Submission of Reports on Ownership or Changes in Ownership of Shares of Public Companies and Reports on Pledging Activities of Public Company Shares Electronically

To:

1. The Board of Directors of PT Kustodian Sentral Efek Indonesia;
2. The Board of Directors of PT Bursa Efek Indonesia;
3. The Board of Directors of Public Companies;
4. The Board of Directors of Securities Companies Conducting Business as Securities Brokers;
5. The Board of Directors of Securities Administration Offices; and
6. The Board of Directors of Custodian Banks,

At your respective locations

COPY

CIRCULAR LETTER OF THE FINANCIAL SERVICES AUTHORITY REPUBLIC OF INDONESIA NUMBER 10/SEOJK.04/2025

CONCERNING

SUBMISSION OF REPORTS ON OWNERSHIP OR CHANGES IN OWNERSHIP OF SHARES OF PUBLIC COMPANIES AND REPORTS ON PLEDGING ACTIVITIES OF PUBLIC COMPANY SHARES ELECTRONICALLY

In accordance with the mandate of Article 7 paragraph (4) and to follow up on the provisions in Article 5 of the Financial Services Authority Regulation Number 4 of 2024 concerning Reports on Ownership or Changes in Ownership of Shares of Public Companies and Reports on Pledging Activities of Public Company Shares (State Gazette of the Republic of Indonesia Year 2024 Number 6/OJK, Additional State Gazette of the Republic of Indonesia Number 74/OJK), it is necessary to regulate implementation provisions regarding the electronic system for the submission and publication of reports on ownership or changes in ownership of shares of public companies and reports on pledging activities of public company shares in this Financial Services Authority Circular Letter as follows:

I. GENERAL PROVISIONS

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

1. Public Company means an issuer that has conducted a public offering of equity securities or a public company.
2. Issuer means the party conducting a public offering.
3. Party means an individual, legal entity, company, joint venture, association, or organized group.
4. Stock Exchange means the organizer of the market in the capital market for exchange transactions.
5. Depository and Clearing Agency means a party that: a. conducts central custodian activities for custodian banks, securities companies, and other parties; and b. provides other services that can be applied to support inter-market activities.
6. Pledging Activities of Public Company Shares means activities conducted by shareholders who pledge shares by mortgaging and/or pawning Public Company Shares they own.
7. Report means the report as referred to in Financial Services Authority Regulation Number 4 of 2024 concerning Reports on Ownership or Changes in Ownership of Shares of Public Companies and Reports on Pledging Activities of Public Company Shares.
8. Electronic Reporting System Provider means a Party designated by the Financial Services Authority to provide, manage, and receive reports on ownership of shares or changes in ownership of shares of Public Companies and reports on pledging activities of Public Company Shares.
9. Electronic Report Publication System Provider means a Party designated by the Financial Services Authority to publish reports on ownership of shares or changes in ownership of shares of Public Companies.

II. ELECTRONIC SUBMISSION OF REPORTS

1. The following Parties: a. members of the Board of Directors or members of the Board of Commissioners who own shares with voting rights, directly or indirectly; b. any Party owning shares with voting rights of at least 5% (five percent) of the shares of a Public Company, directly or indirectly; c. controllers of Public Companies who own shares with voting rights over the shares of Public Companies, directly or indirectly; and/or d. any Party as referred to in letter b who experiences a decrease in the percentage of ownership of shares with voting rights to less than 5% (five percent), are required to submit reports on ownership or changes in ownership of shares of Public Companies to the Financial Services Authority in accordance with the provisions of Financial Services Authority Regulation Number 4 of 2024 concerning Reports on Ownership or Changes in Ownership of Shares of Public Companies and Reports on Pledging Activities of Public Company Shares.

2. Shareholders conducting Pledging Activities of Public Company Shares are required to submit reports on Pledging Activities of Public Company Shares to the Financial Services Authority in accordance with the provisions of Financial Services Authority Regulation Number 4 of 2024 concerning Reports on Ownership or Changes in Ownership of Shares of Public Companies and Reports on Pledging Activities of Public Company Shares.

3. Submission of Reports in this Financial Services Authority Circular Letter includes: a. reports on ownership or changes in ownership of shares of Public Companies as referred to in Article 2 paragraph (1), paragraph (2), and paragraph (3) of Financial Services Authority Regulation Number 4 of 2024 concerning Reports on Ownership or Changes in Ownership of Shares of Public Companies and Reports on Pledging Activities of Public Company Shares; and b. reports on Pledging Activities of Public Company Shares as referred to in Article 6 paragraph (1) of Financial Services Authority Regulation Number 4 of 2024 concerning Reports on Ownership or Changes in Ownership of Shares of Public Companies and Reports on Pledging Activities of Public Company Shares, submitted to the Financial Services Authority through the electronic system provided by the Electronic Reporting System Provider.

4. Submission of Reports as referred to in number 3 is done promptly, at the latest 3 (three) business days from: a. the occurrence of ownership of voting rights over shares or any change in ownership of voting rights over shares of Public Companies; or b. the signing of agreements or arrangements regarding pledging activities of Public Company Shares that cause the conditions referred to in Article 6 paragraph (2) of Financial Services Authority Regulation Number 4 of 2024 concerning Reports on Ownership or Changes in Ownership of Shares of Public Companies and Reports on Pledging Activities of Public Company Shares to be met.

5. In the event that the Party as referred to in number 1 grants a written power of attorney to another party to report ownership of voting rights over shares and any changes in ownership of voting rights over shares of Public Companies, the recipient of the power of attorney submits the Report through the electronic system provided by the Electronic Reporting System Provider.

