{"url_path":"/sec/tlk/10-k/2026/item-3","section_key":"item-3","section_title":"Item 3 KEY INFORMATION**","topic":"sec","document":{"doc_type":"20-F","doc_date":"2026-05-15","source_url":"https://www.sec.gov/Archives/edgar/data/1001807/0001104659-26-062051-index.html","accession_number":"0001104659-26-062051","cik":"0001001807","ticker":"TLK","issuer_name":"PERUSAHAAN PERSEROAN PERSERO PT TELEKOMUNIKASI INDONESIA TBK","edgar_url":"https://www.sec.gov/Archives/edgar/data/1001807/0001104659-26-062051-index.html","primary_entity_key":"0001001807","primary_entity_name":"PERUSAHAAN PERSEROAN PERSERO PT TELEKOMUNIKASI INDONESIA TBK"},"word_count":48764,"has_tables":true,"body_markdown":"**ITEM 3.              KEY INFORMATION**\n\nA.**[RESERVED]**\n\n​\n\n**B**.           **CAPITALIZATION AND INDEBTEDNESS**\n\nNot applicable.\n\n**C**.           **REASON FOR THE OFFER AND USE OF PROCEEDS**\n\nNot applicable.\n\n**D**.           **RISK FACTORS**\n\n*An investment in our ADSs or shares involves risks. You should carefully consider the risks described below, as well as the other information included or incorporated by reference in this Form 20-F, before making an investment decision. Our business, financial condition or results of operations could be materially and adversely affected by any of these risks. The market or trading price of our ADSs could decline due to any of these risks, and you may lose all or part of your investment. In addition, the risks discussed below also include forward-looking statements and our actual results may differ substantially from those discussed in these forward-looking statements. Please note that additional risks not presently known to us, that we currently deem immaterial or that we have not anticipated may also impair our business and operations.*\n\n​\n\n22\n\n[Table of Contents](#TOC)\n\n**Summary of Risk Factors:**\n\n**Risks Related to Our Business**\n\nOperational Risks\n\n·\n\nThe telecommunications industry is characterized by intense competition and rapid technological change, and our ability to compete effectively depends on significant capital investment, access to sufficient spectrum, and successful adaptation to new technologies and market entrants.\n\n·\n\nOur business is highly dependent on the uninterrupted operation of our complex network infrastructure and information systems, which are vulnerable to disruption from operational failures, physical and cybersecurity threats, and other events beyond our control.\n\n·\n\nDamage to our reputation could negatively impact our business, financial condition, and results of operations.\n\n·\n\nWe face a number of risks relating to our internet-related services, including negative associations with and claims arising from content carried over our network or on the websites we host.\n\n·\n\nRevenue leakage might occur due to internal weaknesses or external factors and if this risk were to materialize, it could have a material adverse effect on our operating results.\n\n·\n\nExpected benefits from investment in new networks and technologies may not be realized.\n\n·\n\nWe rely on third parties to supply and maintain our network infrastructure, and they may be difficult to replace.\n\n●Our satellites have limited operational lives and they may be damaged or destroyed during in-orbit operation or suffer launch delays or failures. The loss or reduced performance of a satellite, whether caused by equipment failure or its license being revoked, may adversely affect our financial condition, results of operations and ability to provide certain services.\n\n●Actual or perceived health risks or other problems relating to radio emissions could lead to litigation or decreased mobile communications usage.\n\n●Health epidemics or pandemics and the economic disruption caused by various measures to reduce its spread have had and may continue to have adverse consequences of uncertain magnitude and duration on our operations.\n\nRisks Related to our Fixed and Cellular Telecommunications Business\n\n·\n\nContinuing growth in and the converging nature of wireless and broadband services will require us to deploy increasing amounts of capital and require ongoing access to spectrum in order to provide attractive services to customers.\n\n·\n\nOur continued investments in the construction of our infrastructure network may not adequately address the issues resulting from the substantial increases in data traffic or otherwise achieve the desired economic returns.\n\nRisks Related to the Development of New Businesses and Acquisitions\n\n●We may not succeed in our efforts to develop new businesses.\n\n●Expected benefits from partnerships with global technology companies may not be achieved.\n\n23\n\n[Table of Contents](#TOC)\n\n●Due to intense competition for highly skilled personnel, we may fail to attract, recruit, retain, and develop qualified employees, which could materially and adversely impact our business, prospects, financial condition, and results of operations.\n\n●If we are unable to manage our growth effectively, our business and financial results may be adversely affected.\n\n●Our acquisition activities expose us to various risks.\n\nFinancial Risks\n\n·\n\nIf we fail to maintain an effective system of internal control over financial reporting, we may be unable to accurately report our financial results or prevent fraud.\n\n·\n\nDeterioration of the financial condition of our customers could adversely affect our operating results.\n\n·\n\nWe are exposed to interest rate risk in relation to our bank borrowings.\n\n·\n\nWe may be unable to fund the capital expenditures needed for us to remain competitive in the telecommunications industry in Indonesia.