Circular Letter of the Financial Services Authority Number 35/SEOJK.06/2025 on the Assessment of the Health Level of Pawn Companies and Sharia Pawn Companies

TRANSITION

To:

Board of Directors of Pawn Companies; and
Board of Directors of Sharia Pawn Companies,
at their respective locations.

COPY

CIRCULAR LETTER OF THE FINANCIAL SERVICES AUTHORITY REPUBLIC OF INDONESIA NUMBER 35/SEOJK.06/2025

THE ASSESSMENT OF THE HEALTH LEVEL OF PAWN COMPANIES AND SHARIA PAWN COMPANIES

In relation to the mandate stipulated in Article 196 paragraph (3) and Article 203 paragraph (8) of Financial Services Authority Regulation Number 39 of 2024 as amended by Financial Services Authority Regulation Number 29 of 2025 regarding Amendments to Financial Services Authority Regulation Number 39 of 2024 concerning Pawn (State Gazette of the Republic of Indonesia Year 2025 Number 39/OJK, Additional State Gazette of the Republic of Indonesia Number 168/OJK), it is necessary to further regulate the assessment of the health level of pawn companies and Sharia pawn companies in this Circular Letter of the Financial Services Authority as follows:

I. GENERAL PROVISIONS

Pawn Company is a legal entity conducting business activities providing loans secured by movable property on a conventional basis.
Sharia Pawn Company is a legal entity conducting all business activities providing loans secured by movable property based on Sharia principles.
Company means Pawn Company and Sharia Pawn Company.
Sharia Principle is Islamic law principle based on fatwa and/or Sharia conformity statement issued by an institution having authority in determining fatwas in the Sharia field.
Gadai (Pawn) is a right obtained by the Company over a movable property, which is handed over to it by the customer or by their proxy, as security for their loan, and which gives the Company the authority to take repayment of the loan from that property prior to other creditors, with the exception of costs for auctioning or selling that property and costs for saving that property incurred after that property is handed over as pawn, such costs being prioritized.
Secured Property is any movable property used as security by the customer to the Company.
Loan is money lent by the Company to the customer.
Customer is an individual or business entity receiving a Loan with Secured Property and/or utilizing other services available at the Company.
Health Level is the result of assessing the Company's condition regarding capital adequacy, quality of Loan receivables, profitability, liquidity, and management.
Composite Rank is the final rank resulting from the Health Level assessment.
Equity is equity based on applicable financial accounting standards in Indonesia.
Paid-in Capital is paid-in capital as referred to in laws concerning limited liability companies for Companies formed as limited liability company legal entities or the sum of basic deposits, mandatory deposits, and donations as referred to in legislation concerning cooperatives for Companies formed as cooperative legal entities.

II. GENERAL PRINCIPLES FOR ASSESSING THE HEALTH LEVEL OF COMPANIES

General principles in conducting assessments of the Company's Health Level are as follows:
a. risk-oriented; b. proportionality;
c. materiality and significance; and
d. comprehensive and structured.
What is meant by risk-oriented as referred to in item 1 letter a includes, among others:
a. the assessment of the Company's Health Level is based on the Company's risks and the impact they have on the Company's overall performance; b. the assessment of the Company's Health Level is conducted by identifying internal and external factors that can increase risk or affect the Company's current and future financial performance. In identifying internal and external factors, the Company may assess:
1. internal factors, including:
  a) vision, mission, strategy, and business direction the Company aims to achieve; b) organizational culture and characteristics, particularly in strategic goal setting requiring changes in organizational structure and adjustment of business processes; c) organizational capability factors covering human resources, complexity of business activities, infrastructure, office network, and management information systems; and d) risk tolerance level, i.e., the Company's financial capacity to absorb risk; and
2. external factors, including:
  a) macroeconomic conditions; b) industry conditions; c) technological developments; and d) level of business competition;
  c. the Company is expected to be able to detect the root causes of the Company's problems earlier and take effective and efficient preventive and corrective measures.
What is meant by proportionality as referred to in item 1 letter b includes, among others:
a. the use of parameters or indicators in each factor of the Company's Health Level assessment is conducted by considering the Company's business characteristics and complexity; b. the parameters or indicators for assessing the Company's Health Level in this Financial Services Authority Circular Letter are minimum standards that must be used in assessing the Company's Health Level; and
c. besides the parameters or indicators as referred to in letter b, the Company may use additional parameters or indicators according to its business characteristics and complexity in assessing the Company's Health Level so as to reflect the Company's condition more accurately.
What is meant by materiality and significance as referred to in item 1 letter c includes, among others:
a. the Company needs to pay attention to the materiality and significance of the factors for assessing the Company's Health Level, namely capital adequacy, quality of Loan receivables, profitability, liquidity, and management, as well as the significance of parameters or indicators for assessment in each factor in concluding assessment results and establishing factor ranks; and b. the determination of such materiality and significance is based on analysis supported by adequate data and/or information regarding the Company's risks and financial performance.
What is meant by comprehensive and structured as referred to in item 1 letter d includes, among others:
a. the assessment process is conducted thoroughly and systematically and is focused on the Company's main problems; b. analysis is conducted in an integrated manner, i.e., by considering the interrelationship between risks and between factors of the Company's Health Level assessment; and
c. analysis must be supported by key facts and relevant ratios to show the level, trend, and/or level of problems faced by the Company.

III. PROCEDURE FOR ASSESSING THE HEALTH LEVEL OF COMPANIES

The Company conducts Health Level assessment with coverage of assessment on factors:
a. capital adequacy; b. quality of Loan receivables;
c. profitability;
d. liquidity; and e. management.
Implementation of Health Level assessment in the initial stage is conducted by quantifying components of each factor as referred to in item 1.
Results of quantitative assessment of components of each factor as referred to in item 2 are ranked based on guidelines for establishing factor ranks.
The Company's Health Level assessment is established into 5 (five) composite ranks with categories as follows:
a. Composite Rank 1 (very healthy); b. Composite Rank 2 (healthy);
c. Composite Rank 3 (fairly healthy);
d. Composite Rank 4 (less healthy); and e. Composite Rank 5 (unhealthy), with smaller Composite Rank order reflecting a healthier Company condition.
The Company must meet a Health Level of at least Composite Rank 3.
Assessment of each factor is conducted using quantitative aspects and qualitative aspects based on comprehensive and structured analysis, considering adjustments or judgment against the factor rank conclusion if necessary.
Final Health Level assessment is established based on analysis of each Health Level assessment factor, including analysis of capital adequacy factor, Loan receivables quality factor, liquidity factor, profitability factor, management factor, and overall Health Level analysis. Such analysis is part of the comprehensive and structured Health Level assessment covering at least the latest information on the Company's condition, main problems currently faced, including interrelationships between factors, which can serve as consideration in making adjustments to the composite rank conclusion if necessary (judgment).
Final Health Level assessment as referred to in item 7 uses the Health Level assessment worksheet format as contained in Appendix I, which is an integral part of this Financial Services Authority Circular Letter.

