GeneralRequirements
Adopts IFRS S1
How to identify and report sustainability-related risks and opportunities that could affect an entity's prospects: cash flows, access to finance, and cost of capital.
What are PSPK 1 and PSPK 2?
Standar Pengungkapan Keberlanjutan (SPK) is the umbrella name for Indonesia's sustainability disclosure standards, while PSPK (Pernyataan Standar Pengungkapan Keberlanjutan) is the name of each individual statement within it. The Sustainability Standards Board of IAI ratified the first two PSPK on 1 July 2025. Both adopt IFRS S1 and IFRS S2 issued by the International Sustainability Standards Board (ISSB).
Climate-relatedDisclosures
Adopts IFRS S2
Applies the same structure to climate-related risks and opportunities, and adds emissions, targets, and scenario analysis.
Effective for annual reporting periods beginning on or after 1 January 2027.
Early application is permitted. An entity that applies one standard early must apply the other at the same time.
Why is Indonesia adopting a global baseline ?
The Basis for Conclusions sets out a capital-markets argument: foreign investors in the domestic market, national companies seeking funding abroad, and exporters increasingly need sustainability information in a format aligned with ISSB Standards.
ISSB Standards are endorsed by IOSCO, the G20, and the ASEAN Capital Markets Forum. Using a shared baseline makes sustainability information easier to compare across markets and helps Indonesia stay competitive.
2024
IFRS S1 and IFRS S2 took effect for annual reporting periods beginning on or after 1 January 2024. A number of jurisdictions began introducing sustainability reporting requirements.
2025
ISSB-based obligations were established across various jurisdictions.
2027
PSPK 1 and PSPK 2 take effect in Indonesia.
Because the global standards have applied since 2024, issuers with a foreign parent, foreign investors, or large export buyers may be asked to supply ISSB-style data earlier, even though PSPK in Indonesia only applies to 2027 reporting. That demand comes from parent companies and trading partners, not from the domestic regulator.
Why does PSPK matter?
ReducingGreenwashing
Definitions of disclosure components are standardised and include quantitative aspects that can be evidenced, narrowing the room for unsupported environmental claims.
Transparencyand Accountability
Encourages internal accountability and provides clear metrics for carbon emissions, energy, and social impact, improving the credibility of information for investors.
GlobalCompetitiveness
As a local foundation aligned with global norms, PSPK helps attract foreign investors while supporting national commitments to the SDGs.
Two things that run in parallel
PSPK sets the disclosure baseline , while regulatory adoption by the Financial Services Authority (OJK) determines when, and which entities, must report.
17 Dec 2024
DSK IAI issued the Exposure Drafts of PSPK 1 and PSPK 2 for public consultation.
1 Jul 2025
DSK IAI ratified PSPK 1 and PSPK 2, Indonesia's first sustainability disclosure standards.
2026
OJK opened public consultation on the draft sustainable finance framework.
1 Jan 2027
The standards take effect for annual reporting periods beginning on or after this date.
2028
Under the 2026 OJK draft, reports for Group 1's first reporting period are published.
2027–2029
DSK IAI reviews reporting practice and ecosystem readiness on Scope 3 emissions and use of the GHG Protocol.
2027 is when the standards begin to apply to reporting prepared under them. That is not, in itself, a reporting obligation for every company.
It is the obligation to follow PSPK that is phased. The obligation to prepare a Sustainability Report continues to apply to all groups.
Application groups under the draft POJK
Group 1
Fiscal year 2027
KBMI 3–4 banks (bank groupings by core capital), branch offices of foreign-domiciled banks (KCBLN), issuers and public companies on the Main Board and New Economy Board, stock exchanges, and certain operating financial conglomerates. Reports published in 2028.
Group 2
Fiscal year 2028
Medium and small bank groups, and Development Board issuers.
Group 3
Fiscal year 2030
Special Monitoring Board issuers, large investment managers, and entities with assets of at least Rp5 trillion.
Assets Rp50bn – Rp5tn
Not yet determined
The application year for entities with assets of Rp50 billion to Rp5 trillion has not been determined.
Four core content areas
PSPK 1 requires disclosure across four core content areas. PSPK 2 applies the same structure to climate-related risks and opportunities.
Gover-nance
The governance bodies and management responsible for oversight, including their mandates, expertise, processes, and controls.
Strategy
Risks and opportunities that could affect prospects, including their effect on the business model, value chain, strategy, and on financial position, performance, and cash flows.
