Listing Handbook 2025

General Requirements 

An issuer can list its shares on the IDX either on the Main Board, the Development Board, the Acceleration Board or the New Economy Board depending on the fulfillment of requirements under each of the boards. There are certain general requirements that must be fulfilled by an issuer to have its shares listed in the IDX, such as having Independent Commissioners (the number of Independent Commissioners must be at least 30% of the total members of the Board of Commissioners), having an Audit Committee, having a Corporate Secretary, and the Initial Public Offering (“IPO”) price being at least Rp100 for the Main, Development, and New Economy Boards and at least Rp50 for the Acceleration Board.  

There are specific requirements that differentiate the Main Board, the Development Board, the Acceleration Boards, summarized as follows: 

*Free float shares are shares: (i) owned by a shareholder of less than 5% of the total shares, (ii) not owned by the controller** and affiliate of the company, (iii) not owned by the members of board of directors or board of commissioners, and (iv) not a share that has been bought back by the company. 

**Controller is a party that (i) owns more than 50% of the total issued and paid-up shares of a company or (ii) can determine, directly or indirectly, in whatsoever manner, the management or the policy of a company. 

The requirements to be listed in the New Economy Board are the same as the requirements to be listed in the Main Board.  

In addition, to be listed on the New Economy Board, the company must fulfill the following requirements: 

• Has high-growth revenue 
• Utilizes technology to create innovation of products or services that increases productivity and economic growth as well as having a social benefit. 
• Operates in industries determined by the IDX. 

A more comprehensive and detailed summary of the IDX listing boards’ requirements is provided in Appendix I of this Listing Handbook. 

All Shares Must Be Listed 

The IDX requires all companies wishing to list their shares on the IDX to list all the company’s shares, except for banks where one percent of its paid-up capital must not be listed on the IDX.  

Additional Shares 

Aside from an initial listing, the IDX also allows for the listing of additional shares as a result of issuance of new shares by the listed company, eg, as a result of a rights issue, an increase of capital without preemptive rights, reverse stock split, bonus shares, dividend shares, conversion of indebtedness, employee/management stock option program and exercise of warrants. There are requirements that need to be fulfilled to be able to list these additional shares on the IDX (these include guideline formula for determining the pricing). There are different requirements to be fulfilled for the listing of additional shares depending on how the new shares are issued. 

Prior to the IPO, the intended issuer shall appoint supporting parties i.e. underwriter, auditor, legal consultant, appraisal, notary, financial advisor (if necessary), tax advisor (if necessary), share registry, to assist them in conducting the IPO process. 

Restructuring the ownership of the intended Listco 

Prior to the IPO, an issuer may conduct a restructuring which typically is conducted: 

• Due to regulatory restriction based on industry sector, such as broadcasting company, mining company (holder of Kuasa Pertambangan/KP), tower sector (tower provider, tower operator or tower contractor), port or airport. 
• To increase the share value of the company. 
• To comply with IDX Listing Rule. 

It is recommended that the relevant subsidiary which is slated for listing is a non-PMA Company. 

The reason for this is as follows: 

• The current Indonesian Investment laws and regulations and the rules and regulations of BKPM (the foreign investment regulator) provide that the Indonesian Negative List on Investment does not apply to Indonesian listed vehicles.   
• Despite the inapplicability of the Negative List to the listed company, where a PMA company acquires a non-PMA company, that non-PMA target must convert its status to PMA, that converted PMA target will become subject to the Negative List, and its listed-company shareholder having PMA status will be treated as a “foreigner”.   Accordingly, for this reason, it is important that the listed holding company be listed as a non-PMA, such that when it later acquires new non-PMA subsidiaries, those non-PMA subsidiaries can remain non-PMA status and therefore are not subject to the Negative List. 

Appointment of Supporting Professionals 

To conduct an IPO, a company must appoint the following supporting professionals: 

• Licensed underwriters (investment bankers) 
• Independent Auditor 
• Legal Counsel 
• Share registrar 
• Notary 
• Independent appraiser (as needed) 
• Industry consultant/expert (as needed) 

Submission of Registration Statement to OJK 

Any parties conducting an IPO in Indonesia must file a registration statement (“RS”) with OJK, and the RS must be declared effective by OJK. 

