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Contributors: Almaida Askandar, S.H., MBA, and Nita Damayanti, S.H.

Published on 20 June 2026 by IABF Law Firm, Jakarta, Indonesia.

Mandatory Information Submission for Public Companies and Listed Companies

Pertaining to the mandatory submission of information to the authorized institution, principal regulations will be reviewed at a glance: (i) Financial Service Authority (“FSA”) Regulation Number 40 of 2025 regarding the Use of Proceeds of the Public Offering (“FSA Regulation 40/2025”); (ii) Decree Letter of Board of Directors of PT Indonesia Stock Exchange Number Kep-00087/BEI/12-/2025 regarding Regulation Number I-E concerning the Obligation of Information Submission as amended by Decree of the Board of Directors of the Indonesia Stock Exchange No. Kep-00052/BEI/04-2026 concerning Amendments to the Provisions on the Monthly Report on Share Ownership Registration Activities (“IDX Regulation I-E”).

I.      Mandatory Report in Relation to the Use of Proceeds of the Public Offering

In relation to the obligation on the disclosure of information, FSA Regulation 40/2025 obliges the issuers to submit (i) the report on realization of the use of proceeds of the public offering to the FSA and (ii) announce the realization report of fund utilization to public since the period of fundraising from the public offering, until all the funds from public offering are realized. The Report on Realization of the Use of Proceeds of the Public Offering (“Realization Report”) means the report on realization of the use of the proceeds of public offering which submitted by the issuers, which its registration statement has been effective.

The obligation also applies toward the funds from the conversion of securities that grant the right to buy shares at a certain time which attached to public offering of shares or debt securities that can or must be converted into shares. Moreover, FSA Regulation 40/2025 obliges that the announcement regarding the disclosure of information is made in the Indonesian language and foreign language, provided that the foreign language that is used at least being the English language, and must be made periodically every 6 (six) months, with the report date being June 30 and December 31.

The minimum information that must be listed in the Realization Report as follows:

1. 1. Type of public offering;
   2. The total funds that have been raised;
   3. The total costs that have been spent in terms of public offering;
   4. The planned use of funds, in accordance with the level of fund utilization based on the prospectus which has been disclosed in the form of nominal value completed with the percentage of the total funds from the public offering proceeds after deducting costs;
   5. The funds that have been realized and the allocation in accordance with the realization level of fund utilization that has been disclosed in the form of nominal value completed with the percentage of the all funds from the proceeds of public offering after deducting costs;
   6. The funds that are still remaining in the form of nominal value included with the percentage towards the all funds from the proceeds of public offering after deducting costs including the reasons regarding the funds that have not been realized;
   7. The placement of funds that have not been realized which at least contain the following information:

• • • The form and location where the funds are placed,
    • The placement period,
    • The level of interest rate or the return of proceeds that have been obtained, and
    • Whether or not the affiliation relations exist and the nature of affiliation relations between the issuers and the party where such funds are placed;

8. The deadline for all funds from the proceeds of public offering proceeds to be realized.

II.     Mandatory Reports in Relation to the Obligation of Information Submission under IDX Regulation I-E

1. Periodical Reports

Article III.1 of Regulation I-E describes the type of report that falls under periodical reports, among others, including (i) the annual report and (ii) the financial report. The issuers must submit the financial report regularly to the IDX which covers (i) the interim financial report and (ii) the audited financial report. The Audited Financial Report means the financial report that has been audited by the registered public accountant at the FSA, meanwhile, the Interim Financial Report means the first quarter financial report, mid-year financial report, and third quarter financial report. If there is a change of more than 20% (twenty percent) in the Total Assets and/or Total Liabilities items in the Interim Financial Statements or the annual Audited Financial Statements for the current fiscal year, relative to the latest annual Audited Financial Statements, the Listed Company must, at the same time it submits its financial statements, provide an explanation for the change, together with management’s view on how this change affects the Listed Company’s financial performance for the current year.

A Listed Company shall submit a monthly report on share ownership registration activities no later than the 10th day of the following month. The report must contain the following complete details:

• • Names and addresses of the Controller down to the individual level, along with their respective shareholdings;
  • Information on shareholders with 5% or more ownership (including SID, name, address, number of shares, and status as Controller or affiliate);
  • Share ownership and SID of each director and commissioner;
  • Affiliates of the Controller with ownership below 5% (including SID, name, address, and number of shares);
  • Beneficial Owners with ownership of 10% or more;
  • Employee shares subject to transfer restrictions;
  • The total number of all shareholders who are SID holders;
  • Classification of share ownership by type and classification according to KSEI data; and
  • Calculation of Free Float Shares based on IDX Regulations Number I-A and I-V.

2. Incidental Report

A Listed Company must submit incidental public reports regarding events affecting its subsidiaries (consolidated) or parent company that may influence share prices or investment decisions. These must be submitted as soon as possible, no later than 2 (two) Exchange Days after the event occurs (unless otherwise stipulated by FSA regulations). Key Triggers:

1. 1. Material events/facts.
   2. Merger or consolidation plans.
   3. Changes in major share ownership.
   4. Inability to pay loan interest/principalor receiving a creditor default notice.
   5. Bankruptcy or PKPU (suspension of debt payments)filings—whether by the company, creditors, or authorities—including court developments.
   6. The Listed Company pledges shares as security and/or enters into REPO transactions involving shares held by the Listed Company.
   7. Material eventsthat may threaten the company’s business continuity or profitability.
   8. Affiliate transactionsand conflict-of-interest transactions.
   9. Material transactionsand changes in business activities.
   10. Voluntary tender offersfor the company’s shares.
   11. Takeover plansby any party.
   12. Investor relations activities, such as roadshows and analyst meetings, where performance materials are presented.

A Listed Company must monitor mass media for material information that could affect its share price or investor decisions. If that information has not been reported to the Exchange, was reported incompletely, or is false, the Company must provide an explanation no later than the next Exchange Day.

For any amendment to the Articles of Association, the Listed Company shall submit a summary of such amendment no later than the next Exchange Day following the receipt by the Listed Company of the acknowledgment of receipt of the notification or the approval of the amendment to the Articles of Association, as applicable.

In the event of a change in the name of the Listed Company, the Listed Company shall make an information disclosure, accompanied by the proof of approval from the authorized institution for such name change, no later than 2 (two) Exchange Days following the receipt of said approval

A Listed Company is required to make an information disclosure within 2 (two) Exchange Days after the following events occur:

• • Changes to the Company’s address, email, NPWP (Tax ID), phone, or fax numbers used for public communication;
  • Appointment or change of the Corporate Secretary;
  • Appointment, replacement, or termination of the BAE (Securities Administration Bureau) contract for securities management, including the reasons for the change.

In the case of a Listed Company that has listed Equity Securities and has issued convertible instruments, including but not limited to convertible bonds and warrants, such Company shall, on the next Exchange Day following each conversion event, submit a report setting forth: the volume of such conversion; the remaining unconverted balance of such instruments; and the aggregate potential number of shares or other Equity Securities issuable upon the full conversion of all outstanding instruments.

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Disclaimer

This news update is prepared for general informational purposes only. The content does not constitute legal advice, a legal opinion, or counsel from IABF Law Firm. The information contained herein may not reflect the most current developments. Any quotation, distribution, or use of this information for any purpose is solely at the user’s own risk.