IV. ASSESSMENT OF CAPITAL ADEQUACY FACTOR

Assessment of the capital adequacy factor includes assessment of adequacy, projection, and capital ability to anticipate risks.
Assessment of the capital adequacy factor as referred to in item 1 is conducted using quantitative and qualitative approaches.
Assessment of the capital adequacy factor using the quantitative approach as referred to in item 2 is conducted at least on parameters or indicators for compliance with regulations:
a. Equity; and b. ratio of Equity compared to Paid-in Capital.
Compliance with the capital adequacy factor regulation as referred to in item 3 letter a includes assessment of compliance with Equity according to Financial Services Authority regulations concerning pawn.
Compliance with the capital adequacy factor regulation as referred to in item 3 letter b includes assessment of the ratio of Equity to Paid-in Capital of at least 50% (fifty percent). What is meant by "ratio of Equity to Paid-in Capital" is the comparison between the Company's total Equity and total Paid-in Capital.
Assessment using the qualitative approach as referred to in item 2 is conducted through analysis of, among others, quantitative parameters as referred to in item 3, considering adjustments or judgment so as to produce a comprehensive and structured factor rank conclusion.
The capital adequacy factor is established based on comprehensive and structured analysis of capital parameters as referred to in item 3, considering the materiality and significance of each parameter or indicator and considering other problems affecting the Company's capital.
The Company establishes the capital adequacy factor rank categorized into 5 (five) ranks, namely:
a. rank 1; b. rank 2;
c. rank 3;
d. rank 4; and e. rank 5, with smaller capital adequacy factor rank order reflecting a better condition.
The Company assesses the capital adequacy factor using parameters or indicators as contained in Table II.A Appendix II, which is an integral part of this Financial Services Authority Circular Letter.
Establishment of the capital adequacy factor rank is conducted according to Table II.B Appendix II, which is an integral part of this Financial Services Authority Circular Letter.
The Company assesses the capital adequacy factor using the worksheet as contained in Table II.C Appendix II, which is an integral part of this Financial Services Authority Circular Letter.

V. ASSESSMENT OF LOAN RECEIVABLE QUALITY FACTOR

Assessment of the Loan receivables quality factor includes assessment of the following components:
a. quality of Loan receivables; b. concentration of risk exposure;
c. adequacy of policies and procedures;
d. documentation of Loan provision; and e. performance in handling problematic Loan receivable balances.
Assessment of the Loan Receivables Quality factor as referred to in item 1 is conducted using quantitative and qualitative approaches.
Assessment of the Loan receivables quality component as referred to in item 1 letter a using the quantitative approach is conducted on parameters or indicators for compliance with regulations:
a. gross non-performing Loan ratio; b. net non-performing Loan ratio;
c. gross low-quality Loan ratio; and
d. net low-quality Loan ratio.
Assessment of the concentration of risk exposure component as referred to in item 1 letter b using the quantitative approach is conducted on parameters or indicators for compliance with regulations:
a. Loan ratio per economic sector; b. non-performing Loan ratio per economic sector against total Loans per economic sector; and
c. non-performing Loan ratio per economic sector against total non-performing Loans.
The Company conducts Loan quality assessment:
a. Loans with Secured Property based on Gadai law; and/or b. Loans with Secured Property based on fiducia, which are provided.
Loan quality assessment as referred to in item 5 consists of:
a. performing; b. special mention;
c. substandard;
d. doubtful; and e. loss.
Loan quality assessment as referred to in item 6 is established based on the timeliness of principal and/or Loan interest payment or service/yield remuneration.
Criteria regarding Loan quality as referred to in item 6 refer to regulations stipulated in Article 175 paragraph (4) of Financial Services Authority Regulation Number 39 of 2024 concerning Pawn.
Assessment of the performance in handling problematic Loan receivable balance component as referred to in item 1 letter e is conducted based on documents or supporting information showing that the Company can handle problematic Loan receivable balances, among others through calculation of restructured Loans and results of Secured Property sales.
In the event the Company restructures Loan receivables, the Loan quality after restructuring is established:
a. at highest equal to the Loan quality before restructuring, if the Customer has not met the obligation to pay principal and/or interest installments consecutively for 3 (three) periods according to the agreed time; b. may increase at highest 1 (one) level from the Loan quality before restructuring, after the Customer meets the obligation to pay principal and/or interest installments consecutively for 3 (three) periods as referred to in letter a; and
c. based on assessment factors as referred to in item 6:

after establishment of Loan quality as referred to in letter b; or
in the event the Customer does not meet eligibility and/or payment obligations in the restructuring agreement, both during and after 3 (three) periods of payment obligations according to the agreed time.

The Company calculates and forms provisions for Loan receivable write-offs referring to regulations stipulated in Article 179 of Financial Services Authority Regulation Number 39 of 2024 concerning Pawn.
The Company maintains the net non-performing Loan receivable balance ratio at highest 5% (five percent), calculated by comparing Loans with substandard, doubtful, and loss quality, after deducting provisions for Loan receivable write-offs that have been formed.
Assessment using the qualitative approach as referred to in item 2 is conducted through analysis of, among others, quantitative parameters or indicators as referred to in items 3 and 4, considering adjustments or judgment so as to produce a comprehensive and structured factor rank conclusion.
The Company establishes the Loan receivables quality factor rank categorized into 5 (five) ranks, namely:
a. rank 1; b. rank 2;
c. rank 3;
d. rank 4; and e. rank 5, with smaller Loan receivables quality factor rank order reflecting a better condition.
The Company assesses the Loan receivables quality factor using parameters or indicators as contained in Table III.A Appendix III, which is an integral part of this Financial Services Authority Circular Letter.
Establishment of the Loan receivables quality factor rank is conducted according to Table III.B Appendix III, which is an integral part of this Financial Services Authority Circular Letter.
The Company assesses the Loan receivables quality factor using the worksheet as contained in Table III.C Appendix III, which is an integral part of this Financial Services Authority Circular Letter.

