Key Takeaways from Indonesia’s New OJK Rules on Influencer Marketing by Securities Firms

As part of its ongoing effort to modernize and consolidate the regulatory framework for securities companies, Indonesia’s Financial Services Authority (Otoritas Jasa Keuangan or “OJK”) has issued OJK Regulation No. 13 of 2025 on Internal Control and Conduct of Securities Companies Engaged in Business Activities as Securities Underwriters (Penjamin Emisi Efek or “PEE”) and Security Brokers (Perantara Pedagang Efek or “PPE”) (“OJK Reg. 13/2025”).

This new regulation introduces a more structured approach to internal governance and updates the rules on permissible promotional activities, including the use of social media influencers by securities companies.

OJK Reg. 13/2025 is scheduled to take effect on December 11, 2025. Upon its entry into force, it will formally revoke three existing regulations that currently govern the conduct of securities companies, namely:

• OJK Regulation No. 3/POJK.04/2020 of 2020 on the Conduct of Securities Companies Engaging in Business Activities as PPE;
• OJK Regulation No. 4/POJK.04/2020 of 2020 on the Conduct of Securities Companies Engaging in Business Activities as PEE; and
• OJK Regulation No. 50/POJK.04/2020 of 2020 on the Internal Control of Securities Companies Engaging in Business Activities as PPE.

This article highlights the key provisions under OJK Reg. 13/2025, particularly those relating to the regulatory endorsement of influencer-based promotional strategies and the strengthening of internal control functions within securities companies.

Green Light for Influencer Collaboration

Among the notable developments under OJK Reg. 13/2025 is the express recognition of marketing collaborations between securities companies and social media influencers, e.g., selebgrams, YouTubers and TikTokers. While the current regulations already allowed PPE to engage in marketing and promotional activities, OJK Reg. 13/2025 introduces new provisions that explicitly allow both PPE and Regional Securities Companies (Perusahaan Efek Daerah or “PED”) to partner with influencers as a channel to reach investors and the wider public.

Article 106 para. (2) of OJK Reg. 13/2025 categorizes eligible collaboration models as follows:

• Social media influencers may act as an advertising platform and/or share general information about the capital market, provided they do not invite prospective customers to become customers of PPE and PED, and do not offer any personal assessments or analysis;
• Social media influencers may actively invite prospective clients to open accounts or become customers of PPE and PED; and/or
• Social media influencers may provide analysis and recommendations regarding a specific security, product, and/or service of PPE and PED.

In implementing any of the above schemes, PPE and PED are required to formalize the arrangement in a written agreement. They must also ensure that their influencer partners meet all applicable qualification and licensing requirements in accordance with the selected collaboration model.

Highlights of Other Key Provisions

In addition to marketing-related provisions, OJK Reg. 13/2025 introduces several important refinements to existing governance standards, as follows:

Introduction of PED: OJK Reg. 13/2025 formally recognizes PED as a new category of securities company within the Indonesian capital market. A PED is a PPE that administers clients’ securities accounts and is specifically established to operate within a single province. The new regulation also sets out specific internal functions and conduct requirements applicable to PEDs.

Expansion of internal controls and conduct requirements for PEE and PPE: OJK Reg. 13/2025 introduces internal control requirements for PEEs, which were previously unregulated, and expands the existing obligations for PPEs. PEEs must now establish between five and six internal functions, depending on their business scope. They are no longer liable for refunding unallotted orders; instead, they are obligated to remit offering proceeds to issuers and provide refunds only in the event of a listing failure.

For PPEs, the regulation introduces two new mandatory functions: (i) internal audit and (ii) human resource management and development. It also relaxes the previous requirement that all internal functions be carried out separately, allowing certain functions to be carried out concurrently.

Changes to applicable sanctions: Failure by PEEs, PPEs, or PEDs to comply with their obligations under OJK Reg. 13/2025 may result in a range of administrative sanctions. These include written warnings, fines, temporary restrictions on business activities, suspension of business activities, revocation of business license, cancellation of registration, and revocation of individual licenses. This represents a significant shift from the current framework, which only allows for the cancellation of approvals rather than full revocation of personal licenses.

It is important to note that OJK Reg. 13/ 2025 does not stipulate the amounts of fines applicable to such violations. Instead, the OJK will determine the amounts either through future implementing regulations or on a case-by-case basis, depending on the nature of the violation. We have obtained verbal confirmation from an OJK official to this effect.

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