Indonesia - Tier D · Contained · Question to OJK
Posted: Sun Oct 11, 2026 9:41 am
Fijishi Jurisdiction Index 2026 · Entry ID · Published 12 October 2026
At a glance
1. The rules in Indonesia
Indonesia's financial services authority, OJK, has issued AI governance guidance for the banking sector (April 2025), but no AI instrument addressed to insurers was found. Two national AI Presidential Regulations are drafted but not signed.
OJK's regulation on risk management for insurers, POJK 28/2025, has been in force since 1 January 2026. It requires the risk management function to evaluate the accuracy of models and the validity of data used to measure risk, for firms that use models for internal purposes (Article 22(5)(g)). It does not mention AI.
Who these rules reach
This band describes how far the published record answers the question put to OJK. It is not a finding that OJK, or any firm it oversees, has fallen short of any rule.
Why the question goes to OJK: No Indonesian insurer's own published account of AI in underwriting, claims or pricing was found, so the question goes to the regulator.
The question
3. What the open question means for firms in Indonesia
Until OJK answers, an insurer or reinsurer in Indonesia that uses an AI model to assess risk in underwriting or claims has no published OJK statement on whether that model falls within the model-accuracy duty. This entry gives no band to any firm.
4. What this entry does not establish
Sources
None share a law or regulator with this entry.
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Commercial relationship with any party named here: None · Right of reply: indexreport.protocol@fijishi.com; with the sender's agreement, replies are published in full below the entry, dated · Cite as: Fijishi Jurisdiction Index 2026, Entry ID · Corrections: none.
At a glance
| Jurisdiction tier | Tier D - Not yet specified. No binding instrument that applies to insurers' own use of AI, and no issued regulator document addressed to this insurance market, sets out rules or expectations for AI. |
| Question to | OJK - whether a risk-model duty reaches AI decision models |
| Band for this question | Contained |
| Rules reach | Insurers: directly · Reinsurers: directly · Intermediaries: directly |
| Last verified | [actual date of the launch-window check] |
Indonesia's financial services authority, OJK, has issued AI governance guidance for the banking sector (April 2025), but no AI instrument addressed to insurers was found. Two national AI Presidential Regulations are drafted but not signed.
OJK's regulation on risk management for insurers, POJK 28/2025, has been in force since 1 January 2026. It requires the risk management function to evaluate the accuracy of models and the validity of data used to measure risk, for firms that use models for internal purposes (Article 22(5)(g)). It does not mention AI.
Who these rules reach
- Insurers: directly. Article 22(5)(g) applies "bagi PPDP yang menggunakan model untuk keperluan internal" (for insurance-sector companies, guarantee institutions and pension funds that use models for internal purposes). Article 2(2)(a) lists the perusahaan perasuransian it covers, including "perusahaan reasuransi" (reinsurance companies).
- Reinsurers: directly, under the same provision.
- Intermediaries: directly. Article 2(2)(a) also lists "perusahaan pialang asuransi", "perusahaan pialang reasuransi" and "perusahaan penilai kerugian asuransi" (insurance brokers, reinsurance brokers and insurance loss adjusters).
This band describes how far the published record answers the question put to OJK. It is not a finding that OJK, or any firm it oversees, has fallen short of any rule.
Why the question goes to OJK: No Indonesian insurer's own published account of AI in underwriting, claims or pricing was found, so the question goes to the regulator.
The question
In briefIndonesia's financial services authority, OJK, has issued AI governance guidance for the banking sector (April 2025), but no AI instrument addressed to insurers was found. Its regulation on risk management for insurers, reinsurers, guarantee institutions and pension funds, POJK Number 28 of 2025, in force from 1 January 2026, requires the risk management function "to evaluate the accuracy of models and the validity of data used to measure risk", for firms that use models for internal purposes (Article 22(5)(g)). If an insurer uses an AI model to assess risk in underwriting or claims, is that model within this duty in OJK's view? Or does the duty reach only the internal models an insurer uses to measure its own risks?
Why this band: No company's own account could be tested, so the question rests on the regulator's own published record.Indonesia's financial regulator has AI governance guidance for banks, but none addressed to insurers was found. Its 2026 risk-management rule for insurers requires checks on the accuracy of models used to measure risk. OJK has published nothing on whether an AI model used in underwriting or claims is one of those models. We found no regulator or company publication documenting AI use in underwriting, claims or pricing in Indonesia.
3. What the open question means for firms in Indonesia
Until OJK answers, an insurer or reinsurer in Indonesia that uses an AI model to assess risk in underwriting or claims has no published OJK statement on whether that model falls within the model-accuracy duty. This entry gives no band to any firm.
4. What this entry does not establish
- OJK's banking AI guide was read through its press release, not the guide itself.
- The status of the two Presidential Regulations rests on a government notice of February 2026 and press reports of September 2026.
- A reported right in the personal data protection law to object to automated decisions was not read.
- Whether any Indonesian insurer uses AI in these decisions. This entry says nothing either way.
- Launch-window check: signature of the two AI Presidential Regulations. If one is signed and in force, the tier is re-tested.
Sources
- Otoritas Jasa Keuangan, POJK Nomor 28 Tahun 2025 tentang Penerapan Manajemen Risiko bagi Perusahaan Perasuransian, Lembaga Penjamin, dan Dana Pensiun, ditetapkan 10 November 2025; in force 1 January 2026 (printed). Regulation, Indonesian. iis.or.id copy
- Otoritas Jasa Keuangan, Siaran Pers SP 67/GKPB/OJK/IV/2025, 29 April 2025 (printed). Regulator, Indonesian. ojk.go.id
None share a law or regulator with this entry.
________________________________________
Commercial relationship with any party named here: None · Right of reply: indexreport.protocol@fijishi.com; with the sender's agreement, replies are published in full below the entry, dated · Cite as: Fijishi Jurisdiction Index 2026, Entry ID · Corrections: none.