SOE SPI after Law 16/2025: BP BUMN, Audit Committee, and the Rules in Force

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Since October 2025, SOE governance has changed quite fundamentally. Law 16/2025 turned the Ministry of SOEs into the SOE Regulatory Agency (BP BUMN), changed the BPK (Audit Board)'s authority to audit SOEs, and moved the regulation of audit committees to BP BUMN regulations. On 21 August 2026, Government Regulation 38/2026 on SOE Management was also issued. The practical question for the Internal Oversight Unit (SPI): which rules are still in force?

Regulatory changes in 2025 to 2026 that affect this topic are summarized in the article audit and oversight regulation update 2026.

This article maps the provisions on the SPI, audit committees, and external audits of SOEs from the text of the regulations, while flagging the parts whose status is still uncertain. References checked as of 23 October 2026. For an overview of how internal audit software is used in SOEs, read the article SOE internal audit applications.

What Changed in the 2025 SOE Law?

A correction to a common assumption: the provision that the BPK (Audit Board) audits the financial management of Danantara (Article 3K) comes from Law 1/2025, not Law 16/2025, and was not changed.

What Does the Law Regulate about the SPI?

• Article 67: an internal oversight unit is formed in every SOE, led by a head who is accountable to the president director.
• Article 67A, duties of the SPI: assisting the president director in carrying out operational and financial examinations and assessing controls, management, and their implementation along with suggestions for improvement; submitting examination reports to the president director; and monitoring the follow-up of examination results.
• Article 68: at the written request of the Board of Commissioners or Supervisory Board, the Board of Directors provides information on the results of the SPI's work.
• Article 69: the Board of Directors must pay attention to and promptly take action on every SPI examination report.

Article 67A states that the scope of the SPI covers investment holdings, operational holdings, and SOEs, in line with the new structure. The implementation details of the SPI are in the implementing regulations, which we discuss next.

What Is the Status of PER-2/MBU/03/2023 on the SPI and the Three Lines?

SOE Ministerial Regulation PER-2/MBU/03/2023 on Guidelines for Governance and Significant Corporate Activities of SOEs contains the two provisions most relevant to the SPI.

Article 55 of BP BUMN Head Regulation 1/2026 on asset write-offs (15 October 2026) only revokes Articles 162 to 197 of PER-2. Articles 29 and 51 were not revoked. However, the JDIH BUMN page marks all of PER-2 as no longer in force, so its scope is broader than the wording of the revocation article. We found no BP BUMN regulation on governance, the SPI, or audit committees as of 23 October 2026. Caution is therefore reasonable: treat PER-2 as partly replaced, the SPI and three lines provisions as not yet revoked, and check JDIH BUMN periodically. That PER-2 remains operational after Government Regulation 38/2026 is an interpretation, not an explicit statement in any source.

What Is Regulated about SOE Audit Committees?

Law 16/2025 Article 70 and Government Regulation 38/2026 Article 58 (Persero) and Article 90 (Perum) require an audit committee and delegate the details to BP BUMN regulations. Until that regulation is issued, the available details are in two Ministerial Regulations from 2023:

• PER-3/MBU/03/2023 Articles 132 to 137: the committee chair is a member of the Board of Commissioners or Supervisory Board who is independent; non-board members at most 2 people (Article 123 paragraph 3); one member is independent or an accounting or finance expert and one understands the SOE business; the term of non-board members is a maximum of 3 years and they may be reappointed for a maximum of 2 years. The committee is directly accountable to the board. The text sets neither a minimum number of members nor a meeting frequency.
• PER-2/MBU/03/2023 Article 59: the audit committee's duties include monitoring and reviewing the effectiveness of internal and external audit, ensuring the objectivity and independence of auditors, recommending the SPI's audit plan, scope, and budget, and evaluating the SPI's periodic reports and performance.

The status of PER-3 is recorded as in force on JDIH BUMN as of 23 October 2026. That PER-3 remains the operational detail until a BP BUMN regulation is issued is an interpretation. A cross-sector comparison of audit committees is in the article komite audit.

How Do External Audit and BP BUMN Oversight Work?