\n\nLegal and Compliance Risks\n\n·\n\nWe are and may be subject to legal proceedings, claims and investigations, including for allegations relating to our public disclosures and disputes and litigation with regulators, competitors and other parties. If the outcomes of these proceedings, claims and investigations are adverse to us, our business, results of operations and financial condition could be materially and adversely affected, including because we may be subject to criminal or civil sanctions, or be required to restate our financial statements from prior periods.\n\n·\n\nIf we are found liable for anti-competitive practices, we may be subjected to substantial liability which could have an adverse effect on our reputation, business, financial condition, results of operations and prospects.\n\nRegulatory Risks\n\n·\n\nChanges to our legal and regulatory environment may result in increased competition, reduced margins and operating revenue, asymmetric reduction in costs incurred by our competitors and increased regulatory and enforcement uncertainty.\n\n●Indonesian regulations require telecommunications service providers such as ourselves to share our network infrastructure and capacity with our competitors, and the enforcement of these regulations remain uncertain.\n\n·\n\nApplicable regulations on tariffs and their implementation as supervised by MoCD may affect our revenues and earnings.\n\n·\n\nRegulations for the configuration of BTS towers may delay the installation of new BTS towers or changes in the placement of existing towers and may erode our leadership position by requiring us to share our towers with our competitors.\n\n·\n\nWe may experience local community opposition to some of our tower sites.\n\n·\n\nOur electronic money business is highly regulated.\n\n24\n\n[Table of Contents](#TOC)\n\n·\n\nWe are subject to numerous non-tax state revenue payments and USO Contribution and any disagreement with the relevant authorities relating to such payments and/or failure to make such payments could subject us to the revocations of certain of our licenses, with limited recourse.\n\nRisks Related to our Corporate Structure and Governance\n\n●We are subject to the control of the Government and its interests may not necessarily align with the interest of our other shareholders or our own interests.\n\n●We may experience further changes in governance as an SOE.\n\n●We are dependent on our subsidiary, PT Telekomunikasi Selular (\"**Telkomsel**\"), a cellular telecommunications services and cellular telecommunications networks company.\n\n●Our efforts to streamline our corporate structure may not create expected synergies and efficiency in a timely fashion or at all.\n\n●Our Articles of Association contain certain anti-takeover provisions that could adversely affect the rights of holders of our ordinary shares and ADSs.\n\n**Risks Related to Indonesia**\n\nPolitical and Social Risks\n\n·\n\nCurrent political and social events in Indonesia may adversely affect our business.\n\n·\n\nTerrorist activities in Indonesia could destabilize Indonesia, which would adversely affect our business, financial condition and results of operations, and the market price of our securities.\n\n·\n\nWe may be affected by uncertainty in the delineation of the respective prerogatives and responsibilities of, and the balance of power between, local governments and the central Government in Indonesia.\n\nMacroeconomic Risks\n\n·\n\nNegative changes in global, regional or Indonesian economic activity could materially and adversely affect our business.\n\n·\n\nFluctuations in the value of the Indonesian Rupiah may materially and adversely affect us.\n\n·\n\nRapid and excessive increases in levels of inflation and interest rates in Indonesia could materially and adversely affect our financial condition and results of operations.\n\n·\n\nDowngrades of credit ratings of the Government or Indonesian companies could materially and adversely affect our business.\n\n·\n\nUncertainty in respect of manpower legislation in Indonesia could materially and adversely affect our business.\n\nRisks related to Natural Disasters and Climate Change\n\n·\n\nIndonesia is vulnerable to natural disasters and events beyond our control, which could materially and adversely affect our business and operating results.\n\n25\n\n[Table of Contents](#TOC)\n\n·\n\nWe are exposed to the potential for financial loss and further non-financial detriments arising from climate change and society’s response to it.\n\nRisks related to our ADSs\n\n·\n\nThe trading price of our ADSs may be volatile, which could result in substantial losses to you.\n\n·\n\nIf securities or industry analysts do not publish research reports about us or our business, or if they adversely change their recommendations regarding our ADSs, the market price for our ADSs and trading volume could decline.\n\n·\n\nThe different characteristics of the capital markets in Indonesia and the U.S. may negatively affect the trading prices of our ADSs and shares.\n\n·\n\nOur financial results are reported to the OJK in conformity with IFAS, which differs in certain respects from IFRS, and we distribute dividends based on profit for the year attributable to owners of the parent company and net income per share determined in reliance on IFAS.\n\n·\n\nAs a foreign private issuer in the U.S., we are permitted to, and we have relied on and will rely on exemptions from certain NYSE corporate governance standards applicable to domestic U.S. issuers. This may afford less protection to holders of our ADSs.\n\n·\n\nAs a foreign private issuer in the U.S., we are exempt from certain disclosure requirements under the Exchange Act, which may afford less protection to holders of our ADSs than they would enjoy if we were a domestic U.S. company.