--- title: "OJK Fit and Proper Test for Insurers: Roles, Rules, Timing" canonical_url: "https://www.jessonglobal.com/insights/fit-and-proper-test-ojk-insurance" last_updated: "2026-11-04T22:34:42.736Z" meta: description: "Insurance directors, commissioners, actuaries and internal auditors need OJK fit and proper approval before they act. See the rules, steps and timeline." "og:description": "Insurance directors, commissioners, actuaries and internal auditors need OJK fit and proper approval before they act. See the rules, steps and timeline." "og:title": "OJK Fit and Proper Test for Insurers: Roles, Rules, Timing" "twitter:description": "Insurance directors, commissioners, actuaries and internal auditors need OJK fit and proper approval before they act. See the rules, steps and timeline." "twitter:title": "OJK Fit and Proper Test for Insurers: Roles, Rules, Timing" --- Jesson Global — Home **For Employers**[**Sector Leadership Hiring**](https://www.jessonglobal.com/insights/topics/sector)Nov 4, 2026·14 min read # OJK Fit and Proper Test for Insurers: Roles, Rules, Timing Insurance directors, commissioners, actuaries and internal auditors need OJK fit and proper approval before they act. See the rules, steps and timeline. ![Jessica Baware](https://www.jessonglobal.com/_ipx/fit_cover&pos_top&q_76&s_44x44/cms-media/jessica-baware.jpeg) By [**Jessica Baware**](https://www.jessonglobal.com/about#team) Co-Founder & CEO, Jesson Global The OJK fit and proper test for insurance companies is the approval that a new controller, director, commissioner, sharia supervisory board member, internal auditor or company actuary must receive from Otoritas Jasa Keuangan (OJK) before taking up the role. It is governed by [~~POJK 27/POJK.03/2016~~](https://ojk.go.id/id/regulasi/Pages/POJK-tentang-Penilaian-Kemampuan-dan-Kepatutan-bagi-Pihak-Utama-Lembaga-Jasa-Keuangan.aspx), which tests integrity, financial reputation and competence. OJK must decide within 30 working days of receiving complete documents, and a rejected candidate can usually be proposed again only after six months. ## What is the OJK fit and proper test for insurance companies? It is OJK's assessment of the people who own, run or supervise an insurer, and nobody in a covered role may act until OJK approves them. POJK 27/2016 calls these people _Pihak Utama_ (key parties), defined as a party that "owns, manages, supervises and/or has significant influence" over a financial services institution ([~~OJK, POJK 27/2016, Pasal 1~~](https://ojk.go.id/id/regulasi/Pages/POJK-tentang-Penilaian-Kemampuan-dan-Kepatutan-bagi-Pihak-Utama-Lembaga-Jasa-Keuangan.aspx)). The rule applies across banks, securities firms, finance companies and pension funds, but insurers carry a longer list of covered roles than most. For insurers, guarantors and pension funds, OJK sets the working procedure in [~~SEOJK 23/SEOJK.05/2023~~](https://ojk.go.id/id/regulasi/Pages/Penilaian-Kemampuan-dan-Kepatutan-bagi-Pihak-Utama-Perusahaan-Perasuransian,-Lembaga-Penjamin,-dan-Dana-Pensiun.aspx), in force since 12 December 2023. In practice, a board hire at an insurer is a two-part project: you find the right person, and then the regulator has to agree with you. The same test is covered in Bahasa Indonesia, with a table for every type of financial institution, in our guide to [~~uji kemampuan dan kepatutan OJK~~](https://www.jessonglobal.com/insights/uji-kemampuan-dan-kepatutan-ojk). This article goes deeper on the insurance sector, where [~~POJK 23 Tahun 2023~~](https://ojk.go.id/id/regulasi/Pages/Perizinan-Usaha-dan-Kelembagaan-Perusahaan-Asuransi,-Asuransi-Syariah,-Reasuransi,-dan-Reasuransi-Syariah.aspx) adds board, certification and foreign-worker rules on top. ## Which insurance roles need OJK approval? Six roles at an insurance company need approval: the controller, directors, commissioners, sharia supervisory board (DPS) members, the internal auditor and the company actuary. POJK 27/2016, Pasal 2 ayat (2), lists them for insurers, and SEOJK 23/SEOJK.05/2023 names the same group for its procedure. | **Role at an insurer** | **Covered by the test?** | **Rule** | | --- | --- | --- | | Controller (_pengendali_) | Yes | POJK 27/2016, Pasal 2(2) | | Director | Yes | POJK 27/2016, Pasal 2(2) | | Commissioner | Yes | POJK 27/2016, Pasal 2(2) | | Sharia supervisory board (DPS) member | Yes | POJK 27/2016, Pasal 2(2) | | Internal auditor | Yes | POJK 27/2016, Pasal 2(2) | | Company actuary | Yes | POJK 27/2016, Pasal 2(2) | Two of these roles are not board seats, and employers often plan for them too late. The internal auditor and the company actuary are hired like senior managers, yet they need the same OJK approval as a director, so the hiring timeline is the same too. The approval comes before the work, and a shareholders' resolution does not replace it. Under Pasal 2 ayat (4), a candidate director, commissioner or DPS member who has not been approved may not act, "even if already approved and appointed by the RUPS" (the general meeting of shareholders). Put simply, a general meeting