Regulation Watch · Business Licensing · Indonesia. The regulation applies nationally to conventional and sharia commercial banks, including Indonesian branches of banks headquartered outside Indonesia and conventional banks with sharia business units.
OJK Rewrites Business-Plan Rules for Commercial Banks
POJK 17/2026 requires commercial banks and foreign-bank branches to align annual business plans with risk, capital, technology, sustainability, ownership, foreign-worker and group strategies, with the new reporting framework starting for the 2028 plan cycle.
- Published
- Established by the Financial Services Authority on 21 September 2026 and promulgated on 30 September 2026 in State Gazette 2026 No. 28/OJK with Supplement No. 210/OJK.
- Effective
- 30 September 2026. The new planning and reporting format first applies to the 2028 Business Plan, first-quarter 2028 Realisation Report and first-semester 2028 Supervisory Report. The 2027 plan and reports remain under POJK 5/2016, subject to the specific 2027 disclosures stated in POJK 17/2026.
- Added to Watch
- 26 October 2026
Who is affected
Conventional and sharia commercial banks; Indonesian branches of foreign banks; foreign bank head offices and controlling shareholders; directors, commissioners and sharia supervisory boards; investors planning acquisitions, capital changes or divestments; and strategy, finance, risk, compliance, treasury, technology, sustainability, product, network, human-resources and foreign-worker teams.
Practical impact
POJK 17/2026 replaces the 2016 business-plan rule and turns the annual plan into a more integrated risk and governance document. Directors must prepare, implement and communicate it to shareholders and the organisation; commissioners must approve and supervise it; and a sharia supervisory board must give an opinion for a sharia bank or sharia business unit. The plan must align with the corporate plan, information-technology strategy, sustainable-finance action plan and other strategic plans. Its minimum scope now expressly covers funding, credit by sector and province, investments and divestments, capital, foreign-bank branch business funds and profit repatriation, foreign workers, outsourcing, products and office networks. The new format begins with the 2028 cycle, but a 2027 plan must already disclose a planned divestment and, for a foreign-bank branch, a planned change in business funds under the existing plan's other-information section.
OJK established POJK 17/2026 on 21 September 2026, and the regulation was promulgated and took effect on 30 September. It replaces POJK 5/2016 on commercial-bank business plans, while keeping non-conflicting implementing rules in force during the transition.
The regulation applies to conventional and sharia commercial banks and expressly includes Indonesian branches of banks headquartered abroad. A Business Plan must cover one year in detail and a three-year medium-term horizon, remain realistic and risk based, and reflect the bank's risk appetite, risk tolerance and risk-bearing capacity.
Governance responsibility is direct. The directors prepare and implement the plan and must communicate it to shareholders and every organisational level. The commissioners approve the plan and supervise execution. For a sharia commercial bank or conventional bank with a sharia business unit, the sharia supervisory board must issue an opinion on the plan.
The required content connects the plan to decisions that can matter to foreign investors and group headquarters. It includes dividend policy or, for a foreign-bank branch, fund withdrawal and profit repatriation; proposed equity investments and divestments; capital or business-fund changes; group strategy; foreign-worker use; outsourcing; products; technology; sustainability; and opening, moving, closing or changing the status of offices.
The standard annual submission deadline is 30 November before the plan year. A bank may change the plan once, no later than 30 June of the current year, when significant internal or external factors affect operations or performance. The changed plan may be implemented no earlier than 20 working days after submission. OJK may separately require an adjustment, which must be filed within 20 working days after notice.
Quarterly Business Plan Realisation Reports are due within one month after quarter end. Commissioner-led Business Plan Supervisory Reports are due within two months after each semester. The principal director signs the realisation report and the principal commissioner signs the supervisory report, subject to the regulation's authorised-substitute rules.
The transition is important for implementation planning. The 2027 plan and its reports still use POJK 5/2016. However, a bank must already place a planned divestment and, for a foreign-bank branch, a planned change in business funds in the 2027 plan's other-information section. POJK 17/2026 then governs the 2028 plan, the first-quarter 2028 realisation report and the first-semester 2028 supervisory report.
Required action
- Map every entity and governance body in the banking group that contributes to, approves, receives or supervises the Business Plan, including the foreign head office and the sharia supervisory board where applicable.
- Create one reconciled planning data set covering risk appetite, capital, financial projections, funding, credit, investments, divestments, technology, sustainability, products, office networks, outsourcing and foreign-worker use.
- For the 2027 plan, add any planned divestment and any planned change in a foreign-bank branch's business funds to the other-information section even though the remaining 2027 filing follows POJK 5/2016.
- Prepare the 2028 Business Plan under POJK 17/2026 and test its consistency with the corporate plan, information-technology strategy, sustainable-finance action plan and group strategy before director, commissioner and shareholder communication.
- Add a board calendar for the annual 30 November filing, the 30 June amendment cutoff, quarterly realisation reports, semester supervisory reports and any 20-working-day OJK adjustment request.
- Route every proposed change to the foreign-worker plan through the Business Plan change process and reconcile it with the separate OJK approval and knowledge-transfer requirements for foreign workers in commercial banks.
- Configure the OJK reporting workflow, signatory authority, completeness checks, version control and evidence retention before the first 2028 filings.