VI. ASSESSMENT OF PROFITABILITY FACTOR

Assessment of the profitability factor includes assessment of the following components:
a. ability of productive assets to generate profit; and b. level of operational efficiency.
Assessment of the profitability factor as referred to in item 1 is conducted using quantitative and qualitative approaches.
Assessment of the ability of productive assets to generate profit component as referred to in item 1 letter a using the quantitative approach is conducted on parameters or indicators for compliance with regulations:
a. return on asset (RoA); and b. return on equity (RoE).
Assessment of the level of operational efficiency component as referred to in item 1 letter b using the quantitative approach is conducted on parameter compliance with operating expenses to operating income ratio (BOPO).
Assessment using the qualitative approach as referred to in item 2 is conducted through analysis of, among others, quantitative parameters as referred to in items 3 and 4, considering adjustments or judgment so as to produce a comprehensive and structured factor rank conclusion.
The Company establishes the profitability factor rank categorized into 5 (five) ranks, namely:
a. rank 1; b. rank 2;
c. rank 3;
d. rank 4; and e. rank 5, with smaller profitability factor rank order reflecting a better condition.
The Company assesses the profitability factor using parameters or indicators as contained in Table IV.A Appendix IV, which is an integral part of this Financial Services Authority Circular Letter.
Establishment of the profitability factor rank is conducted according to Table IV.B Appendix IV, which is an integral part of this Financial Services Authority Circular Letter.
The Company assesses the profitability factor using the worksheet as contained in Table IV.C Appendix IV, which is an integral part of this Financial Services Authority Circular Letter.

VII. ASSESSMENT OF LIQUIDITY FACTOR

Assessment of the liquidity factor includes assessment of the following components:
a. ability to meet short-term and long-term obligations, and potential occurrence of mismatch between short-term and long-term obligations; and b. adequacy of liquidity management policies.
Assessment of the liquidity factor as referred to in item 1 is conducted using quantitative and qualitative approaches.
Assessment of the ability to meet obligations component as referred to in item 1 letter a using the quantitative approach is conducted on parameters or indicators for compliance with regulations:
a. short-term liquidity ratio; and b. ability to meet long-term obligations.
Assessment of the short-term liquidity factor as referred to in item 3 letter a is conducted on the Company's ability to maintain a liquidity ratio of at least 120% (one hundred twenty percent), calculated by comparing current assets and current liabilities.
Assessment using the qualitative approach as referred to in item 2 is conducted through analysis of, among others, quantitative parameters as referred to in item 4, considering adjustments or judgment so as to produce a comprehensive and structured factor rank conclusion.
The Company establishes the liquidity factor rank categorized into 5 (five) ranks, namely:
a. rank 1; b. rank 2;
c. rank 3;
d. rank 4; and e. rank 5, with smaller liquidity factor rank order reflecting a better condition.
The Company assesses the liquidity factor using parameters or indicators as contained in Table V.A Appendix V, which is an integral part of this Financial Services Authority Circular Letter.
Establishment of the liquidity factor rank is conducted according to Table V.B Appendix V, which is an integral part of this Financial Services Authority Circular Letter.
The Company assesses the liquidity factor using the worksheet as contained in Table V.C Appendix V, which is an integral part of this Financial Services Authority Circular Letter.

VIII. ASSESSMENT OF MANAGEMENT FACTOR

Assessment of the management factor includes assessment of the following components:
a. quality of general management, including implementation of fulfillment of commitments to the Financial Services Authority or other parties; b. application of risk management, especially management's understanding of the Company's risks; and
c. the Company's compliance with Sharia Principles and implementation of social functions, for Sharia Pawn Companies.
Assessment of the management factor as referred to in item 1 is conducted using a qualitative approach.
Assessment of the management factor components as referred to in item 1 letters a and c is conducted by assessing the application of good corporate governance by the Company's management.
The Company must apply good corporate governance principles in every business activity at all levels or tiers of the organization.
Good corporate governance principles as referred to in item 4 include:
a. openness; b. accountability;
c. responsibility;
d. independence; and e. fairness.
Application of good corporate governance as referred to in item 3 is manifested at least in:
a. implementation of duties and authorities of shareholders, and general meeting of shareholders; b. implementation of duties, responsibilities, and authorities of the board of directors;
c. implementation of duties, responsibilities, and authorities of the board of commissioners;

commissioner; d. implementation of the duties, responsibilities, and authority of the Sharia Supervisory Board; e. completeness and implementation of committee duties; f. implementation of risk management; g. implementation of antifraud strategy; h. implementation of compliance function;
i. implementation of internal and external audit functions;
j. handling of Conflicts of Interest; k. implementation of remuneration policy;
l. information openness;
m. business ethics; n. financing policy; o. implementation of sustainable finance, including the implementation of social and environmental responsibility; and p. business plan.
7. Guidelines and procedures for assessing good corporate governance refer to the Financial Services Authority Circular Letter regarding the reporting of good corporate governance for financing institutions, venture capital companies, microfinance institutions, and other financial service institutions.
8. Assessment of the management factor as referred to in paragraph 1 letter b, letter c, and paragraph 6 letter f is conducted by evaluating the Company's obligation to implement risk management effectively.
9. Implementation of risk management as referred to in paragraph 8 must at least cover:
a. active supervision by the Board of Directors, Board of Commissioners, Sharia Supervisory Board, and managers; b. adequacy of policies, procedures, and risk limit determinations;
c. adequacy of risk identification, measurement, monitoring, and control processes, as well as risk management information systems; and
d. comprehensive internal control systems.
10. Implementation of risk management as referred to in paragraph 8 must at least be applied for Companies:
a. with business scope at the provincial and national levels, to at least:

credit risk;
market risk;
operational risk;
strategic risk;
liquidity risk;
legal risk;
compliance risk; and
reputational risk;
b. with business scope at the regency/city level, to at least:
credit risk;
operational risk;
strategic risk;
liquidity risk;
legal risk;
compliance risk; and
reputational risk.
Companies may establish other risks beyond those referred to in paragraph 10 arising from the Company's business activities after obtaining approval from the Financial Services Authority.
The Financial Services Authority may require Companies to establish other risks beyond those referred to in paragraph 10 arising from the Company's business activities, including risks related to Sharia Principles.
Guidelines and procedures for assessing the implementation of risk management refer to the Financial Services Authority Board of Commissioners Regulation regarding guidelines for implementing risk management for financing institutions, venture capital companies, microfinance institutions, and other financial service institutions.
Assessment using a qualitative approach as referred to in paragraph 2 is conducted through analysis considering adjustments or judgment to produce a comprehensive and structured factor ranking conclusion.
Companies determine management factor rankings categorized into 5 (five) rankings, namely:
a. ranking 1; b. ranking 2;
c. ranking 3;
d. ranking 4; and e. ranking 5, with smaller management factor ranking orders reflecting better conditions.
Companies assess management factors using parameters or indicators as listed in Table VI.A Annex VI, which is an integral part of this Financial Services Authority Circular Letter.
Determination of management factor rankings is conducted in accordance with Table VI.B Annex VI, which is an integral part of this Financial Services Authority Circular Letter.
Companies assess management factors using worksheets as listed in Table VI.C Annex VI, which is an integral part of this Financial Services Authority Circular Letter.
IX. VERIFICATION AND VALIDATION BY THE FINANCIAL SERVICES AUTHORITY
The Financial Services Authority may conduct verification and validation of the truthfulness and fairness of data serving as the basis for calculating the Health Level factors compiled by Companies.

signed.
Aat Windradi
X. CLOSING
This Financial Services Authority Circular Letter takes effect on the date of establishment.
Established in Jakarta on December 1, 2025
EXECUTIVE HEAD OF SUPERVISOR
FOR FINANCING INSTITUTIONS,
VENTURE CAPITAL COMPANIES,
MICROFINANCE INSTITUTIONS, AND
OTHER FINANCIAL SERVICE INSTITUTIONS
FINANCIAL SERVICES AUTHORITY
REPUBLIC OF INDONESIA,

AGUSMAN signed.

