FINANCIAL SERVICES AUTHORITY REGULATION

REPUBLIC OF INDONESIA

NUMBER 39 OF 2025

CONCERNING

PROCEDURES FOR COLLECTING ADMINISTRATIVE SANCTIONS IN THE FORM OF FINES IN

THE FINANCIAL SERVICES SECTOR

BY THE GRACE OF THE ALMIGHTY GOD,

THE BOARD OF COMMISSIONERS OF THE FINANCIAL SERVICES AUTHORITY,

Considering: that in order to implement the provisions of Article 31 paragraph (5) of Government Regulation Number 41 of 2024 concerning the Work Plan and Budget of the Financial Services Authority and Levies in the Financial Services Sector and Article 16 paragraph (2) of Financial Services Authority Regulation Number 2 of 2025 concerning Procedures for Implementing Levies in the Financial Services Sector and Other Receipts, as well as to strengthen the authority of the Financial Services Authority in implementing the management of receipts from administrative sanctions in the form of fines as part of non-tax state receipts originating from other receipts, it is necessary to establish a Financial Services Authority Regulation concerning Procedures for Collecting Administrative Sanctions in the Form of Fines in the Financial Services Sector;

Considering: 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 the 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. Government Regulation Number 41 of 2024 concerning the Work Plan and Budget of the Financial Services Authority and Levies in the Financial Services Sector (State Gazette of the Republic of Indonesia Year 2024 Number 210, Supplement to the State Gazette of the Republic of Indonesia Number 6993);
3. Financial Services Authority Regulation Number 2 of 2025 concerning Procedures for Implementing Levies in the Financial Services Sector and Other Receipts (State Gazette of the Republic of Indonesia Year 2025 Number 6/OJK, Supplement to the State Gazette of the Republic of Indonesia Number 136/OJK);

DECIDING:

Establishing: FINANCIAL SERVICES AUTHORITY REGULATION CONCERNING PROCEDURES FOR COLLECTING ADMINISTRATIVE SANCTIONS IN THE FORM OF FINES IN THE FINANCIAL SERVICES SECTOR.

CHAPTER I

GENERAL PROVISIONS

Article 1

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

1. Party means an individual, legal entity, company, joint venture, association, or organized group.
2. Financial Services Sector means the banking sector, capital market appraisal, derivative finance, carbon exchange, insurance, guarantee, pension fund, financing institution, venture capital company, microfinance institution, other financial service institutions, financial sector technology innovation, digital financial assets, and crypto assets, which are regulated and supervised by the Financial Services Authority.
3. Administrative Sanctions in the Form of Fines, hereinafter abbreviated as SABD, are sanctions in the form of an obligation to pay a certain amount of money to the Financial Services Authority as a result of violations of laws and regulations in the financial services sector, which constitute other receipts as regulated in Government Regulations regarding the Work Plan and Budget of the Financial Services Authority and Levies in the Financial Services Sector.
4. Interest means a certain amount of money that arises and must be paid by each Party subject to SABD as a result of the failure to fulfill the fine payment obligation within the established time limit.

CHAPTER II

PAYMENT OBLIGATIONS AND COLLECTION OF SABD

First Section

Payment Obligations

Article 2

The Financial Services Authority establishes the collection of SABD in accordance with the provisions regulated in Financial Services Authority Regulations.

Article 3

(1) Parties subject to SABD are obligated to make payments to the Financial Services Authority by:
a. depositing into the Financial Services Authority's bank account; or b. other payments determined by the Financial Services Authority.
(2) The implementation of payment as referred to in paragraph (1) letter a must be carried out within a maximum period of 30 (thirty) days after the SABD letter is established or the Financial Services Authority's response letter regarding the objection request is established. (3) For each day of delay in paying SABD from the time limit as referred to in paragraph (2), interest is charged at 2% (two percent) per month of the amount of SABD established by the Financial Services Authority, and at most 48% (forty-eight percent) of the amount of SABD established by the Financial Services Authority, with the provision that a fraction of a month is calculated as 1 (one) month. (4) Delay in paying Interest as referred to in paragraph (3) is no longer subject to fine and/or interest sanctions. (5) The payment mechanism for SABD as referred to in paragraph (1) is carried out in accordance with Financial Services Authority Regulations regarding procedures for implementing levies in the financial services sector and other receipts.

