Internal Liquidity Adequacy Assessment Procedures Clarified: Commercial Banks Required to Begin One-Year Trial Reporting Ahead of December 2026 Initial Submissions

As the most recent amendment to Regulation of the Financial Services Authority (Otoritas Jasa Keuangan– “ OJK ”) No. 42/POJK.03/2015 , Regulation of the OJK No. 19 of 2024 (collectively referred to as “ Regulation 42/2015 ”) requires Conventional Commercial Banks (Bank Umum Konvensional– “ BUK ”) to implement the Internal Liquidity Adequacy Assessment Process (“ ILAAP ”) in order to assess the adequacy of their liquidity under various market conditions and stress scenarios, as may be faced by BUK. [1] Similarly, Regulation of the OJK No. 20 of 2025 (“ Regulation 20/2025 ”) also requires Sharia Commercial Banks (Bank Umum Syariah– “ BUS ”) and Sharia Business Units of BUK (Unit Usaha Syariah– “ UUS ”) to engage in the ILAAP process. [2]