\n\n·\n\nThe voting rights of holders of our ADSs are limited by the terms of the Deposit Agreement.\n\n·\n\nHolders of our ADSs may be subject to limitations on transfer of their ADSs.\n\n·\n\nHolders of our ADSs may not receive distributions on our ordinary shares or any value for them if it is illegal or impractical to make them available to the holders.\n\n·\n\nHolders of our ADSs may experience dilution of their holdings due to their inability to participate in rights offerings.\n\n·\n\nThe time required for the exchange between ADSs and shares might be longer than expected and investors might not be able to settle or effect any sale of their securities during this period.\n\n·\n\nWe are established in Indonesia and it may not be possible for investors to effect service of process or enforce judgments on us, our Commissioners, Directors, or officers within the United States, or to enforce judgments of a foreign court against us or any of these persons in Indonesia.\n\n​\n\n26\n\n[Table of Contents](#TOC)\n\n**Risks Related to Our Business**\n\nOperational Risks\n\nThe telecommunications industry is characterized by intense competition and rapid technological change, and our ability to compete effectively depends on significant capital investment, access to sufficient spectrum, and successful adaptation to new technologies and market entrants.\n\nThe Indonesian telecommunications market is highly competitive and dynamic. We face significant and evolving pressure from multiple sources, which could adversely affect our market share, revenue, and profitability.\n\nMarket Competition and Saturation\n\nOur cellular and data services face intense competition from other operators who continue to make long-term investments in network quality and expand their service offerings. In recent years, competitors have used promotional strategies, such as offering bonus data packages, which have reduced profitability across the market. As major urban markets like those in Java become saturated, this competition has expanded to other regions, requiring us to focus on defending our market share. We also face increasing pressure from non-market leaders who target specific customer segments, such as gamers or entertainment users, with flanking strategies that may erode our market share in these niches.\n\nIndustry consolidation further intensifies this competitive landscape. For a detailed discussion of the merger between PT XL Axiata Tbk and PT Smartfren Telecom Tbk in 2025, which has created a larger competitor.\n\nTechnological Disruption and New Entrants\n\nThe rapid pace of technological change continues to lower barriers to entry and introduce new forms of competition. For instance, the increasing number of smartphone users in Indonesia has fueled the growth of OTT services that substitute for our traditional voice and SMS services. This has directly affected the contribution of our legacy cellular phone services to our consolidated revenues, which has continued to decline from 5.5% in 2023 to 4.2% in 2024 and 3.0% in 2025.\n\nMoreover, we face new competition from satellite-based broadband services. Starlink officially began offering direct satellite broadband access to retail customers in Indonesia in April 2024, which may lead to heightened competition in the retail sector if such services develop more broadly in the future. While the effectiveness of satellite services can be limited in urban areas, Starlink’s “Direct-to-Cell” service, could in the future compete directly with traditional cellular networks, especially in rural or open areas.\n\nThe development and application of new technologies require substantial investment and present both opportunities and risks. We are selectively deploying 5G while considering ecosystem readiness, including spectrum availability, handset penetration, and use case development. In 2025, our 5G services developed further with the expansion of the Hyper 5G network primarily in Greater Jakarta, Greater Bandung, Surabaya, Makassar, and Batam, along with the launch of 5G use cases, including the deployment of 5G Private Network Standalone aiming to enhance operational efficiency, productivity, and competitiveness for smart factories and manufacturing industry. As of December 31, 2025, our 5G services covered more than 80 cities with a total of 4,913 5G BTS. Our 5G rollout is being conducted in a focused and gradual manner, paced by ecosystem maturity and demand in both B2B and B2C segments, and is intended to support broader digital connectivity and future technology solutions. However, if our rollout does not meet expectations for customer adoption or return on investment, it may negatively impact our financial condition.\n\nThe rapid development of AI may alter network traffic patterns, which may require substantial investments to reengineer our network topology without a proportional and concurrent increase in revenue. In 2025, we expanded the deployment of AI-related capabilities across our business, including Hitakari AI as our umbrella AI initiative, Veronika as an AI-enabled virtual assistant for customer service, TED as an AI-based virtual assistant for more complex and\n\n27\n\n[Table of Contents](#TOC)\n\nenterprise-related interactions, Autonomous Network for AI-enabled network planning, optimization and real-time event handling, and AI functionality embedded in the MyTelkomsel super app and Moana, our employee experience platform. We also continued to invest in analytics, automation and data-driven capabilities across our operations. However, we may be unable to sufficiently utilize big data and integrate it into our operations in a timely manner, which could impair our ability to innovate and transition our business models effectively.