Search for:

In brief

In a previous Client Alert (see here), we discussed a rule issued by the Financial Services Authority (Otoritas Jasa Keuangan – OJK) back in 2017 that requires all financial institutions and public and listed companies to prepare a sustainability report and submit it to OJK within a stipulated period. This obligation is set out under Rule No. 51/POJK.03/2017 on Implementation of Financial Sustainability for Financial Services Providers, Issuers and Public Companies (“OJK Rule 51“).

However, towards the end of 2020, OJK (i.e., the capital market division) issued a letter to all listed companies (“OJK Letter“), which effectively extends the deadline for certain types of listed companies to submit their sustainability report. This move is in response to a plea from the Indonesian Issuers Association for an extension and also in response to the ongoing COVID-19 pandemic crisis in Indonesia.

Key takeaways

Who does the deadline extension apply to?

Under OJK Rule 51, listed companies (except those with small-scale or medium-scale assets) must submit their sustainability report (setting out the eligible activities conducted in the financial year 2020) by 30 April 2021. However, by virtue of the OJK Letter, these listed companies now have a one-year extension as the deadline has been moved to 30 April 2022.

What is the new deadline?

Under OJK Rule 51 Under OJK Letter
Period of Sustainability Report 1 January 2020 to 31 December 2020 1 January 2021 to 31 December 2021
Deadline of submission to OJK 30 April 2021 30 April 2022


Please note that for listed companies with a financial year that ends on a date other than 31 December, the deadline to submit the sustainability report is the end of the fourth month after the end of their financial year.

Our Remarks

With this new deadline, listed companies will now have more time to prepare themselves to compile their activities in 2021 that may qualify to be reported in their 2022 sustainability report.

Please also bear in mind that at the end of 2020, OJK also issued a new draft rule on annual reports for public/listed companies, which sets out the required contents of sustainability reports. Listed companies should also consider this draft OJK rule when preparing their sustainability report next year.


Iqbal is the Head of the Capital Markets Practice Group. Iqbal has been involved in various capital market transactions, representing both issuers and banks/underwriters, in both equity and debt capital market. His work encompasses various sectors, including IT, plantations, healthcare, mining and transportation sectors. When representing issuers, Iqbal's work often also involves pre-IPO work. This includes assisting the issuer in putting in place the appropriate corporate and shareholding structures (which may include selling out or injecting new assets). Other than capital raising, over the years Iqbal has also been involved and led teams in doing most of the delisting and going private transactions in Indonesia. Iqbal has also been involved in debt issuance transactions, both USD and IDR denominations. Iqbal also regularly advises clients on various capital market issues such as disclosures, good corporate governance, related party and material transactions, and takeover issues.


Ario Putra Pamungkas is an Associate in Baker McKenzie Jakarta office.


Bernice Koean is an Associate in Baker McKenzie Jakarta office.