The Government has enacted Law Number 4 of 2026 (“Law 4/2026”) as an amendment to Law Number 4 of 2023 concerning the Development and Strengthening of the Financial Sector. One of the main changes introduced through this Law is granting authority to the Badan Pengelola Investasi Daya Anagata Nusantara (“BPI Danantara”) to issue debt instruments in accordance with statutory provisions. These instruments include general debt securities as well as special debt securities, including Patriot Bonds and Merah Putih Bonds, which are expected to expand national financing alternatives and support financial market deepening.

One of the key provisions drawing attention is the provision of legal protection for investors who purchase special debt securities, including Patriot Bonds and Merah Putih Bonds. This protection includes immunity against general and special criminal charges, including criminal provisions in the field of taxation, as well as civil lawsuits related to transactions involving these instruments. Furthermore, data and information arising from these special debt securities cannot be used as a basis for tax assessment or as evidence in judicial proceedings.

Law 4/2026 also reaffirms that investors—including Taxpayers who have participated in the Tax Amnesty Program or the Voluntary Disclosure Program—can still transfer or pledge these special debt securities, including Patriot Bonds and Merah Putih Bonds, without affecting their ownership rights over the instruments. However, provisions regarding the tax treatment of income generated from these instruments have not been specifically regulated under this Law and are pending further regulation through implementing regulations.

Overall, Law 4/2026 provides legal certainty for the issuance of and investment in special debt securities, including Patriot Bonds and Merah Putih Bonds, as new financing instruments. Further provisions regarding the issuance mechanism, management, execution of the instruments, and other matters will be further regulated by a Government Regulation.

This Law became effective as of 16 June 2026.