ANNEX I
FINANCIAL SERVICES AUTHORITY CIRCULAR LETTER
REPUBLIC OF INDONESIA
NUMBER 35/SEOJK.06/2025
REGARDING
ASSESSMENT OF THE HEALTH LEVEL OF PAWN COMPANIES AND SHARIA PAWN COMPANIES

GUIDELINES FOR DETERMINING COMPOSITE HEALTH LEVEL RANKINGS FOR PAWN COMPANIES AND SHARIA PAWN COMPANIES Composite Ranking Company Condition Explanation PK-1 Very Healthy Reflects the Company's condition which is generally very healthy, thus assessed as very capable of facing significant negative influences from changes in business conditions and other external factors, reflected in factor rankings such as capital adequacy, loan receivables quality, profitability, liquidity, and management which are generally very good. In case of weaknesses, they are generally not significant. PK-2 Healthy Reflects the Company's condition which is generally healthy, thus assessed as capable of facing significant negative influences from changes in business conditions and other external factors, reflected in factor rankings such as capital adequacy, loan receivables quality, profitability, liquidity, and management which are generally good. In case of weaknesses, they are generally less significant. PK-3 Fairly Healthy Reflects the Company's condition which is generally fairly healthy, thus assessed as fairly capable of facing significant negative influences from changes in business conditions and other external factors, reflected in factor rankings such as capital adequacy, loan receivables quality, profitability, liquidity, and management which are generally fairly good. In case of weaknesses, they are generally fairly significant and if not successfully addressed well by management, may disrupt the Company's business continuity. PK-4 Unhealthy Reflects the Company's condition which is generally unhealthy, thus assessed as less capable of facing significant negative influences from changes in business conditions and other external factors, reflected in factor rankings such as capital adequacy, loan receivables quality, profitability, liquidity, and management which are generally less good. There are weaknesses which are generally significant and cannot be addressed well by management, disrupting the Company's business continuity. PK-5 Not Healthy Reflects the Company's condition which is generally not healthy, thus assessed as unable to face significant negative influences from changes in business conditions and other external factors, reflected in factor rankings such as capital adequacy, loan receivables quality, profitability, liquidity, and management which are generally not good. There are weaknesses which are generally very significant, requiring financial support from owners or funding from other parties to improve the Company's financial condition.

WORKSHEET FORMAT
HEALTH LEVEL ASSESSMENT FOR PAWN COMPANIES AND SHARIA PAWN COMPANIES
Company Name : ...........................................
Business Scope : Regency/City/Province/National *)
Year Position : ...........................................
Person in Charge
Name : ...........................................
Position : ...........................................
Telephone : ...........................................
Electronic mail (e-mail) : ...........................................

A. Health Level Assessment Results for Pawn Companies and Sharia Pawn Companies Assessment Factors Current Year Position Previous Year Position Ranking Analysis Ranking Analysis (a) (b) (c) (d) A. Capital Adequacy …. …. …. …. B. Loan Receivables Quality …. …. …. ….
C. Profitability
….
….
….
….
D. Liquidity
….
….
….
….
E. Management
….
….
….
….
Composite Ranking
….
….
….
….

signed.
Aat Windradi
B. Analysis of Health Level Assessment Results for Pawn Companies and Sharia Pawn Companies Analysis Analysis of the Company's overall condition is reflected in the five Health Level assessment factors as follows:

capital adequacy factor analysis;
loan receivables quality factor analysis;
profitability factor analysis;
liquidity factor analysis; and
management factor analysis, which among others includes the implementation of good corporate governance and risk management implementation.
Established in Jakarta on December 1, 2025
EXECUTIVE HEAD
OF FINANCING INSTITUTIONS SUPERVISOR,
VENTURE CAPITAL COMPANIES,
MICROFINANCE INSTITUTIONS, AND
OTHER FINANCIAL SERVICE INSTITUTIONS
FINANCIAL SERVICES
AUTHORITY,
AGUSMAN signed.

ANNEX II
FINANCIAL SERVICES AUTHORITY CIRCULAR LETTER
REPUBLIC OF INDONESIA
NUMBER 35/SEOJK.06/2025
REGARDING
ASSESSMENT OF THE HEALTH LEVEL OF PAWN COMPANIES AND SHARIA PAWN COMPANIES

Table II.A: Parameters or Indicators for Capital Adequacy Factor Assessment
Parameter or
Indicator
Capital Adequacy
Explanation a. Equity
Company Equity must be at least:
a. Rp1,000,000,000.00 (one billion rupiah) for regency/city business scope; b. Rp4,000,000,000.00 (four billion rupiah) for provincial business scope; or
c. Rp50,000,000,000.00 (fifty billion rupiah)
for national business scope. b. Equity Ratio compared to Paid-up Capital Company Equity compared to:
a. Paid-up Capital for Companies in the form of limited liability companies; or b. the sum of basic savings, mandatory savings, and grants for Companies in the form of cooperative legal entities, must be at least 50% (fifty percent).
c. Company Capital
Adequacy to
Anticipate
Potential
Losses.
Assessment of Company capital adequacy to anticipate potential losses.