Risk Management
The processes and policies to identify, assess, prioritise, and monitor risks and opportunities, and how they integrate into overall risk management.
Metrics and Targets
Mandatory and entity-specific metrics, together with targets, measurement methods, and progress against those targets.
Information must be connected across all four content areas and with the related financial statements. Risks and opportunities that give rise to a material adjustment to the carrying amount of assets or liabilities in the next annual reporting period must be disclosed.
POJK 51/2017 and PSPK: different disclosure focus
POJK 51/2017
SustainabilityReport
Sets the content of the sustainability report for entities in scope: strategy, governance, and economic, social, and environmental performance.
Scope: performance & programmes
PSPK 1 & PSPK 2
Sustainability-relatedFinancial Disclosures
Sustainability-related risks and opportunities are assessed by their potential effect on cash flows, access to finance, and cost of capital.
Scope: financial effects
The two frameworks do not replace one another. Where relevant, both can be applied at the same time.
PSPK 2: climate risk, opportunity, and resilience
PSPK 2 requires material disclosure of climate-related risks and opportunities that could reasonably be expected to affect an entity's prospects.
Physical Risk
Acute events such as floods, storms, and heatwaves, and chronic shifts such as rainfall, temperature, and sea level.
Transition Risk
Policy, legal, technological, market, and reputational effects of the shift to a low-carbon economy.
Opportunity
Potential positive effects arising from climate change, including mitigation and adaptation efforts.
Each risk must be classified as physical or transition, with the relevant time horizons and the current and anticipated effects on the business model and value chain.
Greenhouse gas emissions: three scopes, one value chain
PSPK 2 requires disclosure of absolute gross emissions in tonnes of CO₂ equivalent, measured under the GHG Protocol Corporate Standard (2004), unless the jurisdiction or exchange the entity is listed on requires another method.
Scope 3
UpstreamPurchased goods and services, capital goods, transport, business travel, and waste.
Scope 1 & 2
EntityDirect emissions from owned or controlled sources, plus indirect emissions from purchased electricity, steam, heat, and cooling.
Scope 3
DownstreamDistribution, processing and use of sold products, end of life, leased assets, franchises, and investments.
- Scope 2 is reported on a location basis, with information about contractual instruments for energy purchases that are not reflected in the location-based measure.
- Scope 1 and 2 are disaggregated between the consolidated accounting group and other investees such as associates and joint ventures.
- Financed emissions: asset managers, commercial banks, and insurers disclose emissions associated with their funding by industry and asset class.
Emissions are just one of seven cross-industry metric categories.
GHG Emissions
Transition Risk
Physical Risk
Climate Opportunities
Capital Deployment
Internal Carbon Price
Remuneration
Testing business resilience across warming scenarios
1.5°C
A rapid, ambitious transition to a low-carbon economy.
2°C
A moderate transition in line with the Paris Agreement.
4°C
High physical risk from unchecked warming.
The benefit: stakeholders can assess how ready the organisation is for extreme-weather risk, changes in carbon regulation, and shifts in market demand driven by climate change.
What the standard requires
PSPK 2 does not prescribe any particular temperature figure. What it requires is an approach commensurate with the entity's circumstances and the use of scenarios from authoritative sources, including consideration of scenarios aligned with the latest international climate agreement. The three pathways alongside are common practice, not a requirement of the standard.
What is asked for is not the raw output of the analysis but the entity's interpretation of that output and how the analysis was carried out. Disclosure covers the scenarios used and their sources, whether they relate to physical or transition risk, the time horizons, the scope of operations, and key assumptions on climate policy, macroeconomic trends, regional variables, energy mix, and technology developments.
The analysis may follow a multi-year strategic planning cycle, but the resilience assessment must still be updated each reporting period.
Every target explained in enough detail that progress can be tested
Basis of the target
The metric used, the objective of the target, the part of the entity it applies to, the period it covers, and the base period against which progress is measured.
Form of the target
Absolute or intensity, together with any milestones and interim targets set.
External context
How the latest international climate agreement and jurisdictional commitments inform the target.
Process
Whether the target and its methodology were validated by a third party, how the target is reviewed, and any revisions made.
Performance
Performance against each target, with analysis of trends or changes.
Net emissions targets
Must be accompanied by the related gross emissions target, and the net target must not obscure the gross figure.
Carbon credits
Any plan to use them must explain the extent to which meeting the target depends on them, the third-party scheme that verifies them, the type of credit, and other factors for assessing their credibility and integrity.
