Overview

The Supreme Court of the Republic of Indonesia issued Supreme Court Regulation (PERMA) No. 4 of 2025 on 17 December 2025. This regulation was enacted to provide legal certainty and procedural guidance for the Financial Services Authority or Otoritas Jasa Keuangan (OJK) in exercising its
authority to file lawsuits in the interest of consumers and the public. Although the OJK Law already recognizes OJK’s authority to initiate lawsuits (institutional standing),specific procedural rules on the submission, adjudication, and enforcement of such claims before the courts had not previously been established. This Supreme Court Regulation was introduced to address the regulatory gap and to strengthen the existing civil procedural framework.(1) In principle, this regulation reinforces the role of the State, through OJK, as a counterbalancing force in the relationship between consumers, who are often in a weaker position, and Financial Services Business Actors or Pelaku Usaha Jasa Keuangan (PUJK).(2)

Key Highlights

• Jurisdictional Separation
This Supreme Court Regulation clarifies the allocation of court jurisdiction based on the
operational principles of Financial Services Business Actors (PUJK), whereby disputes
involving conventional PUJK fall under the jurisdiction of the Commercial Courts, while
disputes concerning PUJK operating under Sharia principles are exclusively adjudicated by the
Religious Courts.(1) This jurisdictional separation is intended to reinforce the role of the
Religious Courts in safeguarding public interests within the Islamic economic sector.(3)

• Legal Standing of OJK
OJK can file a lawsuit without requiring a special power of attorney from consumers.(1) The
purpose of the lawsuit includes the recovery of assets belonging to the aggrieved party and/or
obtaining compensation for losses resulting from violations of laws and regulations in the
financial services sector.(4)

• Consumer Registration Mechanism
Before filing a lawsuit, OJK is required to announce the list of consumers to be included in the
lawsuit through its official website, newspapers, and notice boards at OJK offices.(1)
Consumers have the right to opt out of the list within a certain period.(1) Those who choose to
opt out may file their own individual lawsuit. However, consumers who do not opt out and are
included in a final and binding court decision cannot file a lawsuit on the same matter later.(1)

• Special Procedural Law and Expedited Resolution
The court proceedings are designed to be faster and more streamlined than ordinary civil
litigation, with judgments required to be rendered within 60 days from the first hearing.(1) The
examination process is conducted through limited procedural stages and does not recognize
replies, rejoinders, counterclaims, interventions, or final submissions.(1) All filings and
procedural stages are conducted electronically.(1)

• Limited Legal Remedies
To accelerate legal certainty, this Supreme Court Regulation streamlines the available legal
remedies. Decisions rendered at the first-instance court may only be challenged through a
cassation of appeal to the Supreme Court, without undergoing an intermediate appeal
process.(1) The cassation application must be filed within 14 days from the date the decision
is rendered.(1)

• Execution and Distribution of Compensation
Where a claim is granted, OJK plays a central role in the enforcement process. The distribution
of compensation to consumers is carried out directly by OJK following the execution of the
court’s decision.(1) The ruling must expressly stipulate the method of distribution, whether on
a pro rata basis, meaning distribution proportionately according to an exactly calculable
factor,(4) or pari passu, meaning distribution at an equal rate or pace or through another lawful
mechanism.(5) Consumers are not required to bear court costs up to the implementation of
the judgment.(6)

References
1. Peraturan Mahkamah Agung Republik Indonesia Nomor 4 Tahun 2025 tentang Tata Cara Mengadili Gugatan yang Diajukan oleh Otoritas Jasa Keuangan Sebagai Upaya Pelindungan Konsumen. https://jdih.mahkamahagung.go.id/legal-product/perma-nomor-4-tahun-2025/detail

2. Fitri A. Sinergi Keadilan, Kepastian Hukum, dan Perlindungan Konsumen Jasa Keuangan dalam Peraturan Mahkamah Agung Nomor 4 Tahun 2025. 2026. Available from: https://marinews.mahkamahagung.go.id/artikel/sinergi-keadilan-kepastian-hukum-danperlindungan-konsumen-0Lf

3. Putra  AUS.  Pengadilan  Tinggi  Agama  Yogyakarta  Perkuat  Responsivitas  Hakim HadapiGugatan    OJK    melalui    Sosialisasi   PERMA    4    Tahun    2025.    2026.    Available from: https://marinews.mahkamahagung.go.id/berita/pta-yogyakarta-gelar-sosialisasi-perma-4-
tahun-2025-0ME4.         Merriam-Webster     Dictionary.     Pro      Rata.     Available     from:     https://www.merriam- webster.com/dictionary/pro%20rata
5. Merriam-Webster    Dictionary.    Pari     Passu.     Available     from: https://www.merriam- ebster.com/dictionary/pari%20passu
6. Yudi  AL.  OJK Terbitkan Peraturan Gugatan untuk  Pelindungan  Konsumen. 2026. Available from:  https://www.tempo.co/ekonomi/ojk-terbitkan-aturan-gugatan-untuk-perlindungan- konsumen-2108475

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