Second Section

Collection of SABD

Article 4

(1) In the event that SABD is not paid in full within the time limit as referred to in Article 3 paragraph (2), the Financial Services Authority issues a first warning letter to immediately settle SABD and Interest within a maximum period of 30 (thirty) days after the end of the SABD payment time limit. (2) In the event that SABD and/or Interest is not paid in full within the time limit as referred to in paragraph (1), the Financial Services Authority issues a second warning letter to the Party subject to SABD to immediately settle SABD and/or Interest within a maximum period of 30 (thirty) days after the end of the time limit for the first warning letter as referred to in paragraph (1). (3) In the event that SABD and/or Interest is not paid in full within the time limit as referred to in paragraph (2), the Financial Services Authority issues a third warning letter to the Party subject to SABD to immediately settle SABD and/or Interest within a maximum period of 30 (thirty) days after the end of the time limit for the second warning letter as referred to in paragraph (2). (4) In the event that SABD and/or Interest is not paid in full within the time limit as referred to in paragraph (3), the Financial Services Authority adds information links in the form of debt data of the Party subject to SABD in the financial information service system and records of the Party subject to SABD in the information system of actors in the financial services sector after the end of the time limit for the third warning letter as referred to in paragraph (3). (5) Parties subject to SABD who do not pay or delay paying SABD may be subject to additional administrative sanctions and/or specific actions for a maximum period of 1 (one) year calculated from the date the SABD letter was established. (6) Additional administrative sanctions as referred to in paragraph (5) include:
a. written warnings or written notices; b. reduction of health level;
c. cancellation of competence and propriety results;
d. restrictions on products and/or services and/or business activities; e. revocation of product and/or service licenses; f. orders for management replacement; g. listing of management in the list of tainted persons; h. cancellation of approvals, registrations, and ratifications;
i. prohibitions on becoming controlling shareholders, boards of directors, boards of commissioners, sharia supervisory boards, and/or managers;
j. prohibitions on issuing products or carrying out new activities; k. freezing of products and/or services and/or business activities;
l. revocation of business licenses; and/or
m. revocation of licenses for individuals.
(7) The issuance of the first warning letter, second warning letter, third warning letter, and addition of information links of Parties subject to SABD in the financial information service system and records of Parties subject to SABD in the information system of actors in the financial services sector constitute collection with optimization efforts as a prerequisite for categorizing bad debts. (8) The imposition of additional administrative sanctions and/or specific actions as referred to in paragraph (5) can be considered part of optimization efforts as referred to in paragraph (7). (9) The Financial Services Authority may announce the imposition of additional administrative sanctions as referred to in paragraph (5) to the public.

CHAPTER III

OBJECTION REQUESTS, REFUND OF OVERPAYMENT, AND MANAGEMENT OF BAD DEBTS

First Section

Objection Requests

Article 5

(1) Parties subject to SABD may file objections to SABD established by the Financial Services Authority.
(2) Provisions regarding the submission of objection requests for SABD are determined by the Financial Services Authority.

Article 6

(1) In the event that Parties subject to SABD submit objection requests to the Financial Services Authority, such Parties must first settle SABD in the Financial Services Authority's receipt information system.
(2) In the event that objection requests as referred to in paragraph (1) are accepted in full or accepted in part, the Financial Services Authority returns the excess payment of SABD based on requests from Parties subject to SABD. (3) The return of excess payments as referred to in paragraph (2) also applies if Parties subject to SABD pay more than the value established based on court decisions that have permanent legal force.

Article 7

(1) In the event that the Financial Services Authority's response decides otherwise, thereby creating an obligation to pay SABD exceeding what has been established, Parties submitting objection requests are obligated to pay the shortfall of SABD according to the value established in the Financial Services Authority's response letter regarding the SABD objection request. (2) Payments for the shortfall of SABD as referred to in paragraph (1) must be made by means as referred to in Article 3 paragraph (1) no later than 30 (thirty) days after the establishment of the Financial Services Authority's response letter regarding the SABD objection request.

