04 Mar 2026
OJK Reg. 33/2025: OJK Expands and Strengthens Soundness Level Assessments Framework for Insurance Companies, Guarantee Institutions, and Pension Funds

The Financial Services Authority (Otoritas Jasa Keuangan or “OJK”) has issued OJK Regulation No. 33 of 2025 on the Assessment of the Soundness Level of Insurance Companies, Guarantee Institutions, and Pension Funds (“OJK Reg. 33/2025”), which was promulgated on 17 December 2025 and became effective on 1 January 2026. 

OJK Reg. 33/2025 revokes the provisions governing soundness assessment for: (i) insurance companies and pension funds under OJK Regulation No. 28/POJK.05/2020 of 2020 on the Assessment of the Soundness Level of Non-Bank Financial Services Institutions (“OJK Reg. 28/2020”); and (ii) guarantee institutions under OJK Regulation No. 11 of 2025 on the Business Organization of Guarantee Institutions (“OJK Reg. 11/2025”). 

The new regulation establishes a more refined and comprehensive framework for assessing the soundness levels of insurance companies, guarantee institutions, and pension funds, recognizing that these soundness levels reflect an entity’s overall condition and performance. This framework is intended to support the formulation of supervisory strategies and priorities, as well as to facilitate the implementation of risk-based supervision, particularly for guarantee institutions. 

Below, we explore the key provisions introduced under OJK Reg. 33/2025 and their implications for regulated entities.

1. Harmonization of the Soundness Level Assessment Framework 

   OJK Reg. 33/2025 harmonises the regulatory framework for assessing the soundness levels of insurance companies, pension funds, and guarantee institutions under a single, dedicated regulation for soundness assessments.

   Previously, the assessment of soundness level of insurance companies and pension funds was regulated under OJK Reg. 28/2020 alongside finance companies, while guarantee institutions were subject to OJK Reg. 11/2025, a broader regulation governing business operations rather than a framework specifically designed for soundness assessments.

   OJK Reg. 33/2025 integrates guarantee institutions into the same assessment framework that applies to insurance companies and pension funds, ensuring a consistent approach to soundness assessments across these sectors.

2. New Reporting Obligation for Sharia-Based Entities

   OJK Reg. 33/2025 introduces an additional requirement for insurance companies, pension funds, and guarantee institutions that conduct business based on Sharia principles. 

   Entities with Sharia-based operations, whether partial or full, must now submit their soundness self-assessment results to the Sharia Supervisory Board. This is in addition to the existing obligation to report to the Board of Directors and the Board of Commissioners.

   This requirement strengthens Sharia governance and oversight by ensuring that soundness assessments are subject to review by the relevant Sharia supervisory organ.

3. Mandatory Consideration of Financial Soundness Results

   OJK Reg. 33/2025 maintains the assessment factors under OJK Reg. 28/2020 and extends their application to guarantee institutions. The regulation introduces a new requirement: assessments of risk profile, profitability, capital, and funding must now consider the results of the financial soundness assessment applicable to each institution.

4. Institution-Specific Classification of Risk Profiling

   OJK Reg. 33/2025 introduces a more institution-specific approach to the assessment of the risk profile factor, (e.g. the assessment of inherent risks and the quality of risk management implementation applied to insurance companies, guarantee institutions, and pension funds) by separating the classifications of risks applicable to each entity.  

   With the inclusion of guarantee institutions within the scope of OJK Reg. 33/2025 it now sets out nine risk categories: (i) strategic risk; (ii) operational risk; (iii) guarantee risk; (iv) credit risk; (v) market risk; (vi) liquidity risk; (vii) legal risk; (viii) compliance risk; and (ix) reputational risk. 

   The risk classifications for insurance companies and pension funds remain substantially aligned with the framework under OJK Reg. 28/2020.

5. Broader Penalties and Faster Enforcement 

   OJK Reg. 33/2025 significantly expands the administrative sanctions framework for soundness level assessments. 

   Under the previous regime, OJK Reg. 28/2020 primarily imposed written warnings, with reductions in risk profile ratings or soundness levels typically reserved for entities that failed to remedy violations after receiving such warnings. Under OJK Reg. 33/2025, non-compliance may now directly trigger administrative sanctions that include both written warnings and reductions in soundness level ratings. 

   The regulation also introduces a differentiated fine structure. Administrative fines now vary based on entity type and the nature of the violation, distinguishing between late submissions and complete failures to submit. This broader enforcement framework gives OJK greater discretion and a wider range of monetary sanctions to address non-compliance.

ABNR Commentary:

OJK Reg. 33/2025 establishes a more unified and structured framework for soundness level assessments applicable to insurance companies, guarantee institutions, and pension funds. The expanded scope of regulation—including the inclusion of guarantee institutions and the introduction of institution-specific risk profiling—reflects OJK’s focus on greater consistency in governance standards and stronger regulatory discipline across these sectors.

Given the broader range of administrative sanctions and clearer enforcement mechanisms, entities subject to OJK Reg. 33/2025 should ensure that their internal governance arrangements, risk management practices, and soundness level self-assessment processes are fully aligned with the new requirements. Particular attention to accuracy, documentation, and timeliness in regulatory reporting will be essential to manage compliance risk and avoid administrative sanctions under the updated framework.

By partners Ayik C. Gunadi (agunadi@abnrlaw.com), Muhammad Muslim (mmuslim@abnrlaw.com), associates Arian Hasyim (ahasyim@abnrlaw.com), Hikmatu Shalihah (hshalihah@abnrlaw.com), and trainee associate Chatherine Colose (ccolose@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.