Table II.B: Guidelines for Determining Capital Adequacy Factor Rankings
Ranking
Definition
Ranking 1
The Company has very adequate capital quality and adequacy relative to the Company's risk profile.
Companies included in ranking 1 meet all or most of the following example characteristics:
a. The Company meets at least 120% of the Equity requirements according to the business scope; b. Equity to Paid-up Capital ratio is at least 100% (one hundred percent);
c. The Company has a very adequate capital level, very capable of anticipating all risks faced, and supporting future business expansion; and
d. The Company has adequately anticipated potential losses according to the risk profile faced.
Ranking 2
The Company has adequate capital quality and adequacy relative to the Company's risk profile.
Companies included in ranking 2 meet all or most of the following example characteristics:
a. The Company meets greater than or equal to 110% (one hundred ten percent) and less than 120% (one hundred twenty percent) of the Equity requirements according to the business scope; b. Equity to Paid-up Capital ratio is greater than or equal to 75% (seventy-five percent) and less than 100% (one hundred percent);
c. The Company has an adequate capital level, capable of anticipating almost all risks faced, and supporting future business expansion; and
d. The Company has adequately anticipated potential losses according to the risk profile faced.
Ranking 3
The Company has fairly adequate capital quality and adequacy relative to the Company's risk profile.
Companies included in ranking 3 meet all or most of the following example characteristics:
a. The Company meets greater than or equal to 100% (one hundred percent) and less than 110% (one hundred ten percent) of the Equity requirements according to the business scope; b. Equity to Paid-up Capital ratio is greater than or equal to 50% (fifty percent) and less than 75% (seventy-five percent);

c. The Company has a fairly adequate capital level and is fairly capable of anticipating risks faced; and
d. The Company has fairly adequately anticipated potential losses according to the risk profile faced.
Ranking 4
The Company has less adequate capital quality and adequacy relative to the Company's risk profile.
Companies included in ranking 4 meet all or most of the following example characteristics:
a. Company Equity is greater than or equal to 75% (seventy-five percent) and less than 100% (one hundred percent) of the Equity requirements according to the business scope; b. Equity to Paid-up Capital ratio is greater than or equal to 0% (zero percent) and less than 50% (fifty percent);
c. The Company has a less adequate capital level and is less capable of anticipating all risks faced; and
d. The Company has anticipated potential losses according to the risk profile faced, but less adequately.
Ranking 5
The Company has inadequate capital quality and adequacy relative to the Company's risk profile.
Companies included in ranking 5 meet all or most of the following example characteristics:
a. Company Equity is less than 75% (seventy-five percent) of the Equity requirements according to the business scope; b. Equity to Paid-up Capital ratio is less than 0% (zero percent);
c. The Company has an inadequate capital level and is unable to anticipate all risks faced; and
d. The Company has anticipated potential losses according to the risk profile faced, but inadequately.

Table II.C: Capital Adequacy Factor Assessment Worksheet
PARAMETER
OR INDICATOR
EVALUATION COMPONENT
RANKING
EXPLANATION
(QUALITATIVE ANALYSIS)
(a)
(b)
(c)
(d)

CAPITAL ADEQUACY FACTOR
Adequacy, projection, and capital ability to anticipate risks a. Minimum equity must meet*)

Rp1,000,000,000.00 (one billion rupiah) for regency/city business scope;
Rp4,000,000,000.00 (four billion rupiah) for
provincial business scope; or
Rp50,000,000,000.00 (fifty billion rupiah) for
national business scope.
… ... b. Equity to Paid-up Capital ratio must be at least 50% (fifty percent).*) … ...
c. Company capital adequacy to anticipate
potential losses.
… ...
Capital Adequacy Factor Ranking …
Conclusion
Based on the analysis of all the above assessment criteria or indicators, it is concluded that:
strength of capital adequacy and capital management aspects:……
weakness of capital adequacy and capital management aspects:….

signed.
Aat Windradi
*) Until the December 2029 period, capital adequacy factor assessment for Companies with regency/city business scope regarding the parameters:
a. Minimum Equity; and b. Equity to Paid-up Capital ratio, can be filled with a minimum ranking of 3.
Established in Jakarta on December 1, 2025
EXECUTIVE HEAD OF SUPERVISOR
FOR FINANCING INSTITUTIONS,
VENTURE CAPITAL COMPANIES,
MICROFINANCE INSTITUTIONS AND
OTHER FINANCIAL SERVICE
INSTITUTIONS
FINANCIAL SERVICES AUTHORITY
REPUBLIC OF INDONESIA,

AGUSMAN signed.

ANNEX III
FINANCIAL SERVICES AUTHORITY CIRCULAR LETTER
REPUBLIC OF INDONESIA
NUMBER 35/SEOJK.06/2025
REGARDING
ASSESSMENT OF THE HEALTH LEVEL OF PAWN COMPANIES AND SHARIA PAWN COMPANIES

Table III.A: Parameters or Indicators for Loan Receivables Quality Factor Assessment
Parameter or
Indicator
Loan Receivables
Quality
Explanation
Loan Receivables Quality a. Gross Problematic
Loan Receivables
Ratio total outstanding problematic loan receivables total outstanding loan receivables What is meant by problematic loan receivables is Loans with poor, doubtful, and non-performing quality. What is meant by total outstanding loan receivables is the total net disbursement of pawn loans, net disbursement of fidusia loans, and gold financing disbursement (if any). b. Net Problematic Loan Receivables Ratio total outstanding problematic loan receivables − loan loss provision for problematic loan receivables total outstanding loan receivables What is meant by low-quality loan receivables is Loans with poor, doubtful, and non-performing quality according to applicable regulations.
c. Gross Low-Quality
Loan Receivables
Ratio total outstanding low-quality loan receivables total outstanding loan receivables What is meant by low-quality loan receivables is Loans with special attention, poor, doubtful, and non-performing quality according to applicable regulations. d. Net Low-Quality Loan Receivables Ratio total outstanding low-quality loan receivables − loan loss provision for low-quality loan receivables total outstanding loan receivables Risk Exposure Concentration a. Loan Receivables Ratio per Economic Sector total outstanding loan receivables per economic sector total outstanding loan receivables What is meant by loan receivables per economic sector is Loans to Customers per economic sector based on the applicable standard classification of Indonesian business fields.

b. Problematic Loan Receivables
Ratio per
Economic Sector total outstanding problematic loan receivables per economic sector total outstanding loan receivables per economic sector
c. Problematic Loan Receivables
Ratio per
Economic Sector total outstanding problematic loan receivables per economic sector total outstanding problematic loan receivables Policy and Procedure Adequacy Companies assess the adequacy of policies and procedures, among others, by considering the adequacy of loan disbursement policies and procedures owned according to regulations. Loan Disbursement Documentation Companies assess loan disbursement documentation, among others, by storing and documenting loan disbursement documents according to regulations. Problematic Loan Receivables Balance Handling Performance Problematic loan receivables balance handling performance is assessed, among others, by documents or supporting information that the Company can handle problematic loan receivables balances. Examples of supporting information include worksheets, among others, through calculations of restructured loan receivables and results of collateral sales.

