Incidental Reporting in Capital Markets and Carbon Exchange: POJK 9/2026

Indonesia's Financial Services Authority (Otoritas Jasa Keuangan, OJK) has issued a single rulebook for one-off reports submitted through its online reporting system. Peraturan Otoritas Jasa Keuangan Nomor 9 Tahun 2026 tentang Pelaporan Insidental Melalui Sistem Pelaporan Otoritas Jasa Keuangan Di Sektor Pasar Modal, Keuangan Derivatif dan Bursa Karbon (OJK Regulation 9 of 2026 on Incidental Reporting Through the OJK Reporting System in the Capital Market, Derivatives, and Carbon Exchange Sectors) runs to 41 articles and covers three sectors that had previously handled ad hoc submissions through separate channels.

Issue

Supervised parties in the capital market file two kinds of information with the regulator: periodic reports on a fixed calendar, and reports produced for a particular purpose at a particular time. The second category is what this regulation names. Pasal 1 defines an Incidental Report (Laporan Insidental) as a report prepared for the purposes of OJK at a specified time, and a Reporter (Pelapor) as any party carrying out activities in the capital market, derivatives, or carbon exchange sectors that is obliged to submit such a report under the applicable laws and regulations. The OJK Reporting System is defined as the information system used as the means of online report submission by reporters to the authority. The regulation gathers the submission channel, the correction procedure, the supervision powers, and the sanction consequences for these reports into one instrument.

Key Provisions

Chapter II sets the submission obligation. Pasal 2 ayat (2) and Pasal 3 ayat (1) and ayat (2) carry the operative duties on how and when an incidental report reaches OJK through the reporting system, and Pasal 4 attaches administrative sanctions to a breach of any of them. Chapter III governs correction of incidental reports, with Pasal 11 ayat (4) among the provisions whose breach is separately sanctioned — a structure that treats a defective correction as a reporting failure in its own right rather than as a neutral resubmission.

Supervision is dealt with in Chapter V. Pasal 14 obliges a reporter to provide information and data in the form of documents relating to an incidental report when OJK requests them in the course of supervision. Pasal 15 makes a breach of Pasal 14 subject to administrative sanctions. The definition of "party" in Pasal 1 is deliberately wide — an individual, legal entity, company, joint venture, association, or organised group — so the supervision duty is not confined to licensed institutions.

The sanction ladder is uniform across Pasal 4, Pasal 15, and the other sanctioning provisions. Each imposes administrative sanctions on the party in breach and, expressly, on any party that causes the breach to occur. The sanctions are a written warning; a fine, defined as the obligation to pay a certain sum of money; restriction of business activity; suspension of business activity; revocation of the business licence; cancellation of approval; and cancellation of registration. Each provision then states that the sanctions from fine onwards may be imposed with or without a prior written warning, and that a fine may be imposed on its own or together with any of the heavier measures. Chapter VI adds Pasal 16, under which OJK may take certain actions against a party breaching the regulation in addition to the administrative sanctions the regulation itself provides.

Implications

The regulation's reach across three sectors means a carbon exchange participant and a securities intermediary now answer to the same procedural rules when filing an incidental report. For carbon market participants the timing matters, because the reporting duties of exchange operators were themselves reset by the recent amendment to the carbon exchange rules, which prescribes what must be reported and by when. POJK 9/2026 governs the mechanism through which non-periodic submissions travel and the consequences of failing to submit or to respond to a request for supporting documents. Firms already mapping their filing calendars against the conduct obligations for underwriters and broker-dealers will find the same seven-step sanction sequence applied here.

Regulatory Context

Aligning incidental reporting across the capital market, derivatives, and carbon exchange sectors follows the pattern of consolidation seen in OJK's 2026 output, where sector-specific procedures are drawn into instruments of general application. The identical sanction ladder used in Pasal 4 and Pasal 15 also appears in the carbon exchange rules, and in substance resembles the graduated administrative sequence applied by other regulators, such as the ladder in Indonesia's environmental sanctions regime.

Read the full regulation in the CRPG Law Database.

Methodology: This memo summarises the official regulation text and is not legal advice; report corrections to contact@crpg.info.

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