Jakarta. June 22, 2026. The government finally released the revised copy of the P2SK Law—which was enacted on June 4, 2026—to the public. However, the document was only circulated nearly three weeks after its public release. The public did not have time to examine the P2SK Law article by article. However, after its circulation, Section Eight, concerning Special Financial Instruments, included Article 50A, which regulates special debt securities, including Patriot Bonds and Merah Putih Bonds. This article is fraught with the interests of political elites and financial criminals because it provides immunity for those committing money laundering and other financial crimes.
CELIOS Economics Director, Nailul Huda, said, “The government needs significant funds to finance development and can no longer use the state budget. Development was ultimately handed over to Danantara, but like the government, they are also running low on liquidity. Therefore, Danantara issued debt securities, including Patriot Bonds and Merah Putih Bonds. However, to ensure that these bonds are purchased, the government guarantees that the funds are immune from the law.”
Huda added, “The purchase of special debt instruments (Patriot and Merah Putih bonds) enjoys special protection from the state from general criminal prosecution, tax crimes, and civil lawsuits. This means that money invested in special debt securities cannot be used as evidence of a crime. Corruptors and transnational money launderers who commit financial crimes can use this instrument to whitewash their profits, enjoying the investment interest paid by taxpayers through state-owned enterprises. This law aligns with the latest State-Owned Enterprises Law, which grants immunity to state-owned enterprise employees, including Danantara, from criminal liability for state financial losses.”
CELIOS Executive Director Bhima Yudhistira added that the reputational risk posed by the immunity granted to buyers of Danantara’s special debt securities also impacts the image of the Indonesian government. “Instead of improving the rule of law, particularly with strict regulations regarding anti-corruption and cross-border money laundering, the government is revising the P2SK Law to facilitate extraordinary crimes in the form of special debt securities. They are concerned that investors with high levels of ESG compliance will be reluctant to collaborate with Danantara. They could face reputational risk,” Bhima said.
Furthermore, it is not true that there were previously existing regulations providing legal protection from all lawsuits. In the 2002 SUN (Government Securities) Law, which also regulates ORI, investor protection refers to the state’s obligation to meet interest and principal payments on debt.
“Therefore, the regulation on special debt securities with immunity is indeed the first to be released in the 2026 revision of the P2SK Law,” Bhima said.
CELIOS Public Policy Director, Media Askar, added, “The Prabowo Subianto administration is rolling back Indonesia’s financial legal regulations. These regulations contain problematic clauses that provide special legal protection. Not only corruptors, but also tax evaders, those involved in transfer pricing, smuggling, and other economic crimes can divert their funds to these instruments and receive additional legal protection. This clearly contradicts global principles that continue to promote Anti-Money Laundering (AML) and beneficial ownership transparency.
Furthermore, the country also faces the potential loss of tax revenue because there is a clause stating that these instruments cannot be used as a basis for taxation. While other countries are promoting the principle of fair taxation, Indonesia is firmly opposing the Automatic Exchange of Information and Anti-Tax Avoidance Framework, which are being advocated by many countries around the world. This could cause Indonesia to be isolated from the global alliance that is working hard to combat tax evasion,” he said.
Contact Person:
Nailul Huda +62 85742232974
Access the press release in Bahasa Indonesia here.