can choose a director, but only OJK can let that director start. ## What does OJK assess? OJK assesses three things for directors, commissioners and the other managing roles: integrity, financial reputation and competence ([~~POJK 27/2016, Pasal 4~~](https://ojk.go.id/id/regulasi/Pages/POJK-tentang-Penilaian-Kemampuan-dan-Kepatutan-bagi-Pihak-Utama-Lembaga-Jasa-Keuangan.aspx)). - ****Integrity**** covers legal capacity, good character (including no criminal conviction within a set period), a commitment to follow the rules, and not being on a barred list (Pasal 5). - ****Financial reputation**** means no bad (_macet_) loans or financing, and no link to a bankruptcy in the last five years, either as the bankrupt party or as a shareholder, director or commissioner found guilty of causing one (Pasal 6). - ****Competence**** means at least the knowledge and/or experience that supports running the institution (Pasal 8). For an insurer, POJK 23/2023 adds a concrete competence item. Directors, commissioners and executive officers must hold a risk-management competence certificate from a certified professional body (LSP), and for directors and commissioners this certificate "is one of the requirements" of the fit and proper assessment ([~~POJK 23/2023, Pasal 80~~](https://ojk.go.id/id/regulasi/Pages/Perizinan-Usaha-dan-Kelembagaan-Perusahaan-Asuransi,-Asuransi-Syariah,-Reasuransi,-dan-Reasuransi-Syariah.aspx)). In plain terms, a strong candidate without that certificate is not yet a complete application, so check it at shortlist stage. Some candidates cannot be proposed at all for now. Pasal 9 of POJK 27/2016 bars proposing someone who is in a legal process, in another fit and proper assessment, or under reassessment. That means a candidate who is already being assessed for a seat at another institution has to wait until that process ends. ## How does the process work, step by step? The insurer applies, OJK reviews the documents, the candidate presents and may be asked to clarify, and OJK issues a decision. The table below follows POJK 27/2016, with the insurance-sector procedure from SEOJK 23/SEOJK.05/2023. | **Step** | **What happens** | **Rule** | | --- | --- | --- | | 1. Self-assessment | The insurer assesses the candidate itself before applying and submits the result | POJK 27/2016, Pasal 17 | | 2. Application | The board of directors files the application with the required documents | POJK 27/2016, Pasal 10 | | 3. Administrative review | OJK checks the documents and the candidate's record | POJK 27/2016, Pasal 16 | | 4. Presentation and clarification | The candidate presents to OJK; clarification can follow, by video conference as the default | SEOJK 23/SEOJK.05/2023; POJK 27/2016, Pasal 18 | | 5. Decision | Approved or not approved, within 30 working days of complete documents | POJK 27/2016, Pasal 21 | The self-assessment is the step most worth doing well. Pasal 17 requires the institution to assess the candidate "first" before applying, so the insurer is expected to have checked integrity, finances and competence already. Put simply, OJK wants to see that you have done your own background check before it does one. Clarification is not automatic, and Pasal 18 names the cases where OJK may call one. Under that article, OJK may call a clarification when there is negative information about the candidate, when the candidate has no relevant experience at a financial institution in Indonesia, or when the candidate was rejected before. A candidate moving in from outside Indonesia's financial sector should therefore prepare to explain their experience in detail. The format changed in 2023, and the change matters for candidates based abroad. SEOJK 23/SEOJK.05/2023 says the presentation and clarification are held "face to face through video conference", while in certain conditions OJK can hold them in person at its office or another place it sets ([~~OJK~~](https://ojk.go.id/id/regulasi/Pages/Penilaian-Kemampuan-dan-Kepatutan-bagi-Pihak-Utama-Perusahaan-Perasuransian,-Lembaga-Penjamin,-dan-Dana-Pensiun.aspx)). In practice, the default is a video call, so travel should not hold up the schedule unless OJK asks for an in-person session. New insurers follow the same route at licensing stage. Under POJK 23/2023, Pasal 16, an application for a business licence must be filed together with fit and proper applications for the candidate key parties, assessed under the fit and proper POJK. So a new insurer cannot open with a temporary board and fix it later. ## How long does it take, and what does that mean for a hiring plan? OJK must decide within 30 working days after it receives a complete application ([~~POJK 27/2016, Pasal 21~~](https://ojk.go.id/id/regulasi/Pages/POJK-tentang-Penilaian-Kemampuan-dan-Kepatutan-bagi-Pihak-Utama-Lembaga-Jasa-Keuangan.aspx)). The clock starts at "complete", so missing documents push the date back. Thirty working days is about six calendar weeks at five working days a week, before public holidays. If the search itself takes four to eight weeks, which is the kickoff-to-placement