• Public accountant: annual financial statements are audited by a public accountant determined by the GMS (general meeting of shareholders) for a Persero and determined by the head of BP BUMN for a Perum (Article 71 paragraph 1). Article 71A of Law 1/2025 refers to audits by public accountants registered with the BPK (Audit Board) and OJK.
• BPK (Audit Board): has the authority to audit SOEs (Article 71 paragraph 2) and to audit the financial management of Danantara (Article 3K of Law 1/2025).
• BP BUMN: Government Regulation 38/2026 Article 15 calls for compliance oversight of governance policies to be carried out in an integrated, risk-based manner, possibly through on-site inspections and review of periodic or incidental reports. Article 16 requires SOEs to report follow-up, with administrative sanctions in the form of a written warning or a proposed corrective action. Examinations by the head of BP BUMN are carried out after the President's approval (Article 18).

Government Regulation 38/2026 itself contains no article on the SPI or internal control. In the list of strategic policies set by Danantara, only risk management and internal oversight in general are listed.

What about Danantara's Oversight Organs?

Danantara's organs are the supervisory board and the executive agency (Article 3M of Law 1/2025). Government Regulation 10/2025 Article 9 states that the supervisory board is assisted by an audit committee, an ethics committee, and a remuneration and human resources committee, and Article 14 paragraph (2) letter a places the audit function with one of the members of the executive agency. The law does not mention an SPI at the level of Danantara itself. Government Regulation 19/2026 amends Government Regulation 10/2025 but does not change those articles.

What Are the Practical Implications for SOE SPI?

The following steps are an example of a working approach, not a regulatory provision.

1. Make sure the charter and reporting line are consistent with Article 67 of the Law and Article 29 of PER-2: the head of the SPI is accountable to the president director and reports reach the Board of Commissioners or Supervisory Board.
2. Document the three lines. Explain the role of the SPI as the third line and its boundary with risk management and compliance.
3. Monitor follow-up until completion. Article 69 requires the Board of Directors to act promptly on SPI reports, and Government Regulation 38/2026 Article 16 asks SOEs to report follow-up to BP BUMN. The practice is discussed in the article follow-up on internal audit findings.
4. Prepare evidence for examiners. The BPK (Audit Board)'s authority over SOEs is no longer limited as it was under Law 1/2025, so working papers, audit plans, and recommendation status need to be easy to trace. Risk-based priorities are discussed in the article risk-based audit for SOEs (BUMN) and BUMD.
5. Monitor BP BUMN regulations. Regulations on governance, the SPI, and audit committees are still awaited. Check JDIH BUMN before updating the charter.

What Cannot Yet Be Confirmed?

• We have not found an official copy of Government Regulation 38/2026 from a .go.id portal. The text was read from the State Secretariat copy available on a mirror site, and its State Gazette and Supplement numbers are consistent with those cited by BP BUMN Regulation 1/2026. Verify against the official source before citing it in formal documents.
• The status of PER-2 and PER-3 after Government Regulation 38/2026 and Law 16/2025 is a matter of interpretation, as explained above.
• We found no BP BUMN regulation on governance, the SPI, or audit committees as of 23 October 2026. The JDIH list may be incomplete.

How Does Internal Audit Software Help the SPI?

Audithink does not replace the SPI, does not submit reports to BP BUMN, and does not assess governance compliance. Audithink is internal audit management software with six main features: risk assessment, audit planning, work program templates, notifications, follow-up monitoring, and automated reports. For the SPI, these features help prepare a risk-based audit plan, standardize work programs, remind teams of deadlines, and monitor follow-up on recommendations. Audithink is used in SOEs, including the MIND ID case study, and an overview for SOEs and government agencies is in the article Audithink for SOEs and government agencies.

FAQ on SOE SPI and Law 16/2025

Conclusion

For SOE SPI, the 2025 and 2026 changes are no reason to postpone work: the basic obligations remain, namely an independent function, reports that reach the Board of Directors and the board, and follow-up that gets completed. What has changed is who the regulator and examiners are, so well-organized evidence of the work matters even more.

If your SPI wants to tidy up its audit plan and follow-up monitoring, schedule an Audithink demo.