national policies; b. protect public interests;
c. maintain industry growth; and/or
d. maintain healthy business competition.
Conditions requiring specific consideration include, among others, extraordinary events that can cause significant increases in morbidity and mortality and also impact the economy and society, thus requiring attention and handling by all relevant parties and regulated in other provisions regarding considerations for facing possible extraordinary events.

Article 38
Clearly stated.

Article 39
Clearly stated.

Article 40
Clearly stated.

SUPPLEMENT TO THE GAZETTE OF THE REPUBLIC OF INDONESIA NUMBER ⸙