The enactment of Law No. 1 of 2025 on the Third Amendment to the State-Owned Enterprises ("SOE") Act introduces a notable change to the governance framework of Indonesian SOEs. One of the new key provisions formally affirms that members of an SOE’s board of directors, board of commissioners, supervisory board, and employees ("SOE Officials") are not classified as state administrators ("Non-State Administrator Status"). This development has significant implications for the enforcement of anti-corruption laws — particularly in relation to bribery and gratification offences — which require the involvement of a state administrator.

In this article, Dentons HPRP lawyers — Timothy Joseph Inkiriwang (Partner) and Yonathan Aji Pamungkas (Associate) — provide a brief analysis of the Non-State Administrator Status under the current legal framework. They explore the extent to which the amendment may impact corruption prosecutions and clarify that certain offences under the Anti-Corruption Act remain applicable to SOE Officials. Their insights offer a practical understanding of the amendment’s legal consequences for SOE Officials, anti-corruption enforcement, and corporate governance in Indonesia.

Read the full article here [English | Indonesia].

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