Beneficial ownership transparency in Indonesia: scoping study

Conclusion

Indonesia has made significant advances in its work on beneficial ownership transparency. The country has legislated for a central register under the MLHR, and requires all domestic entities to report their beneficial ownership information to this body. Government agencies continue to seek to improve the quantity and quality of available BO information firstly by seeking to drive up compliance rates for the MLHR register, and secondly by making efforts to harmonise and link existing BO records held by diverse government agencies.

There are a number of areas identified in this report where further improvements to Indonesia’s disclosure regime are possible. These include increasing comprehensiveness by requiring disclosures by foreign entities operating in Indonesia, and making reporting requirements more precise for different sorts of legal entities, as well as making minor modifications to the legal definition to cover more sorts of ownership and control. The Indonesian government has expressed a keen interest in developing its data verification systems, which is commendable, although a design will likely prove difficult to finalise while data sharing mechanisms are still to be harmonised. In the interim, there is significant scope for improving data quality by making a series of tweaks to declaration form design and data collection processes which would allow for a fuller range of corporate and individual situations to be accurately reflected in the data. In addition, the implementation of more robust sanctions for non-compliance with BO legislation could also help encourage higher compliance rates. Collectively, these measures would assist Indonesia to improve the quality and quantity of BO data collected, gain greater utility from the information gathered and realise its wider policy goals.