Table III.B: Guidelines for Determining Loan Receivables Quality Factor Rankings
Ranking
Definition
Ranking
Companies included in ranking 1 meet the following:
a. disbursed loan receivables quality is categorized as performing; b. loan disbursement has very good quality;
c. net problematic loan receivables balance ratio is less than or equal to 2% (two percent);
d. loan disbursement portfolio is dominated by very low credit risk exposure; e. loan disbursement exposure is very well diversified; f. loan disbursement policy and procedure adequacy is very adequate; g. loan disbursement documentation is prepared and stored very well; and very good. Ranking Companies included in ranking 2 meet the following:
a. disbursed loan receivables quality is categorized as special attention; b. loan disbursement has good quality;
c. net problematic loan receivables balance ratio is greater than 2% (two percent) and less than or equal to 3% (three percent);
d. loan disbursement portfolio is dominated by low credit risk exposure; e. loan disbursement exposure is well diversified; f. loan disbursement policy and procedure adequacy is adequate; g. loan disbursement documentation is prepared and stored well; and good. Ranking Companies included in ranking 3 meet the following:
a. disbursed loan receivables quality is categorized as poor; b. loan disbursement has fairly good quality;
c. net problematic loan receivables balance ratio is greater than 3% (three percent) and less than or equal to 5% (five percent);
d. loan disbursement portfolio is dominated by fairly high credit risk exposure;

e. there is fairly significant loan disbursement concentration; f. loan disbursement policy and procedure adequacy is fairly adequate; g. loan disbursement documentation is prepared and stored fairly well; and fairly good. Ranking Companies included in ranking 4 meet the following:
a. disbursed loan receivables quality is categorized as doubtful; b. loan disbursement has poor quality;
c. net problematic loan receivables quality ratio is greater than 5% (five percent) and less than 20% (twenty percent);
d. loan disbursement portfolio is dominated by high credit risk exposure; e. there is significant loan disbursement concentration; f. loan disbursement policy and procedure adequacy is less adequate; g. loan disbursement documentation is prepared and stored less well; and poor. Ranking Companies included in ranking 5 meet the following:
a. disbursed loan receivables quality is categorized as non-performing; b. loan disbursement has very poor quality;
c. net problematic loan receivables quality ratio is at least 20% (twenty percent);
d. loan disbursement portfolio is dominated by very high credit risk exposure; e. there is very significant loan disbursement concentration; f. loan disbursement policy and procedure adequacy is inadequate; g. loan disbursement documentation is prepared and stored very poorly; and very poor.

Table III.C: Loan Receivables Quality Factor Assessment Worksheet
PARAMETER OR
INDICATOR
RANKING COMPONENT
EXPLANATION
(QUALITATIVE ANALYSIS)
(a)
(b)
(c)
(d)
2. LOAN RECEIVABLES QUALITY FACTOR
Loan Receivables
Quality a. gross problematic loan receivables ratio ...
... b. net problematic loan receivables ratio
...
...
c. gross low-quality loan receivables ratio
...
... d. net low-quality loan receivables ratio
...
...
Risk Exposure
Concentration a. loan receivables ratio per economic sector ...
... b. problematic loan receivables ratio per economic sector total loan receivables per economic sector ...
...
c. problematic loan receivables ratio per economic sector
total problematic loan receivables
...
...
Policy and Procedure
Adequacy
...
...
Loan Disbursement
Documentation
...
...
Problematic Loan
Receivables Balance
Handling Performance
Problematic loan receivables balance handling performance is assessed, among others, by documents or supporting information that the Company can handle problematic loan receivables balances, ... ...

PARAMETER OR
INDICATOR
RATING COMPONENT DESCRIPTION
(QUALITATIVE ANALYSIS) among others through the calculation of restructured Loan receivables and the results of the sale of Collateral Goods. Loan Receivable Quality Factor Rating … Conclusion Based on the analysis of all the above assessment criteria or indicators, it is concluded that:
A. Loan Receivable Quality

strength of the loan receivable quality aspect:……
weakness of the loan receivable quality aspect:…..
B. Risk Exposure Concentration
strength of the risk exposure concentration aspect:……
weakness of the risk exposure concentration aspect:…..
C. Adequacy of Policies and Procedures
strength of the adequacy of policies and procedures aspect:……
weakness of the adequacy of policies and procedures aspect:…..

signed.
Aat Windradi
Established in Jakarta on December 1, 2025
EXECUTIVE HEAD OF SUPERVISOR
OF FINANCING INSTITUTIONS,
VENTURE CAPITAL COMPANIES,
MICRO FINANCE INSTITUTIONS AND
OTHER FINANCIAL SERVICE INSTITUTIONS
FINANCIAL SERVICES AUTHORITY
REPUBLIC OF INDONESIA,

AGUSMAN
D. Loan Documentation

strength of the loan documentation aspect:…
weakness of the loan documentation aspect:…
E. Performance in Handling Problematic Loan Receivable Balances
strength of the performance in handling problematic loan receivable balances aspect: …
weakness of the performance in handling problematic loan receivable balances aspect: ….
signed.

APPENDIX IV
CIRCULAR LETTER OF THE FINANCIAL SERVICES AUTHORITY REPUBLIC OF INDONESIA NUMBER 35/SEOJK.06/2025 CONCERNING THE ASSESSMENT OF THE HEALTH LEVEL OF PAWN COMPANIES AND SHARIA PAWN COMPANIES

Table IV.A: Parameters or Indicators for Assessing the Profitability Factor
Parameter or
Indicator
Profitability
Description
Ability of Productive Assets to Generate Profit a. Return on asset (RoA) profit or loss before tax average total assets

Profit or loss before tax is calculated based on the amount of income minus the amount of expenses before deducting the estimate of income tax.
For the calculation of total assets, the average assets per end-of-month position for the last 12 (twelve) months are used. For example, for the March 2026 report position, the calculation method is as follows:
∑ assets April 2025 to March 2026
In the event that there is a Company that has operated for less than 12 (twelve months) since the business license was issued by the Financial Services Authority, the calculation of total assets uses the average assets per end-of-month position for the number of months that have been run. b. Return on equity (RoE) net profit or loss after tax average total Equity for the last 12 months
Net profit or loss is calculated based on the amount of income minus the amount of expenses after deducting the estimate of income tax.
For the calculation of total Equity, the average Equity per end-of-month position for the last 12 (twelve) months is used. For example, for the March 2026 report position, the calculation method is as follows:
∑ Equity April 2025 to March 2026
In the event that there is a Company that has operated for less than 12 (twelve months) since the business license was issued by the Financial Services Authority, the calculation of total Equity uses the average Equity per end-of-month position for the number of months that have been run.

Parameter or
Indicator
Profitability
Description
Operational Efficiency Level
Operating Expenses to
Operating Income
(BOPO) operating expenses of the Company operating income of the Company Details of operating income and operating expense accounts in the calculation of the operating expense to operating income ratio refer to the Circular Letter of the Financial Services Authority regarding the form, structure, and method of submitting periodic reports for pawn business actors and pawn companies or monthly reports for pawn companies and Sharia pawn companies.