\n\nOur failure to acquire or effectively integrate new technologies on commercially acceptable terms could lead to our existing technologies becoming obsolete, materially and adversely affecting our business, financial condition, and prospects.\n\nSpectrum Availability and Network Capacity\n\nOur ability to accommodate future traffic growth, support new technologies like 5G, and maintain service quality is critically dependent on acquiring sufficient spectrum and expanding our network capacity. Spectrum is a scarce resource, and we expect our needs to increase with the growth of data services. We must acquire additional spectrum through Government auctions, but we cannot be certain that we will secure the allocations necessary for our strategic objectives.\n\nThe significant growth in data traffic, driven by smartphone applications, strains our existing network capacity. To manage this, we have been and may in the future be required to make significant capital expenditures to improve network coverage and secure additional spectrum. Limited or unavailable spectrum at suitable prices, or failure to win new allocations in Government auctions, would negatively impact our 5G deployment and overall growth strategy.\n\nIf we are unable to obtain sufficient spectrum or fund the necessary capital expenditures to manage network congestion and deploy new technologies, our network performance could degrade, damaging our reputation and competitive position, which could have a material adverse effect on our results of operations and financial condition.\n\nOur business is highly dependent on the uninterrupted operation of our complex network infrastructure and information systems, which are vulnerable to disruption from operational failures, physical and cybersecurity threats, and other events beyond our control.\n\nWe depend to a significant degree on the uninterrupted operation of our network infrastructure, systems, and connections to other networks to provide our services. For example, we depend on access to our fixed wireline network for the operation of our fixed-line services and for the termination and origination of cellular telephone calls to and from fixed-line telephones, as a significant portion of our cellular and international long distance call traffic is routed through the PSTN. We also depend on access to internet, broadband, and cellular networks, as our integrated network infrastructure includes a copper access network, fiber optic access network, BTSs, switching equipment, optical and radio transmission equipment, an IP Core network, satellites, and application servers. In addition, we rely on interconnection to the networks of other telecommunications operators to carry calls and data from our subscribers to the subscribers of operators both within Indonesia and overseas, and on technologically sophisticated management information systems and other systems, such as our customer billing system, to conduct our operations.\n\nOur network infrastructure and connected systems are vulnerable to damage or interruption from a variety of sources, including:\n\n•\n\n*Operational Failures and Natural Disasters*. Our systems are vulnerable to damage or interruptions in operation due to a variety of causes such as earthquake, fire, flood, power loss, equipment failure, network software flaws, transmission cable disruption, or similar events. As a geographically dispersed network in a region prone to natural disasters, our infrastructure is also susceptible to damage from earthquakes, fires, floods, and other catastrophic events. Past incidents have demonstrated our susceptibility to such damage or interruptions. In 2024, we faced significant infrastructure impacts due to natural disasters and accidents, including earthquakes affecting STO Bawean and Kebalen on March 22, Witel West Sumatra on May 12, and Witel Mataram on May 14, as well as fires at STO Cirebon on July 21 and Site Bunyu on August 21. Such incidents not only disrupt our ability to\n\n28\n\n[Table of Contents](#TOC)\n\nprovide continuous service but also strain our resources during recovery efforts. In late November and December 2025, exceptionally heavy rain caused severe flooding and landslides across Aceh and other parts of Sumatra, majorly displacing thousands from their homes. Large areas of Aceh were flooded, forcing many communities to temporary shelters, which led to significant loss of life and injury.\n\n•\n\n*Physical Security Threats*. Our networks and equipment, particularly our wireline access network, face both potential physical and cybersecurity threats, including facility access issues, energy blackouts, fire, power loss, telecommunications failure, catastrophic events such as landslides and earthquakes, theft and vandalism of our equipment, and organized attacks against key infrastructure intended to disrupt operations. For example, our fiber optic cables were cut several times in 2023 and 2024 because of vandalism, which caused temporary interruptions to our traffic.\n\n•\n\n*Cybersecurity Threats*. In addition, telecommunications companies worldwide face increasing cybersecurity threats as businesses have become more dependent on telecommunications and computer networks, and have adopted or will adopt cloud technologies. Cybersecurity threats include gaining unauthorized access to our systems or inserting computer viruses, malicious and destructive codes, worms, malware, ransomware, or other malicious software in our systems; phishing, or spoofing to misappropriate consumer data and other sensitive information; or corrupting our data or disrupting our operations. Unauthorized access may also be gained through traditional means such as the theft of computers, portable data devices, or mobile phones, and intelligence gathering on employees with access to our systems.