Second Section

Refund of Overpayment

Article 8

(1) Parties subject to SABD may submit requests for the refund of overpayments by submitting letters requesting the refund of overpayments.
(2) Letters requesting the refund of overpayments as referred to in paragraph (1) must be accompanied by:
a. letters establishing the imposition of SABD, Financial Services Authority response letters regarding SABD objection requests, and/or court decisions that have permanent legal force; b. payment proofs; and
c. destination bank account numbers for fund refunds.
(3) Refunds of overpayments as referred to in paragraph (1) are implemented within a maximum period of 10 (ten) working days after the complete receipt of request documents.
(4) In the event that requests for the refund of overpayments submitted by Parties subject to SABD are not accompanied by documents as referred to in paragraph (2), the letters requesting the refund of overpayments are considered not yet submitted to the Financial Services Authority. (5) The time limit for submitting requests for refunds of overpayments as referred to in paragraph (2) does not exceed the time limit as regulated in Government Regulations regarding the Work Plan and Budget of the Financial Services Authority and Levies in the Financial Services Sector.

Third Section

Management of Bad Debts

Article 9

The Financial Services Authority categorizes SABD payment obligations as bad debts if:
a. Parties subject to SABD do not settle SABD payment obligations and/or Interest within a maximum period of 1 (one) year since the end of the payment time limit established in the SABD letter or the Financial Services Authority's response letter regarding the objection request; and b. collection with optimization efforts according to the Financial Services Authority's authority as referred to in Article 4 paragraph (7) has been carried out.

Article 10

(1) In the event that SABD and/or Interest is categorized as bad debts as referred to in Article 9, the Financial Services Authority may request the settlement of bad debts through letters requesting debt management to the National Debt Management Committee according to criteria and processes for receiving debts based on provisions of laws and regulations regarding the management of state debts. (2) SABD categorized as bad debts for which the settlement of bad debts has been requested to the National Debt Management Committee as referred to in paragraph (1) is not subject to Interest as referred to in Article 3 paragraph (3). (3) Payments for the settlement of bad debts that have been handed over for management to the National Debt Management Committee as referred to in paragraph (1) are made through the National Debt Management Committee.

Article 11

In the event that the Financial Services Authority's bad debts do not meet the criteria and processes for receiving debts based on provisions of laws and regulations regarding the management of state debts, the Financial Services Authority carries out the settlement of bad debts itself.

Article 12

(1) In the event that Parties subject to SABD do not fulfill their obligations as referred to in Article 9 and as an effort to settle bad debts themselves as referred to in Article 11, the Financial Services Authority sends summons letters delivered directly to Parties subject to SABD. (2) In the event that summons letters as referred to in paragraph (1) cannot be delivered directly to Parties who do not settle SABD, the Financial Services Authority may send summons letters via post or other delivery services with proof of delivery, no later than 5 (five) working days after the date of the summons letter. (3) Besides efforts to settle bad debts themselves as referred to in paragraph (1) and paragraph (2), the Financial Services Authority may carry out collection efforts with the assistance of third parties and/or efforts through court lawsuits.

Article 13

(1) In carrying out the settlement of bad debts for SABD, the Financial Services Authority has the authority to write off and write off bad debts for which collection optimization efforts have been carried out.
(2) Provisions regarding procedures for writing off and writing off bad debts are determined by the Financial Services Authority.

CHAPTER IV

OTHER PROVISIONS

Article 14

(1) To maintain financial system stability and/or face economic crisis threats, the Financial Services Authority may establish the suspension of interest imposition as referred to in Article 3 paragraph (3) and collection with optimization efforts as referred to in Article 4 paragraph (7). (2) The time limit for suspending collection optimization efforts as referred to in paragraph (1) is determined by the Financial Services Authority.

CHAPTER V

TRANSITIONAL PROVISIONS

Article 15

At the time this Financial Services Authority Regulation takes effect, SABD established before the implementation of this Financial Services Authority Regulation, the collection of SABD and objections to SABD are implemented in accordance with Financial Services Authority Regulation Number 4/POJK.04/2014 concerning Procedures for Collecting Administrative Sanctions in the Form of Fines in the Financial Services Sector as amended several times lastly by Financial Services Authority Regulation Number 36/POJK.02/2020 concerning the Third Amendment to Financial Services Authority Regulation Number 4/POJK.04/2014 concerning Procedures for Collecting Administrative Sanctions in the Form of Fines in the Financial Services Sector.