Table IV.B: Guidelines for Determining the Profitability Factor Rating
Rating Definition
Rating 1 The Company has very adequate profitability, profit exceeds targets, and supports capital growth.
Companies included in Rating 1 meet all or most of the example characteristics as follows:
a. The Company has an ROA ratio of at least 2%; b. The Company has an ROE ratio of at least 4%; and
c. The Company has a BOPO of less than 80%.
Rating 2 The Company has adequate profitability, profit exceeds targets, and supports capital growth.
Companies included in Rating 2 meet all or most of the example characteristics as follows:
a. The Company has an ROA ratio of greater than or equal to 1.5% and less than 2%; b. The Company has an ROE ratio of greater than or equal to 3% and less than 4%; and
c. The Company has a BOPO of 80% to less than 90%.
Rating 3 The Company has fairly adequate profitability, profit meets targets, although there is pressure on profit performance that may cause a decline in profit but still sufficiently supports capital growth. Companies included in Rating 3 meet all or most of the example characteristics as follows:
a. The Company has an ROA ratio of greater than or equal to 1% and less than 1.5%; b. The Company has an ROE ratio of greater than or equal to 2% and less than 3%; and
c. The Company has a BOPO of 90% to less than 100%.
Rating 4 The Company has inadequate profitability, profit does not meet targets, and is estimated to remain in such conditions in the future, thus less supporting capital growth and the continuity of the Company's business. Companies included in Rating 4 meet all or most of the example characteristics as follows:
a. The Company has an ROA ratio of greater than or equal to 0% and less than 1%; b. The Company has an ROE ratio of greater than or equal to 0% and less than 2%; and
c. The Company has a BOPO of greater than or equal to 100% and less than 120%.

Rating 5 The Company has inadequate profitability, profit does not meet targets and is unreliable, and immediately requires an improvement in profit performance to ensure the continuity of the Company's business. Companies included in Rating 5 meet all or most of the example characteristics as follows:
a. The Company has an ROA ratio of less than 0%; b. The Company has an ROE ratio of less than 0%; and
c. The Company has a BOPO of at least 120%.

Table IV.C: Profitability Factor Assessment Worksheet
PARAMETER OR
INDICATOR
ASSESSMENT COMPONENT RATING DESCRIPTION
(QUALITATIVE ANALYSIS)
(a) (b) (c) (d)
3. PROFITABILITY FACTOR
Ability of Productive
Assets to
Generate Profit a. Return on asset (RoA) … ... b. Return on equity (RoE) … ...
Operational Efficiency
Level
Operating expenses to operating income (BOPO)
… ...
Profitability Factor Rating …

AGUSMAN
Conclusion
Based on the analysis of all the above assessment criteria or indicators, it is concluded that:
A. Ability of Productive Assets to Generate Profit

strength of the ability of productive assets to generate profit aspect:……
weakness of the ability of productive assets to generate profit aspect:…..
B. Operational Efficiency Level
strength of the operational efficiency level aspect:……
weakness of the operational efficiency level aspect:…..
signed.

APPENDIX V
CIRCULAR LETTER OF THE FINANCIAL SERVICES AUTHORITY REPUBLIC OF INDONESIA NUMBER 35/SEOJK.06/2025 CONCERNING THE ASSESSMENT OF THE HEALTH LEVEL OF PAWN COMPANIES AND SHARIA PAWN COMPANIES

Table V.A: Parameters or Indicators for Assessing the Liquidity Factor
Parameter or Indicator
Liquidity
Description
Ability to Meet Short-Term, Long-Term Obligations, and Potential Mismatch between Short-Term and Long-Term Obligations a. Short-term liquidity ratio Assessed from the Company's ability to meet financial obligations with a maturity of less than 12 (twelve) months. Measurement can be done by calculating the short-term liquidity ratio using the following formula:
short-term assets short-term liabilities
Short-term assets refer to financial assets with a maturity of less than 12 (twelve) months. Examples of financial assets include securities/Sharia securities, Loan/Financing disbursements, and assets other than Loan/Financing disbursements, and/or securities/Sharia securities held. Short-term liabilities refer to securities/Sharia securities issued, loans/funding received, and liabilities other than securities/Sharia securities issued, and/or loans/funding received with a maturity of less than 12 (twelve) months. b. Ability to meet long-term obligations Assessed from the Company's ability to meet financial obligations with a maturity of at least 12 (twelve) months. Measurement can be done by calculating the long-term liquidity ratio using the following formula:
non-current assets non-current liabilities
Non-current assets refer to financial assets with a maturity of at least 12 (twelve) months. Examples of financial assets include securities/Sharia securities, Loan/Financing disbursements, and assets other than Loan/Financing disbursements, and/or securities/Sharia securities held. Non-current liabilities refer to securities/Sharia securities issued, loans/funding received, and liabilities other than securities/Sharia securities issued, and/or loans/funding received with a maturity of at least 12 (twelve) months. Adequacy of Liquidity Management Policies Company liquidity management This includes the understanding of the Board of Directors and Board of Commissioners, liquidity management policies and procedures, planning, and assessment of liquidity adequacy.

Table VI.B: Guidelines for Determining the Liquidity Factor Rating
Rating Definition
Rating 1 Companies included in Rating 1 meet all or most of the example characteristics as follows:
a. The Company has a short-term liquidity ratio of at least 150% (one hundred fifty percent); b. has very adequate ability to meet long-term obligations; and
c. adequacy of liquidity management policies assessed from the understanding of the Board of Directors and Board of Commissioners, liquidity management policies and procedures, planning, and assessment of the Company's liquidity adequacy which is very adequate.
Rating 2 Companies included in Rating 2 meet all or most of the example characteristics as follows:
a. The Company has a short-term liquidity ratio greater than or equal to 130% (one hundred thirty percent) and less than 150% (one hundred fifty percent); b. The Company has adequate ability to meet long-term obligations; and
c. adequacy of liquidity management policies assessed from the understanding of the Board of Directors and Board of Commissioners, liquidity management policies and procedures, planning, and assessment of the Company's liquidity adequacy which is adequate.
Rating 3 Companies included in Rating 3 meet all or most of the example characteristics as follows:
a. The Company has a short-term liquidity ratio greater than or equal to 120% (one hundred twenty percent) and less than 130% (one hundred thirty percent); b. The Company has fairly adequate ability to meet long-term obligations; and
c. adequacy of liquidity management policies assessed from the understanding of the Board of Directors and Board of Commissioners, liquidity management policies and procedures, planning, and assessment of the Company's liquidity adequacy which is fairly adequate.
Rating 4 Companies included in Rating 4 meet all or most of the example characteristics as follows:
a. The Company has a short-term liquidity ratio greater than or equal to 100% (one hundred percent) and less than 120% (one hundred twenty percent); b. The Company has inadequate ability to meet long-term obligations; and
c. adequacy of liquidity management policies assessed from the understanding of the Board of Directors and Board of Commissioners, liquidity management policies and procedures, planning, and assessment of the Company's liquidity adequacy which is assessed as inadequate.
Rating 5 Companies included in Rating 5 meet all or most of the example characteristics as follows:
a. The Company has a short-term liquidity ratio less than 100% (one hundred percent); b. The Company has inadequate ability to meet long-term obligations; and
c. adequacy of liquidity management policies assessed from the understanding of the Board of Directors and Board of Commissioners, liquidity management policies and procedures, planning, and assessment of the Company's liquidity adequacy which is assessed as inadequate.

