Regulation Watch · Business Licensing · Indonesia. The regulation applies to commercial banks, including conventional commercial banks, sharia commercial banks, conventional commercial banks with a sharia business unit, foreign-owned Indonesian banks and branches of banks domiciled outside Indonesia. It is relevant to shareholders, directors, commissioners, sharia supervisory boards and bank planning, finance, risk, compliance, product, digital, capital, treasury and network teams. It does not impose a business-plan filing duty on an ordinary PT PMA that is not a commercial bank.
OJK Rewrites Commercial Bank Business Plan Duties
POJK 17/2026 immediately replaces the 2016 commercial-bank business-plan framework with wider risk-based planning, governance, reporting and supervisory duties.
- Published
- Established by OJK on 21 September 2026 and promulgated on 30 September 2026 in State Gazette 2026 No. 28/OJK, Supplement No. 210/OJK. OJK published its official implementation announcement on 15 October 2026.
- Effective
- 30 September 2026, the date of promulgation. POJK 5/POJK.03/2016 was revoked when POJK 17/2026 took effect.
- Added to Watch
- 18 October 2026
Who is affected
Commercial banks, including foreign-owned banks and Indonesian branches of overseas banks; bank shareholders and controlling shareholders; directors; commissioners; sharia supervisory boards; and strategy, finance, capital, treasury, credit, investment, product, digital, risk, compliance, corporate planning, reporting, internal audit, human resources, technology and office-network teams.
Practical impact
A commercial bank must treat its business plan as an operational and supervisory instrument rather than a stand-alone filing. The plan must be realistic, risk-based and aligned with the bank's strategic plan, prudential principles, governance, risk management and capacity. Its minimum coverage extends across management policy and strategy, risk and governance, performance, financial and ratio projections, funding and financing, capital participation and divestment, capital planning, organisational infrastructure, product strategy, digital and other service development, and office-network changes. Directors are responsible for preparing, implementing and communicating the plan; commissioners supervise implementation; and the sharia supervisory board must provide an opinion for a sharia bank or conventional bank with a sharia business unit. Submission, amendment, adjustment, evaluation, realisation reporting and supervisory reporting must use OJK's reporting system.
OJK established POJK 17/2026 on 21 September and promulgated it on 30 September in State Gazette 2026 No. 28/OJK, Supplement No. 210/OJK. It took effect on promulgation and revoked POJK 5/POJK.03/2016. The official OJK announcement published on 15 October confirms that the replacement is intended to make commercial-bank planning more adaptive to digital transformation, changing business models, industry complexity and risk-based supervision.
The regulation changes the status of the business plan from a compliance document into the bank's operating and supervisory reference. A bank must prepare a realistic, measurable and risk-based plan that observes prudential principles, governance and risk management and stays aligned with its wider strategic plan. This directly affects decisions on growth, funding, credit, products, digital investment, capital and distribution rather than only the regulatory-reporting team.
Governance responsibility is explicit. Directors prepare, implement and communicate the plan. Commissioners supervise its execution. For a sharia commercial bank or a conventional bank with a sharia business unit, the sharia supervisory board provides an opinion. Banks should therefore preserve approvals, challenge records, supervision evidence and the sharia opinion with the same version of the plan submitted to OJK.
The minimum plan scope is broad. It includes management policy and strategy, risk management, governance and performance, financial statements and ratio projections, funding and fund placement, capital participation and divestment, capital planning, organisational infrastructure, product strategy, office-network development and other information required by OJK. Group initiatives and shareholder decisions that affect these assumptions should be connected to the approved plan before execution.
POJK 17/2026 also governs submission, amendment, adjustment, evaluation and reporting through OJK's reporting system. This includes the business-plan realisation report and the commissioners' supervision report. A bank should map each reporting event to responsible owners, maker-checker controls, board review, submission evidence and reconciliation against actual financial, risk and operational data.
The regulation has applied since 30 September without a general grace period. Earlier implementing provisions remain effective only where they do not conflict with the new rule. Each affected bank should complete a controlled gap review now, confirm the next OJK reporting dates and forms, and avoid carrying forward a 2016 template without testing it against the new plan scope and governance duties.
Required action
- Rebuild the current business-plan checklist against POJK 17/2026 and identify every item that was not captured, or was treated only at a high level, under the revoked 2016 rule.
- Document board ownership: directors should approve, implement and communicate the plan; commissioners should set a documented supervision process; and the sharia supervisory board should issue the required opinion where a sharia bank or sharia business unit is involved.
- Reconcile the business plan with the bank's strategic plan, risk appetite, capital and liquidity capacity, governance framework, prudential limits, recovery planning and the assumptions used in financial and regulatory reporting.
- Expand the plan and its evidence pack to cover financial and ratio projections, funding, credit and other fund placement, capital participation and divestment, capital actions, organisational infrastructure, products and digital services, and office-network development or change.
- Update the OJK reporting workflow for initial submission, changes, regulatory adjustment requests, evaluation, the business-plan realisation report and the commissioners' supervision report, with maker-checker controls and an audit trail.
- Review every circular, template and internal procedure that implemented POJK 5/2016. Continue using an existing implementing rule only to the extent that it does not conflict with POJK 17/2026.
- Shareholders and group planning teams should align proposed capital injections, dividends, divestments, acquisitions, products, digital investments and network changes with the bank's approved plan before the bank makes commitments or regulatory submissions.