III. ELECTRONIC REPORTING SYSTEM PROVIDER

1. In providing the electronic reporting system, the Financial Services Authority designates the Depository and Clearing Agency as the Electronic Reporting System Provider.

2. In providing, managing, and receiving Reports, the Electronic Reporting System Provider: a. receives Reports submitted by Parties as referred to in Roman numeral II number 1; b. submits Reports as referred to in letter a to:

   1. the Financial Services Authority in order to fulfill the provisions of Financial Services Authority Regulation Number 4 of 2024 concerning Reports on Ownership or Changes in Ownership of Shares of Public Companies and Reports on Pledging Activities of Public Company Shares; and
   2. the Stock Exchange in order to publish the Reports; c. establishes guidelines for the use of the electronic reporting system; d. maintains the confidentiality and security of access limits for Parties as referred to in Roman numeral II number 1 in the electronic reporting system; e. ensures the security and reliability of systems connected to the electronic report publication system; f. protects and ensures the security of data and/or completeness of Reports in accordance with applicable regulations concerning personal data protection; g. submits reports to the Financial Services Authority in the event of changes or system developments, including the addition of system services and features that require adjustments to the electronic reporting system; and h. stores reporting documents submitted through the electronic reporting system for a minimum period of 5 (five) years from the date of reporting.

3. The electronic reporting system organized by the Electronic Reporting System Provider must: a. be connected to the electronic report publication system; b. provide an audit trail for all activities related to the processing of Report reception for supervision, law enforcement, dispute resolution, verification, and testing purposes; c. have and place backup data center and disaster recovery facilities within the territory of Indonesia in a safe location separate from the main data center; and d. meet minimum standards for information technology systems, information technology security, system disturbances and failures, and information technology system outsourcing.

4. Mechanisms and procedures for changes or system developments, including the addition of system services and features, are regulated by the Electronic Reporting System Provider.

IV. ELECTRONIC REPORT PUBLICATION SYSTEM PROVIDER

1. In providing the electronic report publication system, the Financial Services Authority designates the Stock Exchange as the Electronic Report Publication System Provider.

2. Report information as referred to in Roman numeral II number 3 letter a is available for public access through the Stock Exchange website.

3. In carrying out the publication of Reports, the Electronic Report Publication System Provider: a. may access data and documents and use reports submitted by the Electronic Reporting System Provider for the purpose of publishing Reports as referred to in Roman numeral II number 3 letter a; b. publishes Reports through the Stock Exchange website; c. establishes guidelines for the procedure for electronic reporting publication; and d. stores reporting documents submitted through the electronic reporting system for a minimum period of 5 (five) years from the date of reporting.

4. The electronic report publication system organized by the Electronic Report Publication System Provider must: a. be connected to the electronic reporting system; b. provide an audit trail for all activities related to the processing of Report publication for supervision, law enforcement, dispute resolution, verification, and testing purposes; c. have and place backup data center and disaster recovery facilities within the territory of Indonesia in a safe location separate from the main data center; and d. meet minimum standards for information technology systems, information technology security, system disturbances and failures, and information technology system outsourcing.

V. ELECTRONIC SUBMISSION OF REPORTS IN FORCE MAJEURE CONDITIONS

1. In the event of: a. force majeure conditions including natural disasters, war, riots, fires, strikes, and other events that significantly affect the ability of the Electronic Reporting System Provider and/or the Electronic Report Publication System Provider; and/or b. technical disturbances and/or system developments, the Electronic Reporting System Provider and/or the Electronic Report Publication System Provider notifies the Financial Services Authority.

2. If conditions as referred to in number 1 occur which cause: a. the Electronic Reporting System Provider to be unable to provide, manage, and receive reports; and/or b. the Electronic Report Publication System Provider to be unable to publish reports, the Financial Services Authority announces on the Financial Services Authority website and states that the electronic reporting system and/or the electronic report publication system is experiencing disturbances.

3. Parties as referred to in Roman numeral II number 1 and number 2 may not submit Reports electronically if: a. the Financial Services Authority states that the electronic reporting system is experiencing disturbances as referred to in number 2; and/or b. an event occurs beyond the control and power of the Parties as referred to in Roman numeral II number 1, including:

   1. natural disasters, war, riots, fires, strikes that significantly affect the ability of the reporting Party to submit Reports through the electronic system provided by the Provider; and/or
   2. other events that significantly affect the ability of the reporter to submit Reports through the electronic reporting system provided by the Electronic Reporting System Provider, including technical disturbances in the electronic reporting system that can be proven.

4. If conditions as referred to in number 1 and/or number 3 occur, the submission of Reports is done by: a. being handed over or sent directly to the correspondence address of the Financial Services Authority headquarters in electronic document form; or b. being sent via email addressed to mailingroomsumitro@ojk.go.id and helpdesk@ksei.co.id.

5. If the conditions as referred to in number 1 and/or number 3 letter a have been resolved, the reporting Party must resubmit the Reports as referred to in Roman numeral II number 3 that were submitted as referred to in number 4 through the electronic reporting system at the latest 5 (five) business days after the Financial Services Authority states that the conditions have been resolved.

6. If the conditions as referred to in number 3 letter b have been resolved, the reporting Party must resubmit the Reports as referred to in Roman numeral II number 3 that were submitted as referred to in number 4 through the electronic reporting system at the latest 5 (five) business days after the conditions have been resolved.

VI. CLOSING

This Financial Services Authority Circular Letter shall take effect 6 (six) months after the date of establishment.

Established in Jakarta on 5 June 2025

EXECUTIVE HEAD OF SUPERVISOR OF CAPITAL MARKETS, FINANCIAL DERIVATIVES, AND CARBON EXCHANGE FINANCIAL SERVICES AUTHORITY REPUBLIC OF INDONESIA,

INARNO DJAJADI