Table VI.C: Liquidity Factor Assessment Worksheet
PARAMETER OR INDICATOR ASSESSMENT COMPONENT RATING DESCRIPTION (QUALITATIVE ANALYSIS) (a) (b) (c) (d)
4. LIQUIDITY FACTOR
Ability to Meet
Short-Term, Long-Term Obligations, and
Potential Mismatch between Short-Term and
Long-Term Obligations a. Short-term liquidity ratio … ... b. Ability to meet long-term obligations … ...
Adequacy of Liquidity Management Policies ... ...
Liquidity Factor Rating …
Conclusion
Based on the analysis of all the above assessment criteria or indicators, it is concluded that:
A. Ability to Meet Short-Term, Long-Term Obligations, and Potential Mismatch between Short-Term and Long-Term Obligations

strength of the ability to meet short-term, long-term obligations, and potential mismatch between short-term and long-term obligations aspect:……
weakness of the ability to meet short-term, long-term obligations, and potential mismatch between short-term and long-term obligations aspect:…..

AGUSMAN
B. Adequacy of Liquidity Management Policies

strength of the adequacy of liquidity management policies aspect:……
weakness of the adequacy of liquidity management policies aspect:…..
signed.

APPENDIX VI
CIRCULAR LETTER OF THE FINANCIAL SERVICES AUTHORITY REPUBLIC OF INDONESIA NUMBER 35/SEOJK.06/2025 CONCERNING THE ASSESSMENT OF THE HEALTH LEVEL OF PAWN COMPANIES AND SHARIA PAWN COMPANIES

Table VI.A: Parameters or Indicators for Assessing the Management Factor
Parameter or Indicator
Management
Description
Assessment of:

General Management Quality, including Implementation of Commitments to the Financial Services Authority or Other Parties; and
Company Compliance with Sharia Principles and Implementation of Social Functions, for Companies conducting business activities based on Sharia Principles,
is conducted by assessing the implementation of good corporate governance by the Company's management.
Companies use the assessment of the implementation of good corporate governance which results in a good corporate governance rating reported through the assessment of the implementation of good corporate governance referring to the Circular Letter of the Financial Services Authority regarding the reporting of good corporate governance for financing institutions, venture capital companies, micro finance institutions, and other financial service institutions. Assessment of:
Implementation of Risk Management, especially Management's Understanding of Company Risks; and
Compliance of the Operator with Sharia Principles and Implementation of Social Functions, for Companies conducting business activities based on Sharia Principles,
is conducted by assessing the Company's implementation of effective risk management.
Companies use the composite rating of the risk profile assessment results which results in a risk rating reported through the risk profile assessment report referring to the Regulation of the Members of the Board of Commissioners of the Financial Services Authority regarding guidelines for the implementation of risk management for financing institutions, venture capital companies, micro finance institutions, and other financial service institutions.

Table VI.B: Management Factor Assessment Worksheet
Rating Definition Rating
Rating
Reflects that the Company's management has implemented good corporate governance and risk management that is generally very good. This is reflected in the very adequate fulfillment of good corporate governance principles and risk management implementation. In the event that there are weaknesses in the implementation of good corporate governance principles and risk management implementation, these weaknesses are generally not significant and can be immediately corrected by the Company's management. Rating Reflects that the Company's management has implemented good corporate governance and risk management that is generally good. This is reflected in the adequate fulfillment of good corporate governance principles and risk management implementation. In the event that there are weaknesses in the implementation of good corporate governance principles and risk management implementation, these weaknesses are generally less significant and can be resolved with normal actions by the Company's management. Rating Reflects that the Company's management has implemented good corporate governance and risk management that is generally fairly good. This is reflected in the fairly adequate fulfillment of good corporate governance principles and risk management implementation. In the event that there are weaknesses in the implementation of good corporate governance principles and risk management implementation, these weaknesses are generally quite significant and require considerable attention from the Company's management. Rating Reflects that the Company's management has implemented good corporate governance and risk management that is generally inadequate. This is reflected in the inadequate fulfillment of good corporate governance principles and risk management implementation. There are weaknesses in the implementation of good corporate governance principles and risk management implementation, which are generally significant and require comprehensive correction by the Company's management. Rating Reflects that the Company's management has implemented good corporate governance and risk management that is generally poor. This is reflected in the inadequate fulfillment of good corporate governance principles and risk management implementation. There are weaknesses in the implementation of good corporate governance principles and risk management implementation, which are generally very significant and difficult to correct by the Company's management.

Table VI.C: Management Factor Assessment Worksheet
PARAMETER
OR
INDICATOR
COMPONENT RATING DESCRIPTION
(QUALITATIVE ANALYSIS)
(a) (b) (c) (d)
5. MANAGEMENT FACTOR
Assessment of:

General Management Quality, including Implementation of Commitments to the Financial Services Authority or Other Parties; and
Company Compliance with Sharia Principles and Implementation of Social Functions, for Companies conducting business activities based on Sharia Principles,
is conducted by assessing the implementation of good corporate governance by the Company's management.
Result of the good corporate governance rating reported through the assessment of the implementation of good corporate governance … ... Assessment of:
Implementation of Risk Management, especially Management's Understanding of Company Risks; and
Compliance of the Operator with Sharia Principles and Implementation of Social Functions, for Companies conducting business activities based on Sharia Principles,
is conducted by assessing the Company's implementation of effective risk management.
Result of the risk profile assessment which results in a risk rating reported through the risk profile assessment report.
… ...
Management Factor Rating … …

AGUSMAN
Conclusion
Based on the analysis of all the above assessment parameters or indicators, it is concluded that …………………………………………………………………………………………… …………………………………………………………………………………………… …………………………………………………………………………………………… …………………………………………………………………………………………… …………………………………………………………………………………………… …………………………….…………………………….………………………………. signed.

Circular Letter of the Financial Services Authority Number 35/SEOJK.06/2025 on the Assessment of the Health Level of Pawn Companies and Sharia Pawn Companies

Lineage: In force

Timeline