The first three years: transition relief
PSPK provides limited, optional relief during the first three years of initial application.
General
Year 1
Years 2–3
After year 3
Climate disclosure
Required
Required
Required
Non-climate topics
May be omitted
May be omitted
Required
Scope 3 emissions
Not required
Not required
Required
GHG Protocol
Prior method
Prior method
Required
Comparative information
Not required
Required
Required
A prior method may only be continued if it was used in the annual reporting period before initial application of PSPK 2. Source for each row: climate disclosure first and non-climate topics voluntary (PSPK 1 Appendix E, explained at DK26–DK32); Scope 3 emissions (PSPK 2 Par. C04(b)); GHG Protocol (PSPK 2 Par. C04(a)); comparative information (PSPK 2 Par. C03 and Par. C05, with the general provisions at PSPK 1 Par. 70–71.
Who needs to start preparing?
Issuers andPublic Companies
Map material risks and opportunities across the value chain; prepare connected sustainability and financial disclosures.
Boards andManagement
Clarify oversight and strengthen governance, risk management, and reporting processes.
Investors andCreditors
Assess the financial effects, assumptions, metrics, and targets in sustainability disclosures.
Timing, location, and the compliance statement
ReportingTiming
Disclosures are reported at the same time as the related financial statements and cover the same period. PSPK 1 adds an explanation absent from IFRS S1: "at the same time" means no later than when the annual report is published under the applicable laws and regulations.
Location ofClimate-related
Presented as part of the financial information report, generally known in Indonesia as the annual report. The standard does not prescribe a specific location, provided the disclosures are clearly identifiable and not obscured by other information.
Cross-referencing
Information may be incorporated by cross-reference to another report, provided it is available to users on the same terms and at the same time, and the referenced part is precisely identified. That information becomes part of the disclosure and is subject to the same requirements.
ComplianceStatement
Must be explicit and unqualified, and may only be made where the disclosures fully comply. An entity that uses the commercial-sensitivity or legal-prohibition exemption does not lose the right to state compliance.
Financial effects, uncertainty, and errors
The three provisions that most change how a report is prepared, because they demand documentation that has rarely been kept.
Current and anticipated financial effects
The entity discloses the effect of risks and opportunities on financial position, financial performance, and cash flows for the reporting period, and the anticipated effects over the short, medium, and long term. Quantitative information may be a single amount or a range. The entity need not provide it where the effects cannot be separately identified, measurement uncertainty is very high, or it lacks the skills and resources to do so, but it must still explain why, give qualitative information, and identify the affected financial statement line items.
Measurement uncertainty
Amounts with a high level of uncertainty must be identified, along with the sources of that uncertainty and the assumptions, estimates, and judgements applied. A high level of uncertainty does not in itself make an estimate less useful, provided it is described accurately.
Prior period errors
Material prior period errors are corrected by restating comparative amounts, unless impracticable. Disclosure covers the nature of the error, its correction, and where correction is impracticable, the circumstances that caused it.
The hierarchy of guidance sources and the relationship with GRI
First
The PSPK that applies specifically to that risk or opportunity
Second
SASB Standards: must be referred to and their applicability considered
Third
CDSB Framework Application Guidance, pronouncements of other standard-setting bodies, and disclosures by entities in the same industry or region
Fourth
GRI Standards and the European Sustainability Reporting Standards
Where GRI stands
GRI is named explicitly as a source that may be referred to, so the two frameworks can run alongside each other. But an entity that applies that source without applying the SPK requirements may not make a statement of compliance with SPK.
Their materiality is not equivalent
GRI uses impact materiality; PSPK uses financial materiality, conceptually similar to SAK. A topic can be material under one and not the other. Existing GRI disclosures therefore do not automatically satisfy PSPK, and a cross-index is not evidence of compliance.
Emission scopes across the four core content areas
Emission figures are disclosed only in metrics and targets, but all three scopes feed into the other three content areas.
Governance
Not the figures but the oversight: which body approves emissions targets, how often performance is discussed, and whether remuneration is linked to meeting them.
Strategy
Scope 3 defines the value chain boundary that must be explained. A transition plan must state which emission scopes it targets.
Risk management
Emissions concentration acts as a proxy for transition risk exposure; Scope 3 indicates supply chain vulnerability.
Metrics and targets
Where the figures are disclosed: gross emissions by scope, industry-based metrics, and targets with progress against them.
Emissions intensity is not required as a metric in its own right. Intensity appears as a choice of target form: an absolute target or an intensity target.
