The Criminal Code, which replaced the 1918 version, was enacted by Law No. 1 of 2023, while the Criminal Procedure Code, replacing the 1981 version, was adopted by Law No. 20 of 2025.

The updated Criminal Code introduces a number of changes, including those relating to corruption offences.

Criminal offences

Under Article 622 of the Criminal Code, a number of provisions of Law No. 31 of 1999 on the Eradication of Corruption Crimes are repealed. The relevant offences are now regulated exclusively by the Criminal Code, in particular:

• Article 2(1) of the Law (“Illicit enrichment”) – Article 603 of the Criminal Code;
• Article 3 of the Law (“Abuse of power”) – Article 604 of the Criminal Code;
• Article 5 of the Law (“Bribery of public officials”) – Article 605 of the Criminal Code;
• Article 11 of the Law (“Acceptance of gifts by public officials”) – Article 606(2) of the Criminal Code;
• Article 13 of the Law (“Giving gifts to public officials”) – Article 606(1) of the Criminal Code.

Sanctions for these offences have also been revised.

Imprisonment: For illicit enrichment, the penalty now ranges from 3 to 15 years’ imprisonment (previously – from 4 years to life imprisonment); for abuse of power – from 2 to 12 years (previously – from 1 to 20 years). For bribery, the bribe-giver now faces 1 to 5 years’ imprisonment, and the bribe-taker – 1 to 6 years (previously, the maximum sentence for both offences was 5 years). For acceptance of gifts by public officials, the sanction provides for up to 4 years’ imprisonment (previously – from 1 to 5 years); for giving gifts, the penalty remains unchanged – up to 3 years’ imprisonment. The possibility of imposing the death penalty (for illicit enrichment) and life imprisonment (for abuse of power) has been abolished.

Fines: For illicit enrichment and abuse of power, the criminal fine has been increased to up to IDR 2 billion (previously – from IDR 200 million to 1 billion for illicit enrichment and from IDR 50 million to 1 billion for abuse of power). For bribery of public officials, the maximum fine has been increased to IDR 500 million (previously – IDR 250 million [RUB 1.1 million]). For receiving and giving gifts, a uniform fine of IDR 200 million has been established (previously, the maximum fine for receiving gifts was higher – IDR 250 million, and for giving gifts lower – IDR 150 million).

Corporate liability

Another significant innovation of the new Criminal Code is the introduction of criminal liability for legal entities.

Under Article 45, liability may be imposed on legal entities in the form of limited liability companies, foundations, cooperatives, state-owned enterprises, regional enterprises or their equivalents, as well as associations – both registered and unregistered – and business entities in the form of limited partnerships or their equivalents.

Pursuant to Articles 46–48, an offence is deemed to have been committed by a company if it is committed by: (1) a manager holding a functional position within the organizational structure; or (2) a person who, under an employment relationship or other relationship, acts on behalf of or in the interests of the company; or (3) a person authorized to give orders, a person performing control functions within the company, or the beneficial owner acting outside the formal organizational structure but capable of exercising control over the company – provided that at least one of the following conditions is met:

• the act falls within the scope of the company’s activities as defined in its charter or other applicable documents;
• the act results in unlawful benefit to the company;
• the act is committed in accordance with company policy;
• the company failed to take measures to prevent or mitigate more serious consequences of the act or to ensure compliance with relevant rules aimed at preventing such conduct;
• the company intentionally allowed the criminal act to occur.

The minimum sanction for companies is set at IDR 200 million. The maximum fine depends on the specific offence; in particular, for offences punishable for individuals by life imprisonment or imprisonment of up to 20 years, legal entities may be fined up to IDR 50 billion.

In addition to fines, companies may be subject to supplementary sanctions, including:

• compensation for damage;
• confiscation of property or profits obtained as a result of the criminal offence;
• an obligation to eliminate the consequences of the offence;
• publication of the court decision;
• revocation of certain licences for up to two years;
• a permanent ban on certain activities;
• full or partial closure of facilities and/or business activities for up to two years;
• full or partial suspension of business activities for up to two years;
• liquidation of the company, among others.

A company may also be placed under special state supervision or control.