12 Jan 2026
Shareholding Electronic Reporting Goes Live: What the New Electronic System Means for Shareholding Reporting Obligations Under OJK Regulation No. 4 of 2024

1. AKSes KSEI – The System

On 26 February 2024 the Indonesian Financial Services Authority (Otoritas Jasa Keuangan or “OJK”) enacted OJK Regulation No. 4 of 2024 on Reports on Ownership or Any Changes to the Ownership of Shares in Public Companies and the Activity of Encumbering the Shares of a Public Company (“OJK Reg. 4/2024”) which we have previously discussed on this link.

The regulation generally requires the relevant report to be submitted within 5 business days. However, Article 7 provides that once OJK has made an electronic reporting system available, the deadline is shortened to 3 business days from either: (i) the acquisition of voting rights (or any change in voting rights) in shares of a public company, or (ii) the signing of the security documents over pledged/encumbered shares.

After nearly two years of anticipation since OJK Reg. 4/2024 promises the implementation of an electronic reporting system, KSEI formally implemented this electronic reporting mechanism through KSEI Board of Directors Decision No. KEP-0042/DIR/KSEI/1225 on the use of AKSes as the platform for electronically submitting reports on share ownership (and changes thereto) and share encumbrances under OJK Reg. 4/2024. The updated reporting functionality on AKSes was officially launched on 5 December 2025.

For clarity, AKSes itself is not a new platform. AKSes has long been a KSEI online facility allowing investors to monitor their securities holdings and portfolios. What changed on 5 December 2025 is that AKSes was updated and re-launched to also support electronic submission of these OJK reports.

2. Organized Group Reporting – The Mechanism 

Under OJK Reg. 4/2024, an Organized Group refers to parties that coordinate, through a plan, agreement, or decision, to work together toward a particular objective.

Where the aggregate shareholding of an Organized Group reaches 5% of the total voting rights in a public company, a disclosure obligation is triggered for the group. In this context, the reporting obligation applies at the group level, even if the individual shareholding of one or more members is below the 5% threshold. Importantly, an Organized Group does not need to be linked by share ownership, voting control, or a parent–subsidiary relationship. For example, a parent and subsidiary may be regarded as an Organized Group if they coordinate to pursue a shared objective, such as exercising control over an issuer/public company.

Under OJK Reg. 4/2024, reporting by an Organized Group is carried out by one shareholder designated to represent the group, with the report required to include details of all members of the Organized Group.

From an operational perspective, reporting as an Organized Group may be more challenging under the AKSes KSEI electronic reporting system. Previously, such reports could be submitted to OJK by email and followed by physical filings. With the implementation of AKSes, reporting generally requires access to the system, including a valid login linked to a Single Investor Identification (SID).

In practice, submission of an Organized Group report requires the designated reporting party to have an active AKSes account. After logging in, the reporting process involves:

1. Declaring the Organized Group through the menu “Organized Group Declaration / Deklarasi Kelompok Terorganisasi”, by inputting the names of all entities and/or individuals forming part of the group (then save); and

2. Submitting the relevant disclosure through “Shares Ownership Reporting Form / Formulir Laporan Kepemilikan Saham”, with the system prompting completion of the required fields in accordance with OJK Reg. 4/2024.

Upon successful submission, the system generates an AKSes inbox notification confirming receipt of the report and providing a reporting ID.

For further details on the reporting, please access the user guide titled ‘Pelaporan OJK (sebagai Investor)’ on this link. Please note that is the guide is available in Indonesian only.

3. ABNR Commentary

The launch of AKSes KSEI introduces a new electronic reporting process for disclosures under OJK Reg. 4/2024. Previously, investors were generally required to download the reporting template attached to the regulation, complete the form, submit it to OJK by email, and follow up with the original signed documents by mail for the filing to be treated as formally submitted. With the implementation of AKSes, reports may now be submitted by completing the required fields directly within the system.

While the change in format streamlines the submission process, the more significant practical impact lies in the shortened reporting timeline. With the electronic reporting system now operational, the applicable deadline has been reduced from 5 business days to 3 business days, and submission through AKSes replaces the previous email-based filing mechanism.

In light of the above, investors should be prepared internally and build in a sufficient compliance buffer to meet the 3-business day deadline, particularly for transactions involving multiple parties or Organized Groups. Late filing may expose investors to administrative sanctions under OJK Reg. 4/2024.

By partners Chandrawati Dewi  (cdewi@abnrlaw.com), Novario Asca H (nhutagalung@abnrlaw.com), and associate Beverly Laza (blaza@abnrlaw.com)

This ABNR News and its contents are intended solely to provide a general overview, for informational purposes, of selected recent developments in Indonesian law. They do not constitute legal advice and should not be relied upon as such. Accordingly, ABNR accepts no liability of any kind in respect of any statement, opinion, view, error, or omission that may be contained in this legal update. In all circumstances, you are strongly advised to consult a licensed Indonesian legal practitioner before taking any action that could adversely affect your rights and obligations under Indonesian law.