Preparation
Before 2027: what applies today
Standards for the current fiscal year
Reports for fiscal years 2025 and 2026 are still prepared under POJK 51/2017 and SEOJK 16/SEOJK.04/2021, generally with reference to GRI Standards. PSPK is not yet mandatory for those periods, which makes this the right window for gap mapping.
Assurance
Assurance over sustainability reports is not yet required, but the direction of policy and market expectation points that way. The main constraint is the limited number of domestic practitioners with the capacity to provide assurance. The consequence is that data traceability needs to be built now, as though the report will be examined.
Post-implementation review
DSK IAI will review reporting practice and ecosystem readiness across 2027 to 2029, covering Scope 3 emissions, use of the GHG Protocol, and non-climate disclosures. That review will inform the scope of subsequent disclosure requirements.
Because application is phased and some OJK provisions are still in draft, the scope of the obligation needs monitoring until the final provisions are issued.
Preparation for report preparers
Bilingual glossary
The official PSPK terms in Indonesian and English, not a loose translation of IFRS S1 and S2.
Gap mapping
A comparison of current reporting practice against PSPK requirements, with a dual GRI–PSPK index.
Data requests
Methodology, organisational boundaries, base year, emission factors, and assumptions, not just finished figures.
Figure consistency protocol
One traceable data source, shared by the financial statements, the annual report, and the sustainability report.
Technical capacity
GHG Protocol fundamentals, the logic of scenario analysis, and SASB-derived industry-based metrics.
The risk to guard against
PSPK demands measurable, traceable disclosure, which leaves the promotional language long common in these reports exposed. Every figure needs a source, every target needs a scope and a base year, and every forward-looking statement needs a reasonable qualification.
Official references
The texts of PSPK 1 and PSPK 2 are available through IAI's SAK Online. Regulatory context can be referred to OJK's Sustainable Finance pages, and the international comparison to IFRS S1 and IFRS S2 from the IFRS Foundation.
Paragraph reference index
Provided for tracing back to the text of the standards. Paragraph numbers are not carried in the body so as not to disrupt readability.
PSPK 1
- Objective and scope
- Par. 01–09
- Fair presentation
- Par. 11–16
- Materiality and its reassessment
- Par. 17–19; B13–B28
- Reporting entity
- Par. 20; B38
- Connected information
- Par. 21–24; B39–B44
- Core content: governance
- Par. 26–27
- Core content: strategy
- Par. 28–42
- Business model and value chain
- Par. 32
- Current and anticipated financial effects
- Par. 34–40
- Resilience to sustainability risk
- Par. 41–42
- Core content: risk management
- Par. 43–44
- Core content: metrics and targets
- Par. 45–53
- Sources of guidance; SASB and CDSB
- Par. 54–59
- GRI Standards and ESRS as sources
- Appendix C Par. C01–C03
- Location of disclosures and cross-referencing
- Par. 60–63; B27, B45–B47
- Reporting timing
- Par. 64–69, khususnya Par. 64A
- Comparative information
- Par. 70–71; B49–B54
- Statement of compliance and exemptions
- Par. 72–73; B33, B34–B37
- Judgements and measurement uncertainty
- Par. 74–82
- Errors and restatement
- Par. 83–86; B55–B59
- Effective date and transition provisions
- Appendix E; DK26–DK32
PSPK 2
- Objective and scope
- Par. 01–04
- Climate governance
- Par. 05–07
- Strategy: risks, opportunities, time horizons
- Par. 09–12
- Business model and value chain
- Par. 13
- Climate-related transition plan
- Par. 14
- Climate financial effects
- Par. 15–21
- Climate resilience and scenario analysis
- Par. 22–23; B01–B18
- Climate risk management
- Par. 24–26
- Metrics and targets
- Par. 27–28
- Cross-industry metric categories
- Par. 29; B64–B65
- Greenhouse gas emissions
- Par. 29(a); B19–B57
- Financed emissions
- Par. 29(a)(vi); B58–B63
- Capital deployment
- Par. 29(e)
- Internal carbon price
- Par. 29(f)
- Climate-related remuneration
- Par. 29(g)
- Industry-based metrics
- Par. 32
- Climate targets
- Par. 33–37; B66–B69
- Carbon credits
- Par. 36(e); B70–B71
- Effective date
- Par. C01–C02
- Transition provisions
- Par. C03–C05
Paragraph numbers follow the text issued by the Sustainability Standards Board of IAI and should be verified against SAK Online before being cited in a published document.