ISSN: 2442-3173 | en.hukumonline.

com Issue 3241 | 9 NOVEMBER 2017

Enforcement Date
27 September 2017 CLICK HERE
For Indonesian Version

Financial Services

• Related ILB

• OJK Redefines Provisions on Technical Provisions

Bank Examinations
• OJK Regulates
Implementation of
Commercial-Bank
Compliance
• New State Securities and
Investment Caps for
Investments Made by Non-
Bank Financial Services
Institutions
• New Provisions on Single-
Presence Banking Policy
• Technical Provisions on
Short-Term Liquidity Loans
for Conventional
Commercial Banks
for the Reporting and
Requesting of Debtor
Information through the
Financial Information
Services System
In order to participate in reporting and requests
for debtor information through the SLIK, reporters
are required to submit the following reports to the
OJK: 1) Comprehensive and accurate monthly
reports relating to debtor; and 2) Corrections to
reports of debtor information (if a submitted report
fails to meet the provisions set by the OJK).

The Financial Services Authority (Otoritas Jasa Keuangan – “OJK”) has issued Circular No.
50/SEOJK.03/2017 on Reporting and Requests for Debtor Information through the Financial
Information Services System (“Circular 50/2017”), which will serve as an implementation of OJK
Regulation No. 18/POJK.03/2017 (“Regulation 18/2017”).1
In essence, Circular 50/2017 establishes the Financial Information Services System (Sistem Layanan
Informasi Keuangan – “SLIK”) as a medium for the exchange of credit information between financial
institutions which are managed by the OJK,2 and replaces the now obsolete Debtor Information System
(Sistem Informasi Debitur - “SID”), which was managed by Bank Indonesia (“BI”) and which was
previously regulated under the following circulars (collectively referred to as “Previous Circulars”):3
1. BI Circular No. 7/63/DPBPR of 2005 on the Debtor Information System, as amended by BI
Circular No. 8/6/DPBPR of 2006 (“Circular 7/2005”); and
2. BI Circular No. 10/47/DPNP of 2008 on the Debtor Information System (“Circular 10/2008”).
1 Recitals, Circular 50/2017.
2 Section I.1, Circular 50/2017.
3
Section IX.2, Circular 50/2017.
 ISSUE 3241 | 9 November 2017
en.hukumonline.com
Technical Provisions for
the Reporting and
Requesting of Debtor
Information through the
Financial Information
Services System

Reporters under the SLIK

There are two types of reporters to consider within the context of reporting and requests for debtor
information through the SLIK, specifically mandatory and non-mandatory reporters. Details of each
reporter, as well as the procedure to be followed when seeking to become a reporter, are elaborated
upon in the table below

Reporters Procedures
1. Mandatory reporters, comprising:4 Parties are to be determined as mandatory reporters
5
a. Commercial banks (i.e., conventional banks, by the OJK with reference to the following timeline:
sharia commercial banks, and sharia 1. Mandatory reporters who have been registered
business units at conventional banks); with the SID will be automatically determined as
b. Rural Banks (“BPR”); reporters from 27 September 2017;
c. Sharia Rural Financing Banks (“BPRS”); 2. BPR, BPRS, FI, venture-capital companies,
d. Financing institutions (“FI”) which provide infrastructure-financing companies and
funding facilities (“Funding Facilities”); and pawnshops which have not been registered with
the SID prior to 27 September 2017 will be
e. Other financial institutions, which provide
determined as reporters by 31 December 2022 at
Funding Facilities (with the exception of
the latest;
micro-financial institutions).
3. Commercial banks which engage in business
activities after 27 September 2017 will be
determined as reporters with reference to the
commencement date of their various operational
activities; and so forth.
2. Non-mandatory reporters, comprising:6 Parties are to be determined as reporters through the
7
a. Other financial institutions, which provide following procedures:
information-technology-based money-lending 1. Submission of a written application signed by a
services (P2P Lending) and micro-financial director or related official to the Department of
institutions; and Licensing and Banking Information at the OJK,
b. Other non-financial institutions (i.e., credit along with a copy of an article of association,
unions). documentation outlining the relevant
organizational and human-resources structures;
and so forth;
2. The OJK will assess and approve the application
within ten business days of taking receipt of a full
set of completed documents;

4 Section II.1, Circular 50/2017.

5 For a complete timeline, see Section III.1, Circular 50/2017.
6 Section II.2, Circular 50/2017.
7
Section. III.2-III.4, Circular 50/2017.

