Intelligence Brief: Indonesia just made "finfluencer" distribution permissioned in the securities sector. With OJK Regulation No. 13/2025, effective December 11, 2025, securities firms may collaborate with influencers — but only inside a compliance cage: written contracts, a role framework with licensing triggers, and joint accountability. This is a structural shift from viral hype to auditable marketing.
01. The Problem: Retail Hype Became a Systemic Risk
Social channels turned into the default "broker onboarding funnel," but with no uniform standards: performance claims, hidden sponsorships, and pseudo-education content blurred lines. OJK's move is a direct attempt to reduce mis-selling and tighten market conduct without banning creators.
What Gets Regulated
- • Sponsored investment content
- • Client acquisition & referral funnels
- • Investment analysis & recommendations
- • Public claims about returns / safety
What This Is Not
Not a ban on influencers. It's a rule that securities firms must treat creator campaigns like any other regulated communication: supervised, documented, licensed.
02. The Control Stack: Contracts, Role Framework, and Disclosure
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Written Agreement + Defined Scope (Articles 106-109) Securities firms (PPE/PED) must have written contracts with influencers that explicitly define the scope of cooperation. The collaboration must be contractual — a liability bridge that ties the influencer's output to the firm's compliance function.
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Three-Tier Role Framework POJK 13/2025 creates a classification system defining which activities require licensing:
Education only: No license needed — can discuss markets generally without soliciting clients.
Client acquisition: Requires "Mitra Pemasar PPE" (PPE Marketing Partner) license.
Investment advice: Requires "Penasihat Investasi" (Investment Adviser) license for analysis/recommendations. -
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Content Responsibility & Oversight Securities firms are legally responsible for influencer content and must prepare promotional materials. With sanctions applying to firms for violations, internal oversight processes become essential compliance infrastructure.
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Mandatory Disclosure (Article 110) Influencer content must clearly state that the influencer is not an employee of the securities firm and does not hold OJK licensing (unless actually licensed), ensuring transparency with audiences.
Compliance Red Flags
- • "Guaranteed profit" language or misleading return claims
- • Hidden sponsorship, unclear compensation, or undisclosed affiliate structures
- • Providing investment advice/recommendations without "Penasihat Investasi" license
- • Client solicitation without "Mitra Pemasar PPE" license
03. Enforcement: Sanctions Apply to Both Sides
Joint Accountability Framework
OJK explicitly confirms that sanctions under POJK 13/2025 apply not only to securities firms but also to influencers who cause violations. This creates bilateral enforcement pressure.
- • Written warnings
- • Fines (amounts determined case-by-case)
- • Business restrictions / suspension
- • License revocation
- • Securities fraud under UU P2SK
- • Misleading information dissemination
- • Capital market manipulation charges
04. Market Context: Why Now
Explosive Growth, Concentrated Risk
Indonesia's capital market investor base surged from 2.5 million (2019) to 14.87 million (end of 2024), driven by app-based platforms and influencer marketing. A 2023 CELIOS survey found 70% of Indonesians trust finfluencers — nearly equal to certified advisers (69.5%).
High-profile cases like PT Waktunya Beli Saham (illegal fund collection of IDR 71 billion) and P2P lending collapses amplified regulatory urgency. POJK 13/2025 is OJK's first comprehensive response targeting the securities distribution layer.
What's Coming Next
OJK officials have signaled plans for a broader finfluencer regulation covering all financial products (not just securities), with implementation targeted for 2026. This may include mandatory certification requirements for influencers across banking, insurance, and investment products.
Analyst Outlook
"OJK didn't kill finfluencers — it formalized them. POJK 13/2025 creates a three-tier role framework: pure educators stay unlicensed, marketers need PPE partnership status, advisers need full licensing. The broker that wins in 2026 won't look like a meme machine — it will look like a regulated media house with compliance infrastructure, written contracts, and audit trails. The era of 'trust me bro' investment tips just got a legal framework."