Documents to be submitted as the RS documents are among others: 

• Cover letter 
• Public Offering schedule 
• Financial report which has been audited by independent auditor (the date of the audited financial statements must not be more than 180 days as of the effective date of the RS) 
• Comfort letter from the auditor concerning the change in the financial condition of the issuer after the date of the audited financial report 
• Prospectus and abridge prospectus 
• Legal due diligence report and legal opinion issued by the appointed legal counsel 
• Initial underwriting agreement with the underwriters/ lead managing underwriters 
• Shares administration management agreement with share registrar (Biro Administrasi Efek) 
• Preliminary listing agreement with the IDX 
• Agreement with Indonesian Central Securities Depository (PT Kustodian Sentral Efek Indonesia – “KSEI“) 
• Appraisal report (the date of the assets appraisal report must not be more than 180 days as of the effective date of RS), as needed 
• Shareholders resolution approving the IPO 
• Amended articles of association to comply with OJK regulation 
• Various statement letters as required under OJK regulations 

RS will be effective: 

1. a. 20 business days after the RS is completely accepted by OJK, i.e. it meets all the criteria set out in the regulation on RS of a public offering and other regulations related to the public offering OR
2. 20 business days after the latest amendment of the RS is submitted by the issuer or any request by OJK is fulfilled
3. On the issue of an effective statement of OJK that it does not require any further amendment and/or additional information.

Any request for amendment and/or additional information from OJK must be fulfilled within 10 business days by the issuer. Failure to comply with this will be deemed cancelling the RS. Abridged prospectus/preliminary prospectus for bookbuilding purposes can only be published after OJK issues specific written permission to do so.  

General Activities During an IPO Process 

What will happen during an IPO process are listed below: 

• First submission to OJK 
• IDX and KSEI submission 
• Analyst presentation 
• Mini expose and IDX’s site visit 
• Anchor process (as relevant) 
• IDX comments 
• Response to IDX comments 
• OJK comments 
• Second submission to OJK 
• Determination of price range to be submitted to OJK 
• Signing of Underwriting Agreement to include price range 
• Submission to OJK 
• OJK issue pre-effective statement 
• Abridged Prospectus publication 
• Public expose and bookbuilding period 
• Price finalization 
• Third submission to OJK 
• OJK issue effective statement 
• Final Abridged Prospectus publication 
• Public/Retail offering period  
• Payment of IPO proceeds to the company 
• Electronic distribution (issuance date) 
• Listing on IDX 

IDX Listing Process 

The procedures for listing of shares, as stated in Listing Rule No. I-A on Listed Stock and Equity Securities other than Shares Issued by Listed Companies (“IDX Listing Rule”) are divided into those for (i) prospective listed companies that intend to list shares on the IDX, and (ii) prospective listed companies that are public companies or companies that have already been listed on another stock exchange. The explanation below will focus on the first procedure, ie, the procedure for prospective listed companies which intend to list shares on the IDX (listing after IPO). 

Submission of Listing Request to IDX 

A prospective listed company which intends to list its shares on the IDX has to file a request for the listing of shares to the IDX (“Request”) and pay an initial listing fee. The initial listing fee is calculated based on the share capitalization value1 of the listed company.  

• For the Main and New Economy Boards’ initial listing fee, for every IDR 1 billion of share capitalization value, the initial listing fee is IDR 1 million, with the minimum initial listing fee being IDR 25 million and the maximum being IDR 250 million.  
• For the Development Board’s initial listing fee, for every IDR 1 billion of share capitalization value, the initial listing fee is IDR 1 million, with the minimum initial listing fee being IDR 25 million and the maximum being IDR 150 million. 
• For the Acceleration Board, the initial listing fee is IDR25 million. 

The Request from the prospective listed company should comply with the form attached to the IDX Listing Rule. The documents that must be attached to the Request include: 