CHAPTER VI

CLOSING PROVISIONS

Article 16

At the time this Financial Services Authority Regulation takes effect:
a. Number 14 of Regulation Number XIV.B.2 which is an Appendix of the Chairman of Bapepam and LK Decision Number: KEP- 642/BL/2012 dated December 5, 2012 concerning Submission of Objection Requests for Sanctions; b. Financial Services Authority Regulation Number 4/POJK.04/2014 concerning Procedures for Collecting Administrative Sanctions in the Form of Fines in the Financial Services Sector (State Gazette of the Republic of Indonesia Year 2014 Number 67, Supplement to the State Gazette of the Republic of Indonesia Number 5522);
c. Financial Services Authority Regulation Number 7/POJK.04/2015 concerning Amendments to Financial Services Authority Regulation Number 4/POJK.04/2014 concerning Procedures for Collecting Administrative Sanctions in the Form of Fines in the Financial Services Sector (State Gazette of the Republic of Indonesia Year 2015 Number 98, Supplement to the State Gazette of the Republic of Indonesia Number 5695);
d. Financial Services Authority Regulation Number 26/POJK.02/2018 concerning the Second Amendment to Financial Services Authority Regulation Number 4/POJK.04/2014 concerning Procedures for Collecting Administrative Sanctions in the Form of Fines in the Financial Services Sector (State Gazette of the Republic of Indonesia Year 2018 Number 242, Supplement to the State Gazette of the Republic of Indonesia Number 6273); e. Financial Services Authority Regulation Number 36/POJK.02/2020 concerning the Third Amendment to Financial Services Authority Regulation Number 4/POJK.04/2014 concerning Procedures for Collecting Administrative Sanctions in the Form of Fines in the Financial Services Sector (State Gazette of the Republic of Indonesia Year 2020 Number 140, Supplement to the State Gazette of the Republic of Indonesia Number 6521); and f. Article 115 paragraph (9) of Financial Services Authority Regulation Number 22 of 2023 concerning Consumer and Community Protection in the Financial Services Sector (State Gazette of the Republic of Indonesia Year 2023 Number 40/OJK, Supplement to the State Gazette of the Republic of Indonesia Number 62/OJK), are revoked and declared invalid.

Article 17

This Financial Services Authority Regulation takes effect on the date of enactment.

In order for everyone to know it, ordering the enactment of this Financial Services Authority Regulation by placing it in the State Gazette of the Republic of Indonesia.

Established in Jakarta on December 19, 2025

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

MAHENDRA SIREGAR

Enacted in Jakarta on [Date]

MINISTER OF LAW OF THE REPUBLIC OF INDONESIA,

SUPRATMAN ANDI AGTAS

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

EXPLANATION

OF

FINANCIAL SERVICES AUTHORITY REGULATION

REPUBLIC OF INDONESIA

NUMBER 39 OF 2025

CONCERNING

PROCEDURES FOR COLLECTING ADMINISTRATIVE SANCTIONS IN THE FORM OF FINES IN

THE FINANCIAL SERVICES SECTOR

I. GENERAL

The development of the dynamic financial services industry has led to the need for adjustments in regulations in the Financial Services Sector to align with the needs of strengthening the Financial Services Authority's institutional framework and managing non-tax state receipts originating from other receipts, specifically administrative sanctions in the form of fines. Provisions regarding the management of other receipts originating from administrative sanctions in the form of fines have been regulated in Government Regulation Number 41 of 2024 concerning the Work Plan and Budget of the Financial Services Authority and Levies in the Financial Services Sector.

Provisions regarding procedures for collecting administrative sanctions in the form of fines in the financial services sector currently in effect still refer to Financial Services Authority Regulation Number 4/POJK.04/2014 concerning Procedures for Collecting Administrative Sanctions in the Form of Fines in the Financial Services Sector as amended several times lastly by Financial Services Authority Regulation Number 36/POJK.02/2020 concerning the Third Amendment to Financial Services Authority Regulation Number 4/POJK.04/2014 concerning Procedures for Collecting Administrative Sanctions in the Form of Fines in the Financial Services Sector and are not aligned with regulations in Government Regulation Number 41 of 2024 concerning the Work Plan and Budget of the Financial Services Authority and Levies in the Financial Services Sector and Financial Services Authority Regulation Number 2 of 2025 concerning Procedures for Implementing Levies in the Financial Services Sector and Other Receipts, so it is necessary to regulate them again so that the collection of administrative sanctions in the form of fines is implemented more effectively.

