The Indonesia Stock Exchange (IDX) has replaced the listing rules issued in March 2026 (the March Listing Rules) with Board of Directors Decree No. Kep-00152/BEI/10-2026 on the Amendment to Regulation No. I-A on Listing of Shares and Equity Securities other than Shares Issued by Listed Companies (the October Listing Rules). The October Listing Rules took effect on 9 October 2026. 

Compared with the March Listing Rules, the October Listing Rules do not change the following key requirements, which we discussed in our April 2026 bulletin on the new free float rules:

  • criterion for free float shares;
  • exclusion of pre-IPO minority shareholders from free float calculation at initial listing;
  • post-IPO lock-up requirements for controllers;
  • free float threshold for initial IDX listings, except that the minimum number of shareholders has now been increased (as discussed below);
  • ongoing free float requirements for IDX-listed companies, except that the minimum number of shareholders for IDX main board listings has now been increased (as discussed below);
  • transition period for complying with the new free float requirements; and
  • eligibility of specific shareholders to be treated as free float shareholders.

Key changes

However, the October Listing Rules have made several notable changes:

Significantly larger shareholder base at listing

In order to increase initial public free float, for companies seeking IPO listing, the minimum number of single investor identification (SID) holders at listing has increased from 1,000 to 10,000 for the IDX main board and from 500 to 5,000 for the IDX development board.

IPO price floor removed

The previous minimum IPO share price of IDR100 has been removed. This development also raises the question whether no-par-value shares may be permitted in the future.

Key changes to supporting documents submitted to IDX

A listing applicant company is now required to prepare financial projections for the next five years (previously three years), and the lead underwriters must conduct due diligence on those projections as one of their responsibilities in connection with underwriting the IPO.  In addition, the IDX has clarified that an equity research report prepared by the lead underwriters is required, reinforcing the requirements previously set out in the IDX Letter discussed in our August 2023 bulletin. 

New recognition of operating track record following restructuring

For a listing applicant company resulting from a restructuring, the October Listing Rules allow the required operating period of the same core business conducted by other entities under the same controller to count towards the applicant's required operating track record. This applies to both the 36-month main board and 24-month (previously, 12 months) development board operating history requirements. This change, first proposed in the draft March Listing Rules and now implemented in the October Listing Rules, provides a pathway for a recently restructured pre-IPO group company to proceed with an IPO without having to wait for the applicable operating history period to run anew after the restructuring.

Enhanced financial requirements for IDX main board listings

An IDX main board applicant must now have positive retained earnings and must satisfy one of the following financial requirements: 

  1. have market capitalisation of at least IDR100 trillion and equity of at least IDR10 trillion; or
  2. have net tangible assets (NTA) of at least IDR250 billion (for the last two audited financial years and the latest audited interim period, if any), together with at least one of the following:
    • average pre-tax profit of at least IDR100 billion for the last three financial years and market capitalisation of at least IDR1 trillion;
    • revenue of at least IDR800 billion and market capitalisation of at least IDR8 trillion;
    • total assets of at least IDR2 trillion and market capitalisation of at least IDR4 trillion; or
    • operating cash flow of at least IDR100 billion and market capitalisation of at least IDR4 trillion.

Enhanced track record and financial requirements for IDX development board listings

An IDX development board applicant must have been in commercial operation with revenue recorded for at least 24 months (previously, 12 months) and must satisfy one of the following financial requirements:

  1. have market capitalisation of at least IDR10 trillion and equity of at least IDR1 trillion; or
  2. have NTA of at least IDR50 billion (for the last two audited financial years and the latest audited interim period, if any), together with at least one of the following:
    • average pre-tax profit of at least IDR20 billion for the last two financial years and market capitalisation of at least IDR300 billion;
    • revenue of at least IDR100 billion and market capitalisation of at least IDR400 billion;
    • total assets of at least IDR250 billion and market capitalisation of at least IDR500 billion; or
    • operating cash flow of at least IDR10 billion and market capitalisation of at least IDR400 billion.

Pathway for applicants without positive retained earnings

A listing applicant that has negative retained earnings can list on the IDX development board as long as its financial projections demonstrate that positive retained earnings will be achieved by the end of the third financial year following listing.

Clearer timeline for resubmitting listing applications to IDX

A listing applicant whose application was initially rejected by the IDX may now reapply for a listing based on audited financial statements dated at least six months after the date of the financial statements upon which the rejection was based. For example, if the initial IPO application was based on audited financial statements as of 30 June 2026 and was subsequently rejected by IDX, the listing application may be resubmitted using audited financial statements as of 31 December 2026. This change incorporates existing IDX policy and practice into the October Listing Rules.

More stringent requirements to remain listed on the IDX main board

The October Listing Rules also introduce notable changes for continued listing on the IDX main board, including (i) having more than 1,000 SID holders as shareholders; and (ii) recording positive retained earnings in the latest financial statements.

Separately, the October Listing Rules broaden the mechanism for obtaining free float treatment by allowing a listing applicant to apply for certain shareholders to be recognised as free float shareholders where their shares are held for the benefit of public investors. This may facilitate concurrent IDX and offshore listings, as it provides a pathway for investors subscribing under the international offering tranche of an offshore listing to be recognised as free float shareholders to satisfy the IDX’s free float requirements for an initial listing. The application of this mechanism to a concurrent dual listing would require further discussion with the IDX but offers a welcome new basis for exploring such listings.

Key takeaways

The October Listing Rules reflect a further recalibration in the development of the IDX listing framework rather than a reversal of the changes introduced in March 2026. The core free float framework introduced by the March Listing Rules remains largely intact, while the October Listing Rules introduce three key changes affecting listing readiness and IPO structuring.

  • Higher bar for IDX listings. The October Listing Rules raise the threshold for IPO readiness overall, with significantly higher minimum shareholder numbers and expanded operational and financial requirements.
  • Greater flexibility for IPO structuring. The recognition of pre-restructuring operating history should facilitate pre-IPO restructurings, while the IDX development board continues to provide a pathway for eligible applicants without positive retained earnings.
  • Potential pathway for concurrent dual listings. The expanded free float recognition mechanism may facilitate concurrent IDX and offshore listings by allowing certain international offering investors to be recognised towards the IDX free float requirement. However, this application of the mechanism would need to be discussed with the IDX.

Overall, the October Listing Rules raise entry and continuing-listing thresholds in several important respects with a view to improving the substance of companies seeking IDX listing, while introducing more targeted flexibility for restructurings, and potentially concurrent IDX and offshore listings. Prospective listed companies should assess their proposed listing structure, operating history, financial position and shareholder distribution against the October Listing Rules at an early stage.

Please reach out to your usual contact if you would like to discuss how these changes might affect your plans for an IPO or listing in Indonesia.

Viska Kharisma Fajarwati photo

Viska Kharisma Fajarwati

Partner (Hiswara Bunjamin & Tandjung), Jakarta

Dandy Firmansyah photo

Dandy Firmansyah

Partner (Hiswara Bunjamin & Tandjung), Jakarta


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Viska Kharisma Fajarwati photo

Viska Kharisma Fajarwati

Partner (Hiswara Bunjamin & Tandjung), Jakarta

Dandy Firmansyah photo

Dandy Firmansyah

Partner (Hiswara Bunjamin & Tandjung), Jakarta

Capital markets David Dawborn Viska Kharisma Fajarwati Dandy Firmansyah