• Deed of establishment and/or articles of association of the prospective listed company which have been approved by the authorized government body with all the amendments, and the company registration certificate (Tanda Daftar Perusahaan) 
• Organizational structure of the prospective listed company up to the first level officials below the board of directors (Direksi) 
• Organizational structure of the group showing the position of the prospective listed company within the group (if any) 
• Updated curriculum vitae of the members of the board of directors (Direksi) and board of commissioners signed by the person concerned 
• Register of shareholders, including the number of shares, the composition of shareholders and any changes thereto during the last three years (or since the establishment of the company if the company was established for less than three years) 
• A list showing the ownership of shares and business affiliations of the directors, commissioners and their families, whether in the prospective listed company or its affiliates 
• Audited annual financial report for the last three years and the last audited interim financial report (if any), or all the audited financial reports since the prospective listed company started operations if the prospective listed company has been operating for less than three years 
• A brief history of the prospective listed company 
• A description of the business activities of the prospective listed company 
• Taxpayer registration number (Nomor Pokok Wajib Pajak (NPWP)) of the prospective listed company 
• Management discussion and analysis on the business activities, performance, and financial position of the prospective listed company 
• Analysis of risks and prospects of the prospective listed company’s business 
• Financial projection for at least three years including the assumptions that are used (for certain companies that require a significant amount of time to reach a break-even point, eg, companies engaged in the infrastructure sector or other sectors that relate to public service, they are required to provide a financial projection until the company obtains business profit and net profit) 
• The intended use of the funds raised through the public offering 
• The total number of shares offered and the estimated offer price 
• A copy of the underwriting agreement for the IPO 
• Information on the total number of shares to be listed 
• Dividend policy 
• Transactions/agreements, credit and liabilities to affiliated parties (including their amounts and terms/conditions) 
• Receivables of the prospective listed company which is guaranteed by an affiliate, and/or third-party loans or loans of affiliated parties which are guaranteed by the prospective listed company (if any) 
• A summary of material contracts 
• Performance, operational, growth, liquidity and solvency ratios 
• Legal opinion from a legal counsel registered at OJK 
• Evidence of payment for listing application  
• Appraisal report by an independent appraiser registered at OJK (if any) 
• A copy of the contract with the share registrar or a statement from the prospective listed company if it manages the registration of its own securities 
• A copy of approvals as required by the authorities on the environmental impact analysis for the prospective listed company 
• For a prospective listed company which operates in a sector that is specifically regulated in an IDX rule, the relevant documentation required in that IDX rule, such as for a company that operates in the mining sector: 
  • A letter issued by the relevant authority stating that the concession is still valid 
  • A letter issued by the relevant authority related to the contract of work or mining authorization or license for mining in the local regions 
  • Supporting documents showing that the directors have the necessary technical ability and experience in mining to run the activities of the prospective listed company 
  • A letter from an independent party which states that the prospective listed company already owns proven deposits or its equivalent in line with the type of mineral being mined 
• A copy of the letter from the relevant authority which issues the concession or license for a prospective listed company whose activities need a concession or a license to manage such as forestry business or toll roads 
• A statement on the independent commissioner(s) and independent director 
• A list of the names of the audit committee members 
• The name of the chairman of the internal audit unit 
• A statement on the fulfillment of requirements to be directors and commissioners of the prospective listed company 
• Names and signature specimens of the authorized signatories of the prospective listed company 
• Statement letter on the responsibility and accuracy of information submitted to the IDX, including the commitment to comply with the IDX rules signed by the board of directors 

Mini Expose and Site Visit  

The prospective listed company and all its advisors must make a “mini public expose” in the form of a presentation to the IDX to introduce and its operations, business model, growth strategy, financial highlights and rationale for going public as well as all findings of the advisors. 

Some topics to be discussed in the mini expose may include: 

• Company vision and milestones 
• Market position and future expansion plans 
• Company’s going concern 
• Use of IPO proceeds 
• Corporate governance practice 

IDX will also visit the office and the project site of the prospective listed company, and this is a part of the pre-IPO due diligence to assess the readiness of the prospective listed company. 

The purposes of the site visit are: 

• To observe the company’s operations, facilities and management firsthand. 
• To verify that the company meets the eligibility and operational criteria for listing.  

Roadshow 

• Publicity Restrictions
  Following the submission of registration statement for IPO to OJK, the issuer and other offering participants are prohibited from disclosing or announcing any information in relation to the offering until OJK issues: (i) a statement letter that the issuer is required to announce the abridged prospectus, or (ii) a statement letter permitting the commencement of an initial offering (bookbuilding) and/or publication with respect to the public offering pursuant to the registration statement submitted (pre-effective statement). 
  
  No publication that contains a solicitation to participate in the offering or to purchase the shares to be offered should be distributed or released prior to obtaining the pre-effective statement. 

• Communication with Investors
  Prior to the issuance of the pre-effective statement by OJK, any meetings or engagements with investors, analysts and/or media representatives are allowed. 
  
  However, such meetings and engagements must be strictly informational and must not include any invitation/solicitation to the investors, analysts and/or media representatives to participate in the offering or to purchase the shares to be offered. Such activities should be conducted discreetly, in a private, controlled setting and must avoid promotional language or materials related to the offering. 