range Jesson Global publishes for its own [~~executive search~~](https://www.jessonglobal.com/executive-search) process, the total from kickoff to a director who can legally act is roughly 10 to 14 weeks. That estimate assumes the self-assessment is prepared during the search and the documents are complete on the first submission. | **Stage** | **Estimated time** | **Basis** | | --- | --- | --- | | Search to accepted offer | 4 to 8 weeks | Jesson Global's published process | | Self-assessment and document pack | During the search | POJK 27/2016, Pasal 17 | | OJK decision | Up to 30 working days (about 6 weeks) | POJK 27/2016, Pasal 21 | | Total to a director who can act | About 10 to 14 weeks | Sum of the above | Put simply, a board seat at an insurer takes about a quarter of a year to fill from the day you start, so start before the current holder leaves. For a wider view of how long senior searches take in Indonesia, see our guide on [~~how long executive search takes~~](https://www.jessonglobal.com/insights/how-long-does-executive-search-take-in-indonesia-a-2026-complete-guide). ## What other POJK 23/2023 rules shape an insurance board hire? POJK 23/2023 sets the board size, limits other posts a director or commissioner may hold, and requires the risk-management certificate. These rules decide who is even eligible, so they belong in the brief before the search starts. | **Rule** | **What it says** | **Article** | | --- | --- | --- | | Board size | At least 3 directors and at least 3 commissioners; no more commissioners than directors | Pasal 76 | | Directors' other posts | No post as director, commissioner or DPS at an insurer or any other company | Pasal 77(1) | | Exception for directors | A director other than the president director may sit as commissioner of a controlled subsidiary for a functional task | Pasal 77(2) | | Commissioners' other posts | Commissioner or DPS seats at no more than 3 other companies that are not insurers, or are insurers in a different line | Pasal 78(2) | | Certification | Directors, commissioners and executive officers hold a risk-management certificate from an LSP | Pasal 80 | The rule on directors' other posts is the one that most often narrows a shortlist. A director of an insurer may not also be a director or commissioner at another company, with only the subsidiary exception for directors who are not the president director ([~~POJK 23/2023, Pasal 77~~](https://ojk.go.id/id/regulasi/Pages/Perizinan-Usaha-dan-Kelembagaan-Perusahaan-Asuransi,-Asuransi-Syariah,-Reasuransi,-dan-Reasuransi-Syariah.aspx)). In simple terms, a candidate with outside board seats has to give them up before joining, and that is worth raising in the first interview. The rules are recent, and they replaced older ones. POJK 23/2023 came into force on 22 December 2023, replaced POJK 67/POJK.05/2016 and revoked the concurrent-post articles of POJK 73/POJK.05/2016, according to OJK's regulation page. Our check of OJK's site and a search for amendments on 5 November 2026 found no later change. ## Can an insurer hire a foreign executive or actuary? Yes, but only in listed posts and functions, and only for a limited time. POJK 23/2023, Pasal 81, says a foreign worker employed by an insurer may hold only three posts: an expert who is an executive officer (_Tenaga Ahli yang merupakan Pejabat Eksekutif_), an actuary, or a consultant. They may handle only underwriting, actuarial, marketing and/or information-system functions. | **Post for a foreign worker** | **Maximum term** | **Other conditions** | | --- | --- | --- | | Expert who is an executive officer | 3 years, extendable once by up to 1 year | Paired with an Indonesian worker for knowledge transfer | | Actuary | 5 years, extendable once by up to 5 years | Actuary qualification; at least 3 years of insurance actuarial experience | | Consultant | 3 years, extendable once by up to 1 year | Specific project only; paired with an Indonesian worker | The insurer also has to show the post cannot yet be filled by an Indonesian worker, and it must meet the general manpower rules (Pasal 81 ayat (4)). The plan to use foreign workers must be in the business plan and reported to OJK at least 20 working days before the person starts, and each appointment is reported within 20 working days (Pasal 82 and 83). Put simply, a foreign hire at an insurer is planned a year ahead in the business plan, not decided in the month you need someone. Board seats are not on the Pasal 81 list, which covers foreign workers the insurer employs. If you are considering a foreign national for a director or commissioner seat, confirm the position with OJK before you start the search, because this article does not cover that question. The company actuary role has its own rules whatever the nationality. Every insurer must employ one company actuary to lead the actuarial function, and that person may not also be a director, commissioner, DPS member or other officer in the same company ([~~POJK 23/2023, Pasal 