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Summary of the Detailed Assessment of Observance—Basel Core Principles for Effective Banking Supervision in Indonesia

Core Content Overview

This document is a detailed assessment of the observance of the Basel Core Principles (BCP) for effective banking supervision in Indonesia, prepared by the IMF and World Bank as part of the Financial Sector Assessment Program (FSAP). The assessment was conducted during the 2023 FSAP mission, reflecting the regulatory and supervisory framework in place at that time. It evaluates the Otoritas Jasa Keuangan (OJK), Indonesia's financial services authority, and its supervisory practices in relation to the 2012 BCP methodology. The assessment does not cover the overall state of the banking sector or crisis management framework, which are addressed separately.

Main Findings

A. Principles 1–2: Objectives, Powers, and Independence

• The OJK has made substantial progress in updating its regulatory and supervisory frameworks since the 2017 FSAP.
• The Financial Sector Omnibus Law (FSOL) enhances the OJK’s institutional setup, powers, and regulatory scope.
• The OJK's independence from government influence is a concern due to the presence of an ex-officio member (typically the Vice Minister of Finance) on the Board of Commissioners (BoC).
• Legal protection for supervisors is crucial to ensure they can perform their duties effectively without fear of adverse consequences.

B. Principles 3 and 13: Supervisory Cooperation and Cross-Border Supervision

• The OJK supervises both solo and consolidated bases, covering cross-border activities of Indonesian banking groups.
• However, there is a limitation in collecting data on unregulated entities within a group, which could expose risks that are not adequately monitored.

C. Principles 4–7: Licensing, Changes in Control, and Major Acquisitions

• The OJK has implemented Basel III post-crisis reforms and strengthened its licensing and control mechanisms.
• There is a need for more comprehensive definitions and governance requirements to address related party transactions and concentration risk.

D. Principles 8, 9, and 10: Supervisory Approach, Tools, and Reporting

• The OJK uses a six-point supervisory cycle, starting with the "Know Your Bank" phase, followed by frequent risk assessments and annual on-site examinations.
• The risk methodology is structured and covers key banking risks, but further enhancement is needed to make it more risk-sensitive and evidence-based.

E. Principles 11 and 12: Corrective Measures and Consolidated Supervision

• The OJK has broad powers for corrective measures, including written warnings, capital requirements, and license revocation.
• However, over-reliance on breach notices for minor non-compliance issues is a concern.
• A portfolio view of risks and integrated analysis of risk management and governance practices is needed for better supervision.

F. Principles 14, 26–28: Corporate Governance, Audit, and Financial Reporting

• The OJK has increased focus on corporate governance and introduced new standards.
• Holistic corporate governance assessments and routine meetings with independent non-executive representatives are recommended to improve standards.
• Stress testing and Internal Capital Adequacy Assessment Programs (ICAAPs) should be more integrated into the supervision process.

G. Principle 16: Capital Adequacy

• Indonesia’s capital buffers are relatively high, with CAR, Tier 1 (T1), and Common Equity Tier 1 (CET1) ratios at 25%, 23%, and 21% respectively as of 2023Q1.
• The FSOL strengthens the OJK’s powers to include non-financial and unregulated entities in its supervision, which is essential for a comprehensive risk assessment.

H. Principles 15, 17–25: Risk Management

• The OJK has made progress in risk management, but more depth of analysis and coverage of credit risks are required.
• A portfolio-level risk assessment and greater specificity in expectations for stress testing are recommended to ensure effective risk mitigation.

I. Principle 29: Abuse of Financial Services

• The OJK is working to implement Mutual Evaluation Review (MER) recommendations, including Customer Due Diligence (CDD) and Ultimate Beneficial Owner (UBO) identification.
• Indonesia has become a member of the Financial Action Task Force (FATF) since October 25, 2023, enhancing its AML/CFT framework.

Key Recommendations

• Enhance the independence of the OJK by limiting government influence, particularly through the BoC.
• Strengthen the risk methodology to make it more risk-sensitive and evidence-based, incorporating ICAAP, stress testing, D-SIBs, and recovery plans.
• Improve transparency and disclosure standards by implementing a more structured process to evaluate public disclosures.
• Encourage a portfolio view of credit risk and risk-taking to assess industry-wide standards.
• Expand the scope of supervision to include non-financial and unregulated entities within financial conglomerates.
• Integrate risk management and corporate governance practices more deeply into the Supervisory Review and Evaluation Process (SREP).
• Enhance cooperation with the Financial Intelligence Unit (FIU) for AML/CFT supervision.
• Implement routine meetings with independent non-executive representatives of the BoC to improve corporate governance.

Conclusion

The OJK has made significant progress in banking supervision, particularly with the implementation of Basel III and the FSOL. However, to meet the international standards set by the Basel Core Principles, it must strengthen its supervisory framework, enhance risk sensitivity, and ensure independence from government influence. The FSAP highlights the need for continuous improvement in risk management, corporate governance, and transparency to ensure the safety and soundness of the banking sector.