Language 

Any documents submitted to OJK and the IDX must generally be submitted in Bahasa Indonesia. If the documents are submitted in a language other than Bahasa Indonesia, generally, a Bahasa Indonesia translation must also be submitted. 

Corporate Governance 

Indonesian companies are required to have a two-tier management structure. The executive functions are managed by a board of directors (Direksi), which is supervised by a board of commissioners (Dewan Komisaris). The board of commissioners does not have an executive function or authority, except in the absence of all members of the board of directors. 

Under the Indonesian Company Law (Law No. 40 of 2007) the board of directors (Direksi) is tasked for managing the company for the best interest of the company in accordance with the purpose and objective of the company. Whereas the board of commissioners is tasked with supervising and advising the board of directors  for the best interest of the company in accordance with the purpose and objective of the company. Generally, the board of directors  and board of commissioners have defined rules to guide their conduct. The company is a separate legal entity to which the board of directors and the board of commissioners owe a loyalty above both their own personal interests and the interests of the shareholders. The board of directors and board of commissioners therefore are obligated to run the company in the best interests of the company, even if that may conflict with personal or shareholders interests. 

As mentioned above, under the OJK regulations and IDX Listing Rule, a listed company must have: 

• Independent commissioners comprising at least 30% of the total number of members of the board of commissioners 
• An audit committee 
• A corporate secretary 
• An internal audit unit 

Independent Commissioners 

To become an independent commissioner in a listed company, he/she:  

• Is not a person that has the authority and responsibility to plan, lead, control or supervise the activity of the listed company in the last six months before his appointment as an independent commissioner 
• Must not own any shares of the listed company, directly or indirectly 
• Must not have an affiliated relationship with the listed company, or with any commissioner, director or principal shareholder of the listed company concerned 
• Must have no business relationship which is directly or indirectly related to the listed company’s business activity 
• May not hold a dual position as a director of another company which is an affiliate of the listed company 
• Must have adequate knowledge of all relevant capital markets regulations 

An independent commissioner that has served for two consecutive terms of office, can be elected for the third consecutive term so long as he/she declares and proves to a general meeting of shareholders that he/she remains independent. Further, if there is a vacancy in the independent commissioner’s position, the listed company must fill that vacancy at the latest at the next general meeting of shareholders or within six months after the vacancy occurs. 

Audit Committee 

A listed company’s audit committee must comprise at least three members, one of whom must be an independent commissioner who will serve as chairman of the audit committee. The other members must also be independent people (usually originating from outside the company), at least one of whom must be an expert in the field of accounting and/or finance. 

The following people are prohibited from becoming members of the audit committee of a listed company: 

• Any inside person of a public accountant, legal consultant or other party who gives audit, non-audit and or other consultation services to the company that personally audits the financial statements of the listed company in the last six months before his appointment as a member of the audit committee. 
• Any person that has the authority and responsibility to plan, direct or control the activity of the listed company in the last six months before his appointment as a member of the audit committee, except an independent commissioner. 
• Any person who owns shares, either directly or indirectly, in the listed company. 
• Any person who has an affiliated relationship with commissioners, directors or a principal shareholder of the listed company. 
• Any person who has a business relationship which is directly or indirectly related to the listed company’s business activity. 

In addition to the above, each member of the audit committee must: 

• Have high integrity, ability, knowledge and adequate experience (including any relevant educational qualifications) and be able to communicate properly. 
• Be capable of reading and understanding financial reports, and at least one of the members of the audit committee must have an educational qualification in accountancy or finance. 
• Have adequate knowledge of all relevant capital market regulations. 
• Understand financial statements, the business of the listed company concerned, audit process, risk management and capital market regulations and other related regulations. 
• Comply with the audit committee’s code of conduct which is stipulated by the listed company. 
• Agree to increase his/her competency continuously through education and training. 

A listed company must set up an audit committee charter. The charter must at least consist of: 

• The duties, responsibilities and the authority of the audit committee 
• The composition, structure and requirements of members of the audit committee 
• Guidelines and working procedure 
• The requirements for audit committee meetings 
• Reporting mechanism 
• Provisions on complaints or reports received in connection with any suspicion as to whether there is any violation in financial reporting 
• The term of the audit committee 

The charter must be published on the listed company’s website. 

Corporate Secretary 

The function of the corporate secretary may be performed by one of the directors of the listed company, or an official of the listed company designated to carry out such function. However, a corporate secretary cannot have a dual position as director in other listed companies. The corporate secretary acts as a liaison or contact person between the listed company, government authorities, including OJK, and the public. The corporate secretary must have access to material and relevant information relating to the listed company and must be familiar with all statutory regulations relating to capital markets, particularly on disclosure matters. 

