OJK sets Indonesian banks a new resilience planning test

Banks must decide how to use two new OJK instruments in planning before either becomes a dated supervisory requirement.

The Otoritas Jasa Keuangan (OJK) launched the Roadmap for the Development and Strengthening of Indonesian Banking, or RP3I, alongside updated Climate Risk Management and Scenario Analysis guidance, or CRMS 2026, on 2 October 2026. The release describes RP3I as a roadmap and CRMS 2026 as updated guidance. It does not specify a commencement date, reporting frequency or enforcement consequence for either instrument.

The immediate management decision is whether to treat the material as background strategy or as a basis for preparatory review. The evidence supports the second approach, without supporting a claim that OJK has already imposed new bank-level duties.

A roadmap spanning prudential and market functions

The RP3I sets five priorities for 2026-2030. They cover institutional capacity and integrity, technology modernisation and digital resilience, financial-market deepening and intermediation, sustainable finance and sustainability-risk resilience, and integrated licensing with adaptive supervision.

The first priority places capital, liquidity, governance, risk management and integrity within the same institutional capacity agenda. The third links expansion of banking products and activities under a universal-bank model with productive-sector financing, supply-chain ecosystems and Open Banking and Open Finance. The fifth combines integrated licensing with risk-based supervision, market conduct and sustainability-risk supervision.

That structure connects prudential resilience with OJK’s broader banking and financial-services remit. The release describes RP3I as part of the follow-up to Law No. 4 of 2026, which amended the 2023 Financial Sector Development and Strengthening Law, and says it is aligned with the 2025-2029 National Medium-Term Development Plan. Those references provide policy context, not a substitute for an operative rule specifying what a bank must do and when.

OJK’s stated starting figures are credit growth of 13.65 per cent year on year through August, third-party-fund growth of 10.92 per cent, a capital adequacy ratio of 24.1 per cent and gross non-performing loans of 2.11 per cent. The figures frame the roadmap as an attempt to preserve resilience while expanding intermediation and banking capacity.

The implementation architecture identifies four enablers: the supporting economic ecosystem, data, technology and digital infrastructure readiness, human-capital capacity, and cross-sectoral coordination among supervisors and authorities. For management, the supported response is a review of whether existing governance, data and technology arrangements can support the roadmap’s priorities. The release does not assign additional controls or responsibilities to particular banks.

CRMS 2026 supplies the technical reference point

CRMS 2026 is the more specific technical component. OJK describes CRMS as a framework integrating climate risk into governance, business strategy, risk management, measurement and targets, and disclosure.

The update has four identified components:

- Book 3 updates the methodology for calculating carbon emissions.
- Book 4 updates macroeconomic assumptions and climate scenarios.
- Book 5 expands physical-risk coverage.
- Book 7 introduces Standardized Solutions to support more structured and consistent implementation.

The mechanism is therefore broader than a disclosure exercise. The four updates affect the reference materials through which a bank may assess climate-related assumptions, exposure and targets. But the release does not say that CRMS 2026 changes regulatory capital weights, creates an automatic lending prohibition or imposes a new conduct rule.

Banks should obtain the CRMS 2026 books and map the four updates against existing climate-risk governance, scenario-analysis and disclosure processes. That is an operational recommendation drawn from the content OJK identifies, not a new obligation established by the press release. The source does not specify which banking cohorts are covered, whether implementation will be phased or how compliance will be assessed.

Book 7 may help standardise implementation, but its publication alone does not establish a reporting form, frequency or supervisory sanction. Those details would need to come from a further OJK instrument or dated supervisory instruction.

The next instrument will determine the consequence

RP3I is a published 2026-2030 roadmap and CRMS 2026 is updated guidance described in OJK’s release. Neither is presented in the supplied text as a final rule with a specified commencement date. The release also does not establish a transition period, application cohort or enforcement consequence.

That distinction limits what banks should conclude now. A bank can use the roadmap to organise planning around institutional capacity, digital resilience, intermediation, sustainability risk and adaptive supervision. It can use CRMS 2026 to test whether its climate-risk materials address the updated emissions methodology, scenarios, physical-risk coverage and Standardized Solutions. Neither step proves that OJK has already created a new capital requirement, reporting duty or sectoral lending restriction.

The next OJK circular, supervisory instruction or dated application notice will provide the decisive evidence. It should show whether the technical books become operative, which banks are covered and what timetable or evidence OJK expects. Until then, the instruments establish direction and reference material rather than a specified implementation obligation.