A New Era for Financial Conglomerates: Key Highlights from OJK Regulation No. 30 of 2024 (Indonesia)

Who is impacted?

Financial Conglomerate (Konglomerasi Keuangan) under the POJK 30/2024 is defined as a group of financial services institutions that operate under common ownership and/or control.

POJK 30/2024 introduces a clear requirement for controlling shareholders (Pemegang Saham Pengendali) and/or ultimate controlling shareholders (Pemegang Saham Pengendali Terakhir) of a Financial Conglomerate to establish a PIKK if the group meets one of the following thresholds:

1. The total consolidated assets of the financial group are at least IDR 100 trillion, and it includes at least two financial institutions (Lembaga Jasa Keuangan – “LJK”) operating in two different financial sectors; or
2. The total consolidated assets of the financial group are between IDR 20 trillion and IDR 100 trillion, and it includes at least three LJKs operating in three different financial sectors.

Although the IDR 100 trillion threshold has been there since POJK 45/2020, the OJK has introduced a “smaller” threshold to cover groups with total consolidated assets less than IDR 100 trillion. Under POJK 30/2024, smaller groups with total consolidated assets between IDR 20 trillion and IDR 100 trillion are also caught if they operate across three different financial sectors. This lower threshold is a big shift, bringing mid-sized groups into scope for the first time. On top of that, the OJK has expanded the definition of LJK to include not just banks, insurance companies, finance and securities companies, but also venture capitals, fintech players like P2P lenders and crowdfunding platforms.

Governance and ownership

Another important change introduced by POJK 30/2024 is the emphasis on clarity of ownership and control within Financial Conglomerates. POJK 30/2024 sets out detailed criteria for determining control and places restrictions on cross-ownership among group entities. While certain exceptions are allowed – such as minority ownership or relationships between parent and subsidiary companies – the overarching objective is to simplify group structures and enhance regulatory visibility.

Governance expectations under POJK 30/2024 have also been elevated. In addition to the existing requirement to prepare a corporate charter, Financial Conglomerates must now prepare a comprehensive corporate plan. This plan should outline, at the minimum:

1. the group’s strategic direction;
2. assess past performance; and
3. define a clear risk appetite.

The PIKK is expected to take an active role in guiding these efforts, ensuring that each entity within the group is aligned with the broader objectives. The shift reflects the OJK’s intention to hold larger, more complex financial groups to a higher standard of oversight and accountability.

Implications

For existing financial conglomerates, the transition to the PIKK model will likely require more than a simple adjustment. Some groups may need to establish a new holding company or restructure ownership arrangement to meet the new regulatory expectations. Beyond structural changes, there may also be a need to enhance governance practices – particularly in areas such as group-level coordination.

For groups that did not previously qualify under POJK 45/2020 but now fall within the scope of POJK 30/2024, the transition may present a different set of challenges. These newly qualified groups may not have existing structures in place to support group-level compliance or integrated governance. As a result, the introduction of the PIKK requirement may prompt a need to rethink how responsibilities are allocated across the group, how decisions are coordinated, and how risk is managed holistically.

These groups will need to begin by assessing whether they meet the updated criteria, both in terms of asset size and the number of financial institutions operating across different sectors. Once confirmed, they must determine the most appropriate PIKK structure, whether operational or non-operational. Establishing a PIKK may require not only legal restructuring, but also the development of entirely new governance frameworks, internal controls, and reporting mechanisms. From the OJK’s perspective, the regulatory expectation is that all qualifying groups, regardless of size or past regulatory experience, are expected to comply with the new requirements within the prescribed timeline.

Transitional periods

POJK 30/2024 provides a transitional period for companies to adjust to the new requirements. Entities that meet the criteria for a Financial Conglomerate under POJK 30/2024 must submit their application to establish a PIKK no later than 23 June 2025, which is six months from POJK 30/2024’s effective date. POJK 30/2024 also prescribed that qualification assessments will be based on financial reports as of 30 June 2024, giving institutions a clear reference point for determining whether they fall within scope.

Following the OJK’s approval of a PIKK application, Financial Conglomerates will have up to one year to complete any necessary restructuring to comply with the new framework, unless a longer period is granted by the OJK. This may include adjusting ownership structures and/or updating governance arrangements to align with POJK 30/2024.

Conclusions

POJK 30/2024 marks a decisive move in Indonesia’s ongoing efforts to strengthen the regulatory foundation of its financial sector. By redefining what constitutes a financial conglomerate and mandating the establishment of PIKK, the OJK aims to promote greater transparency and more consistent supervision across financial groups that operate under shared control or ownership. For many institutions, the transition to the new framework will involve more than compliance. In some cases, this may include establishing a new holding entity and revisiting existing shareholder arrangements.

POJK 30/2024 also brings into scope a broader range of financial groups that were not previously classified as conglomerates under the earlier framework. These newly captured groups should carefully assess whether they now meet the updated thresholds and, if so, begin evaluating the most appropriate structure for establishing a PIKK. More broadly, POJK 30/2024 encourages more coordinated implementation of risk management, governance, capital planning, and other key aspects across the financial conglomerate.