The appointment and termination of the corporate secretary are based on the board of director’s decision. If there is no corporate secretary, the listed company must appoint a replacement at the latest 60 calendar days after the corporate secretary position becomes vacant. Such appointment and termination must be: (i) reported to OJK and (ii) published on the relevant listed company’s website, at the latest two business days after the appointment or the termination. 

Internal Audit Unit 

The internal audit unit shall play a visible leadership role in promoting compliance and performing internal audit function within the listed company. Each listed company must have an internal audit unit and the number of internal auditors in the internal audit unit will be adjusted based on the scale and the complexity level of the listed companies’ business.  

To become an internal auditor, she/he, at minimum: 

• Must have integrity, and be professional, independent, honest and objective 
• Must have knowledge and experience in relation to undertaking an audit and other knowledge relevant to his/her duties 
• Must have knowledge of capital market regulations and other related regulations 
• Must have the ability to interact and communicate effectively 
• Must comply with the professional standards issued by the Internal Audit Association 
• Must comply with the code of ethics for internal audits 
• Must protect the confidentiality of all information and/or company data related to the implementation of his/her duties–an exception to this may be granted only if the prevailing laws and regulations stipulate otherwise, or if it is based on a court decision 
• Must understand good corporate governance principles and risk management 
• Must continuously improve his/her knowledge, ability and professionalism 

The duties and responsibilities of an Internal Audit Unit include: 

• Preparing and implementing an annual internal audit plan 
• Examining and evaluating the implementation of an internal control and risk management system in accordance with the company’s policy 
• Reviewing and evaluating efficiency and effectiveness in the areas of finance, accounting, operations, human resources, marketing, information technology and other activities 
• Providing objective suggestions and information on activities which have been audited at all management levels 
• Making an audit report and submitting the report to the president director and the board of commissioners of the company 
• Overseeing, analyzing and reporting on the implementation of the suggestions 
• Working together with the Audit Committee 
• Preparing programs to evaluate the quality of the internal audit activities he/she has conducted 
• Conducting special reviews/investigations, if required 

Annual Fee 

IDX 

Main Board, Development Board and New Economy Board: 

• For every IDR 1 billion of share capitalization value, the annual listing fee is IDR 500 thousand, with the minimum annual fee being IDR 50 million and the maximum being IDR 250 million 
• For every IDR 1 billion of share capitalization value, the additional listing fee is IDR 1 million, with the minimum fees for an additional listing being IDR 10 million and the maximum being IDR 150 million 

Acceleration Board: 

• The annual listing fee is IDR 25 million 
• The additional listing fee is IDR 25 million for each corporate action 

KSEI 

Annual fee of KSEI is IDR 10 million for every securities registered at KSEI. 

OJK 

Annual fee of OJK is 0.03% of the outstanding issuance value (nilai emisi efek outstanding) with the minimum of IDR 15 million and the maximum of IDR 150 million. 

Listing Maintenance 

Requirements to maintain listing in the Main Board and Development Board: 

• The total number of free float shares is (i) at least 50 million shares and (ii) at least 7.5% of the total paid up capital of the company. If a company breaches this requirement due to a mandatory tender offer, it will be given a two-year deadline to comply with the maintenance requirements in accordance with the mandatory sell-down obligation regulated in OJK regulation on takeover of public companies. 
• The total number of shareholders is at least 300 holders of SID. 
• If the company does not meet the criteria stipulated in point (a) above, the company may submit an application so that certain shareholders can be categorized as free float shareholders provided that the ownership is in the form of an investment portfolio with the public investor as the beneficiary. 
• If a company breaches the requirements stipulated in points (a) and (b) above due to corporate actions, it must submit an application to the IDX containing a plan to satisfy the maintenance requirements no later than two trading days after the company is discovered to have failed to fulfill the requirements. 

