New OJK Circular Sets Reporting Standards for Pension Funds in Indonesia

As part of the implementation of Indonesia’s Financial Services Authority (Otoritas Jasa Keuangan or “OJK”) Regulation No. 21 of 2024 on the Periodic Reporting of Pension Funds (“OJK Reg. 21/2024”), the OJK has issued Circular Letter No. 11/SEOJK.05/2025 (“CL 11/2025”) regarding the Form and Structure of Periodic Pension Fund Reports.

CL 11/2025 provides further guidance on the types of reports required under OJK Reg. 21/2024. It introduces standardized reporting formats, as outlined in the Annexes, tailored to each report type and content.

It is important to note that Article 2 of OJK Reg. 21/2024 requires pension funds to prepare and submit Periodic Reports in a complete, accurate, and timely manner. These reports consist of Monthly Reports, Annual Reports, and Other Reports.

Reporting Obligations of Employer Pensions Funds (Dana Pensiun Pemberi Kerja or “DPPK”)

DPPKs are required to submit Periodic Reports, which consist of the following:

1. Monthly Reports, which include monthly financial statements and other necessary information;
2. Annual Reports, which include audited annual financial statements, technical reports, and publication reports; and
3. Other Reports, as may be required.

CL 11/2025 provides further elaboration on the content requirements for technical reports, publication reports, and other reports, as outlined below:

• Technical Reports must include:

• • A profile of the DPPK;
  • Implementation of governance in accordance with OJK regulations;
  • An evaluation of investment performance by the supervisory board;
  • Oversight of Sharia compliance (if applicable);
  • Evidence of ongoing competence development for management, supervisory board members, and members of the Sharia supervisory board; and
  • Proof of continued competency of investment-related personnel.

• Publication Reports shall consist of information on the DPPK’s financial condition and a calculation of operating results.

• Other Required Reports include the following:

• • Notification of the appointment and realization of engagement of public accountants;
  • Business plans;
  • Implementation and supervisory reports;
  • Self-assessment of financial soundness and related follow-up action plans;
  •  Periodic actuarial reports;
  • Sustainability reports;
  • Reports on the implementation of anti-fraud strategies;
  • Investment policy evaluations; and
  • Proof of compliance with publication obligations.

Reporting Obligations of Financial Institution Pension Funds (Dana Pensiun Lembaga Keuangan or “DPLK”)

Similar to DPPKs, DPLKs are required to submit Periodic Reports, which include Monthly Reports, Annual Reports, and Other Reports.

However, with respect to Other Reports, DPLKs are not required to submit periodic actuarial reports or investment policy evaluations as stipulated for DPPK’s in the OJK regulation. Instead, DPLKs are subject to additional reporting obligations, particularly related to compliance with financial sector regulations. These include:

• Report on the update of risk assessment documents related to money laundering, terrorism financing, and/or the financing of the proliferation of weapons of mass destruction;
• Report on the data update plan; and
• Report on the realization of data updates.

Procedures for Submitting Periodic Reports

Under CL 11/2025, all pension funds are required to submit Periodic Reports through the OJK's electronic reporting system. A report is considered officially submitted only once it has passed system validation and is accompanied by a submission receipt generated by the OJK platform.

If technical issues or force majeure prevent submission through the system, the OJK will notify pension funds via the reporting platform, an official letter, or an announcement on the OJK website. In such cases, the OJK may allow alternative submission methods, including email or physical delivery of the required documents, and may extend submission deadlines until the system is fully operational.

Pension funds affected by force majeure that prevents them from submitting a report must notify the OJK within one business day, providing an explanation of the situation, the reason for the reporting failure, and a proposal for an alternative submission method or deadline extension.

The OJK will evaluate the circumstances and communicate the appropriate steps through an official letter. Once normal conditions resume, the pension fund must submit its report through the OJK electronic reporting system.

Additionally, if required, all submitted reports must also be available in printed form.

Procedures for Submitting Corrections to Monthly Reports

Under CL 11/2025, if the OJK identifies any misinformation in a submitted Monthly Report, the pension fund is required to submit a correction. However, this correction may only be made after receiving formal confirmation from the OJK.

The correction must be submitted via the OJK electronic reporting system, accompanied by a letter signed by the pension fund’s authorized management, taking responsibility for the correction. In cases of technical issues or force majeure, the correction process follows the same alternative reporting procedures outlined previously.

Note that the submission of a correction does not exempt the pension fund from administrative sanctions for the original reporting error.

Conclusion

By standardizing the structure, content, and submission procedures for Periodic Reports through CL 11/2025, the OJK aims to reinforce transparency, accountability, and effective supervision in the sector.

CL 11/2025 has been in effect since June 11, 2025, and officially revokes and replaces prior regulations, including provisions of Section X point 5 and Annex VI of CL 22/SEOJK.05/2020, CL 4/SEOJK.05/2021, and CL 5/SEOJK.05/2021.

Lastly, if the OJK’s electronic reporting system has not yet implemented the updated formats required under CL 11/2025, reports may be submitted using the existing formats available in the system.

This publication is intended for informational purposes only and does not constitute legal advice. Any reliance on the material contained herein is at the user’s own risk. All SSEK publications are copyrighted and may not be reproduced without the express written consent of SSEK.