On 15 October 2026, Indonesia's Financial Services Authority (OJK) announced POJK Number 17 of 2026 on Commercial Bank Business Plans. The regulation was issued on 30 September 2026 and updates POJK 5/POJK.03/2016 on bank business plans. OJK's press release does not state when it takes effect, so check the full text of the regulation for that.

One thing needs saying up front: the title says commercial banks. Rural banks (BPR) and fintechs are not automatically covered. So why should a finance or operations team at a BPR or fintech read it anyway? Because partner banks will be asked about their realised numbers, and some of those numbers come from your data. That is our reading, not the wording of the rule.

The main message: a plan is not a formality

OJK put it in its own words: "Rencana Bisnis Bank tidak hanya merupakan dokumen pemenuhan kewajiban pelaporan", meaning a bank's business plan is not only a reporting-compliance document. The plan is framed as a tool for setting direction, growth strategy, and risk management. OJK also wants forward-looking supervision, with fuller information about each bank's direction and strategy.

The minimum contents are long: an executive summary, management policy and strategy, risk management in practice, governance and performance, projected financial statements and ratios, funding and fund-provision plans, equity investment and divestment, capital, organisational infrastructure, product delivery strategy, and office network changes. The plan must be realistic, risk-based, prudent, and consistent with the bank's strategic plan.

The split of duties is clear. The Board of Directors prepares, implements, and communicates the plan. The Board of Commissioners oversees execution. For sharia commercial banks and conventional banks with sharia units, the Sharia Supervisory Board gives an opinion.

Four layers holding roles in a bank business plan under POJK 17/2026: directors, commissioners, the Sharia Supervisory Board, and finance and operations data as the source of realised figures

Our reading: the plan will be set against what actually happened

One line in the press release is easy to skip. Reporting covers a Business Plan Realisation Report and a Business Plan Supervision Report, all through OJK's reporting system. So a plan does not finish when the directors hand in the document. It keeps being checked against reality.

Rakyatku reports that a gap between plan and realisation is not automatically treated as a violation. What gets assessed includes the bank's condition and the reasons behind the change. That is good news, with a catch: the reasons need to be shown in numbers. "The market was slow" is not an answer anyone can check.

At that point the work moves from the boardroom to the desks of finance and operations. Realised funding, product, and channel figures come from daily transactions passing through many doors: core banking, ATM switching, partner banks, billers, QRIS, connected fintechs. If the figures across those sources do not agree yet, nobody can explain why realisation differs from the plan, because the realised numbers themselves are still in dispute.

Five-stage business plan cycle: prepare and submit, execute, report realisation, get evaluated, then change or adjust, all through OJK reporting

The parts of the plan that depend on daily data

Re-read the minimum contents with data in mind. Financial projections and ratios are calculated from balances and entries. The funding plan depends on money flows per channel. Product delivery strategy means transactions have to be readable by channel. Every new channel or branch adds one more source to reconcile.

To be straight about it: POJK 17/2026 never mentions reconciliation. That is our conclusion. But the direction is hard to avoid. The more seriously plans are compared with realisation, the more expensive an unexplained gap becomes.

Seven parts of a bank business plan whose realised results depend on daily data, with the core point that realised figures are only as strong as the reconciliation

Three questions to try with your team this week:

  1. How long after close of day do the figures on every channel agree with the ledger? Hours, or days?
  2. For discrepancies still open today: who holds them, and how many days old are they?
  3. If an auditor points at one number, can it be traced to the original transaction in minutes rather than weeks?

If any answer is "it depends on who is in", a spreadsheet is carrying too much weight.

The order for fixing it

Healthy reconciliation is not a spreadsheet moved onto a nicer screen. The order looks like this:

  • Gather every source. Core banking, switching, partner banks, billers, and fintechs read in one place, not opened one by one.
  • Match with fixed rules. Matching keys and time tolerance are set once and apply to every transaction.
  • Gaps go to a queue. Mismatches do not sink among thousands of rows.
  • Fix through approval. The people who make, check, and approve a correction are different people.
  • Keep the trail. Who changed what and when is recorded automatically, ready to open on request.
Five steps for fixing reconciliation: gather every source, match with fixed rules, send gaps to a queue, fix through approval, and keep an audit trail

One way to tidy it up: SIRECONS

SIRECONS is a reconciliation and settlement system built by XETUP. It does not write a bank's business plan and does not make a bank automatically compliant with POJK 17/2026. What it does sits in the layer underneath: it reads files from many channels through per-channel templates, matches them with rules set once, sends discrepancies to a queue, requires corrections through a maker, checker, and approver, and keeps the audit trail. SIRECONS can be installed on the bank's own servers and connects to the user accounts the bank already has.

The result is not a prettier report. It is an answer to the earlier questions: who matched it, when, under which rule, and who approved the correction.

Talk through your situation first

No proposal needed. Message us on WhatsApp at +62 823 1499 5005 and tell us which channel is the hardest to reconcile. Example file formats can be anonymised. From there we can look together at whether reconciliation at your organisation is worth fixing now, or not yet.