Additional requirements to maintain listing in the Main Board: 

• Fulfill one of the following conditions: 
  • Not recording a net loss for two consecutive years 
  • Recording a compound annual growth rate of operating income of at least 20% for the last three years 
• The company does not record negative equity in the last financial statements. 
• The number of shareholders is more than 750 holders of SID 
• Free float shares fulfil the following conditions: 
  • If there are free float shares of 10% or more, then the shares capitalization value from the free float share is more than IDR 200 billion 
  • If there are free float shares of less than 10%, then the shares capitalization value from the free float share is more than IDR 1 trillion 
• Fulfill one of the following conditions: 
  • Price to earnings ratio per share of the company is not more than three times the market price to earnings ratio 
  • Price to book value of the share is not more than three times the market price to book value ratio 
  • Share capitalization value of at least IDR 12 trillion 
• The company did not receive written sanction from IDX for the past year 
• The annual audited financial statements of the company have obtained an unqualified opinion for two consecutive financial years 

Requirements to maintain listing in the Acceleration Board: 

• Non-controlling shareholders and non-principal shareholders must hold at least 7.5% of the total paid up capital of the company 
• The total number of shareholders with SID is at least 300 

Requirements to maintain listing in the New Economy Board: 

• Fulfill all requirements to maintain listing in the Main Board of the IDX 
• High growth revenue 
• Utilize technology to create innovation of products or services that increases productivity and economic growth as well as having social benefit 
• Operate in the industries determined by the IDX 

Periodical Reporting Obligations 

Listed companies are required to submit periodic reports to OJK and IDX, including the following: 

• An annual report to be submitted no later than four months after the end of the financial year of the listed company (If the annual report has already been available to the shareholders before the deadline, the annual report must be submitted to OJK on the day it becomes available to the shareholders) ̶ the annual report must be prepared in two languages, one being Indonesian language and the other one being a foreign language. 
• Consolidated financial statements consisting of:  
  • An annual financial report audited by an accountant registered with OJK, to be submitted not later than three months after the date of such report 
  • Any of the following mid-year reports: (a) a mid-year report (unaudited), to be submitted not later than one month after the date of such report; (b) a mid-year report with limited review by an accountant registered with OJK, to be submitted not later than two months after the date of such report; or (c) a mid-year report audited by an accountant registered with OJK containing a full opinion on the fairness of such report, to be submitted not later than three months after the date of such report 
  • Quarterly reports, the preparation of which is required by the rules of the IDX, to be submitted to the IDX not later than one month after the date of such report for a non-audited report, two months after the date of such report for a limited audit report, and three months after the date of such report for a fully audited report 
• The use of the net proceeds from the initial public offering 
• Annual sustainability report 

Non-Periodic Reporting Obligations 

Listed companies are also required to immediately disclose to the public, OJK and the IDX any material information or facts which may affect the value of the securities or an investment decision of investors (price sensitive information), such as a merger, acquisition, consolidation, stock split, stock dividend, change in management, labor disputes, replacement of a public accountant, replacements of a trustee and material legal claims, within two business days of such an event taking place. 

Reporting Obligations Related to Corporate Actions 

Listed companies that undertake material corporate actions (unless specifically exempted by OJK rules) must either (i) issue a circular to their shareholders and make a disclosure of information on the corporate actions in such a circular as well as obtain the approval of a general meeting of shareholders or (ii) merely announce such a corporate actions to the public, depending on the value of the proposed corporate actions.2 

In addition, listed companies that undertake corporate actions that are considered as affiliated party transactions (transactions with an affiliated party) must either (i) issue a circular to their shareholders and make a disclosure of information on the corporate actions in such a circular or (ii) obtain the approval of the independent shareholders in a general meeting of shareholders in addition to issuing the aforementioned circular and making the aforementioned disclosure, depending on whether or not the affiliated party transaction is deemed as a conflict of interest transaction. 

In addition, if listed companies were to issue new shares, either with or without pre-emptive rights, the companies must either issue a circular to their shareholders and make a disclosure of information on the corporate actions in such a circular and obtain the approval of a general meeting of shareholders. 

Shareholding Reporting Obligations 

Further, there is also an obligation of shareholders of a public company to report their shareholding composition to OJK. Any party that owns five percent or more of the issued shares of a public company, is required to report to OJK on its ownership or change thereon within 5 business days of the date on which the transaction takes place. This reporting obligation also applies if any directors or commissioners of a public company own shares in the same public company.  

Insider Trading 

Insider trading, fraud and market manipulation of securities are prohibited under Indonesian capital markets laws. In such circumstances, a transaction may be cancelled or suspended by the IDX, or OJK may suspend or revoke the license of the capital market supporting institutions and supporting professionals involved. A party engaging in (i) conducts that are misleading, fraud or manipulation in connection with the sale of securities; (ii) other actions which mislead the public regarding trading activities, market conditions or price or (iii) insider trading,