Based on these considerations, the Financial Services Authority needs to regulate again the procedures for collecting administrative sanctions in the form of fines in the Financial Services Sector. This refinement is expected to support the optimization of the collection of administrative sanctions in the form of fines, strengthen the authority of the Financial Services Authority, and increase the compliance of financial services business actors with laws and regulations.

Generally, this Financial Services Authority Regulation contains main materials arranged systematically, including regarding payment obligations and optimization of SABD collection, objection requests, refunds of overpayments, and management of bad debts.

II. ARTICLE BY ARTICLE

Article 1

Clear enough.

Article 2

Clear enough.

Article 3

Paragraph (1)

Clear enough.

Paragraph (2)

Clear enough.

Paragraph (3)

What is meant by "per month" is 30 (thirty) calendar days after the SABD letter is established or 30 (thirty) calendar days after the response letter regarding the objection request is established by the Financial Services Authority. Days of delay less than 30 (thirty) days are calculated as 1 (one) month of delay.

Paragraph (4)

Clear enough.

Paragraph (5)

Clear enough.

Article 4

Paragraph (1)

Clear enough.

Paragraph (2)

Clear enough.

Paragraph (3)

Clear enough.

Paragraph (4)

The third warning letter contains information on the addition of information links in the form of mandatory debt data in the financial information service system and the information system of actors in the financial services sector.

Paragraph (5)

Specific actions include among others the postponement of the issuance of effective statements other than initial public offerings and the postponement of the issuance of licenses for individuals.

Paragraph (6)

Clear enough.

Paragraph (7)

Clear enough.

Paragraph (8)

Clear enough.

Paragraph (9)

Clear enough.

Article 5

Paragraph (1)

Provisions regarding the submission of objection requests for SABD include among others:
a. Regulation Number XIV.B.2 which is an Appendix of the Chairman of Bapepam and LK Decision Number: KEP642/BL/2012 dated December 5, 2012 concerning Submission of Objection Requests for Sanctions; b. Financial Services Authority Regulation Number 22 of 2023 concerning Consumer and Community Protection in the Financial Services Sector; and
c. Financial Services Authority Regulation Number 17 of 2017 as amended by Financial Services Authority Regulation Number 37 of 2024 concerning Procedures and Procedures for Imposing Administrative Sanctions in the Insurance Sector and Blocking Assets of Insurance Companies, Sharia Insurance Companies, Reinsurance Companies, and Sharia Reinsurance Companies.

Paragraph (2)

Clear enough.

Article 6

Clear enough.

Article 7

Clear enough.

Article 8

Clear enough.

Article 9

Clear enough.

Article 10

Paragraph (1)

Clear enough.

Paragraph (2)

Examples:

1. The Financial Services Authority hands over bad debts to the National Debt Management Committee in the 15th month after SABD is established, so Interest is only charged up to a maximum of 14 (fourteen) months or equivalent to 28% (twenty-eight percent) with a calculation of 2% (two percent) multiplied by 14 (fourteen) months of delay.
2. The Financial Services Authority hands over bad debts to the National Debt Management Committee beyond the 24 (twenty-four) month time limit or as an example handed over in the 36th (thirty-six) month after SABD is established, so Interest is charged at most 48% (forty-eight percent).

Paragraph (3)

Clear enough.

Article 11

Clear enough.

Article 12
Paragraph (1)
Is clear enough.
Paragraph (2)
Conditions causing summonses to not be delivered directly include the cost of delivering the summons being higher than the potential revenue obtained by the Financial Services Authority.
Paragraph (3)
Collection with third parties includes cooperation with liquidators, curators, the prosecutor's office, and/or other government institutions.

Article 13
Is clear enough.

Article 14
Paragraph (1)
What is meant by "maintaining financial system stability and/or facing economic crisis threats" is an effort that must be made to prevent conditions where the financial system fails to perform its functions and roles effectively and efficiently, indicated by worsening various economic and financial indicators such as very high exchange rate depreciation in a short time, a very significant decline in economic growth, and/or a significant surge in non-performing loans in the financial services industry. Example: The Financial Services Authority may determine the postponement of issuing warning letters and imposing interest, for example, during the Coronavirus Disease 2019 (Covid-19) pandemic. Paragraph (2) Is clear enough.

Article 15
Is clear enough.

Article 16
Is clear enough.

Article 17
Is clear enough.

SUPPLEMENT TO THE STATE GAZETTE OF THE REPUBLIC OF INDONESIA NUMBER ⸙