93~~](https://ojk.go.id/id/regulasi/Pages/Perizinan-Usaha-dan-Kelembagaan-Perusahaan-Asuransi,-Asuransi-Syariah,-Reasuransi,-dan-Reasuransi-Syariah.aspx)). The company actuary needs a licensed actuary qualification and at least three years of insurance actuarial experience. In practice, you cannot fill the actuary seat by giving the job to a finance director, so it needs its own search. ## What happens if a candidate is not approved? A rejected candidate cannot take up the role, and if the general meeting had already appointed them, the insurer must hold a general meeting to cancel the appointment ([~~POJK 27/2016, Pasal 26~~](https://ojk.go.id/id/regulasi/Pages/POJK-tentang-Penilaian-Kemampuan-dan-Kepatutan-bagi-Pihak-Utama-Lembaga-Jasa-Keuangan.aspx)). The candidate can usually be proposed again only six months after the decision (Pasal 27). There is one shorter route. If the rejection was about competence, the candidate may be proposed earlier for a different field at the same or a lower level in the same institution, at a similar but smaller institution, or at a different institution, with evidence that their competence has improved (Pasal 27 ayat (2) and (3)). In simple terms, a competence rejection closes that particular seat for six months, but not every seat. Approval is also not permanent. OJK cancels an approval when the information submitted turns out to be untrue (Pasal 28), and POJK 23/2023, Pasal 15, lets OJK reassess an insurer's key parties. So the self-assessment is not a formality, because errors found later can cost the company its director. ## How should an insurer plan its next board or actuary hire? Write the regulatory filters into the brief, search early, and prepare the self-assessment while candidates are still in process. A short checklist taken from the rules above: 1. Confirm the role is a key party under POJK 27/2016, Pasal 2, including internal auditor and company actuary. 2. Screen for outside board seats against POJK 23/2023, Pasal 77 and 78. 3. Check the risk-management certificate under Pasal 80. 4. For a foreign hire, confirm the post is on the Pasal 81 list and is already in the business plan. 5. Prepare the self-assessment and documents during the search, not after the offer. 6. Plan roughly six weeks for OJK after the file is complete. If you are weighing whether to run the search yourself or with a firm, our guide to [~~choosing an executive search firm in Indonesia~~](https://www.jessonglobal.com/insights/executive-search-firm-indonesia) sets out the questions to ask. When a board, actuary or internal audit seat at your insurer opens, our [~~executive search~~](https://www.jessonglobal.com/executive-search) team can map candidates who already meet the POJK filters and give you a shortlist of three to five vetted profiles, with support for the first 90 days after placement. ## FAQ ### **How long does the OJK fit and proper test take for an insurance company?** OJK must decide within 30 working days after it receives a complete application, under POJK 27/POJK.03/2016, Pasal 21. That is about six calendar weeks before public holidays. Missing or incomplete documents delay the start of that period, so the realistic timeline depends on how complete the first submission is. Add the time needed to find and agree terms with the candidate before the application. ### **Who needs a fit and proper test at an Indonesian insurer?** The controller, directors, commissioners, sharia supervisory board members, the internal auditor and the company actuary, as listed in POJK 27/2016, Pasal 2 ayat (2). Each of them needs OJK approval before acting in the role. A general meeting resolution alone is not enough, because Pasal 2 ayat (4) says an unapproved director or commissioner may not act even after appointment. ### **Is the OJK fit and proper test done in person?** For insurers, guarantors and pension funds, SEOJK 23/SEOJK.05/2023 says the presentation and clarification are held face to face by video conference. In certain conditions, OJK can hold them in person at its office or another place it sets. A candidate living abroad can usually take part without travelling, unless OJK asks for an in-person session. ### **Can a foreigner work in a senior role at an insurance company in Indonesia?** Under POJK 23/2023, Pasal 81, a foreign worker employed by an insurer may hold only three posts: an expert who is an executive officer, an actuary or a consultant. Their work is limited to underwriting, actuarial, marketing and/or information systems, for fixed terms. The insurer must include the plan in its business plan and report it to OJK at least 20 working days before the person starts. ### **What happens if a director fails the fit and proper test?** The candidate cannot take up the role. If the general meeting had already appointed them, the insurer must hold a general meeting to cancel the appointment, under POJK 27/2016, Pasal 26. The candidate can generally be proposed again after six months, or earlier for a different role or institution when the rejection was about competence. 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