2
 3. Once approved, the relevant reporter must then
submit a written application for a user ID and
password for the administrator that will be
responsible for the management of the SLIK
account, using the format set out under Appendix
I.A to Circular 50/2017.

By way of comparison, only commercial banks and BPR were determined as eligible reporters for SID
under the Previous Circulars.8

Debtor Information Reports

In order to participate in reporting and requests for debtor information through the SLIK, reporters are
required to submit the following reports to the OJK (“Reports”):9
1. Comprehensive and accurate monthly reports relating to debtor information (which contain
information on debtors, credit facilities [either in rupiah or in foreign currencies], collateral,
guarantors; and so forth);10 and
2. Corrections to reports of debtor information (if a submitted report fails to meet the provisions set by
the OJK).

Reports must be submitted online through the SLIK using the format set out under Appendix IV to
Circular 50/2017.11 However, in cases where any technical issues arise, reporters are allowed to
submit their Reports manually to the OJK in form of digital files which are generated from the relevant
SLIK application and which have been stored on a compact disc or USB flash disk, along with written
notification which follows the format set out under Appendix III to Circular 50/2017.12

Requests for Debtor Information

Information on debtors (“Information”) can only be requested through the SLIK by eligible parties (i.e.,
reporters which have fulfilled their reporting obligations to the OJK, debtors, Credit Information
Management Institutions [“LPIP”] and other parties) and should be used for the following purposes
only:13

1. In order to support the process of Funding Facilities, in accordance with the prudential principle;
2. In order to implement risk management to support reporters’ operational activities; and/or
3. In order to identify the quality of debtors for the purposes of compliance with OJK provisions or
another authorized party.

8 Compare: Section II, Circular 50/2017 with Section II, Circular 7/2005 and Section II, Circular 10/2008.
9
Section I.3, Circular 50/2017.
10 For a complete list of information, see Section IV.2-IV.6, Circular 50/2017.
11 Sections IV.1 and IV.6.a, Circular 50/2017.
12 Section IV.6.b, Circular 50/2017.
13
Section V.2.b,Circular 50/2017.

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 ISSUE 3241 | 9 November 2017
en.hukumonline.com
Technical Provisions for
the Reporting and
Requesting of Debtor
Information through the
Financial Information
Services System

The scope of Information that can be requested by reporters and debtors is stipulated under Appendix
IV to Circular 50/2017, while the scope of Information that can be requested by LPIP and other
parties is stipulated under Appendix II to Circular 502017, including:14

1. Personal identities of debtors (i.e., names, addresses, occupations, office addresses, etc.);
2. Loan facility information (i.e., total effective plafond, number of creditors, etc.);
3. Credit or financing information (i.e., type of credit/financing, date of non-performing loan, category
of debtor, etc.);
4. Irrevocable Letter of Credit (L/C) information (i.e., number, type, expiry date); and so forth.

The Previous Circulars did not incorporate the LPIP as a party eligible to request debtor information
through the SLIK.15 Moreover, Circular 50/2017 now sets out more comprehensive debtor information
which can be requested by eligible parties in comparison with the Previous Circulars.16

Circular 50/2017 has been in force since 27 September 2017 and will repeal and replace the
Previous Circulars on 1 January 2018. DW

14 For a complete list of information, see Appendix II to Circular 50/2017 and Appendix IV to Circular 50/2017.
15 Compare: Section V, Circular 50/2017 with Section V, Circular 10/2008.
16
Compare: Appendices II and IV,Circular 50/2017 with Section V.B, Circular 10/2008.

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