\n\nWe protect confidential information and personal data on our systems by entering into confidentiality agreements with employees, consultants, customers, suppliers, and service providers, and we design our networks and implement various procedures to restrict unauthorized access and dissemination of such information and data. Nonetheless, we, our service providers, and others who may have access to our systems and confidential information are still subject to internal and external cybersecurity threats. For instance, current, departing, or former employees, business partners, consultants, and other individuals with whom we do business could attempt to improperly use or access our computer systems and networks, or those of third-party service providers, to copy, obtain, and misappropriate our confidential information, including personal data.\n\nA lack of awareness among our employees and service providers of the cybersecurity risks that we face, as well as a lack of cybersecurity skills and capabilities, could contribute to our vulnerability if not adequately addressed in our training and awareness programs. Cyber-attacks may be conducted by sophisticated and organized groups and individuals with a wide range of motives and expertise, including organized criminal groups, “hacktivists,” terrorists, nation-states, nation-state-supported actors, and others. Our network and website are frequently targeted by cyber-attacks. In 2025, we detected 545.9 million cyber threats, 9,613 DDoS attacks, and 1,434 brute force attacks on our IT assets.\n\nAlthough most of the cybersecurity threats were non-disruptive and none of them rose to the level of requiring us to specifically address them, the techniques that computer hackers and others use to access or sabotage networks and computer systems constantly evolve and are generally not recognized until launched against a target. As a result, we and our service providers may be unable to anticipate, detect in a timely manner or at all, react to, counter or ameliorate all of these techniques or remediate any incident as a result therefrom. Our safety procedures and intrusion detection systems may not be fully effective in preventing unauthorized access to our internal data and databases, as well as data of customers, suppliers and other parties that we host on our systems. Therefore, such data could be misappropriated and illegally used, monitored, modified, or disseminated. More extensive infrastructure damage from any source could severely hamper service provision across our operations, and our business continuity and disaster recovery plans may not fully protect us from damage or interruptions to our operations.\n\nAny such failure or breach, whether from operational disruption, natural disaster, physical attack, or cybersecurity breach, could expose us to significant legal, financial, and reputational consequences. A successful attack or other material failure may lead us to incur substantial costs and devote increasing resources to repair damage or restore data, implement substantial organizational changes, new safeguards, system improvements, and training to prevent future similar attacks.\n\n29\n\n[Table of Contents](#TOC)\n\nIt could also result in lost revenues and litigation costs, and cause substantial reputational damage, loss of customer confidence in the adequacy of our threat mitigation and detection processes and procedures, and impact our competitive position. Such incidents may also cause equipment failures, loss of information, failure or perceived failure to comply with applicable privacy, security or data protection laws, or our failure to make adequate or timely disclosures to the public, regulators, or shareholders following any such event, as well as disruption to our operations or our customers’ operations.\n\nFurthermore, it might be difficult to calculate the economic costs caused by potential cybersecurity incidents and maintain sufficient insurance coverage relating to them at commercially reasonable rates and terms. Eliminating computer viruses and other security problems may also require interruptions, delays, or suspension of our services, reduce our customer satisfaction, and cause us to incur additional costs. Due to the evolving nature of these threats, the scope and impact of any future incident cannot be precisely predicted, and the physical and cybersecurity measures that we take to protect our network may not be successful. Any such event could divert our management attention and resources, expose us to liability and damages, negatively impact our operations, reputation, and competitive position, and materially and adversely affect our business, prospects, financial condition, and operating results.\n\nDamage to our reputation could negatively impact our business, financial condition, and results of operations.\n\nOur reputation is a critical factor in our relationships with customers, employees, the Government, other state-owned enterprises, suppliers, and other stakeholders. Our reputation may be adversely affected by incidents or allegations involving, among other things, the quality of our products and services, security or safety issues, unethical behavior or misconduct, legal non-compliance, internal control failures, data or privacy breaches, workplace safety incidents, environmental incidents, the use of our communications systems for illegal or objectionable applications, negative media reports, and the conduct of our partners or representatives, whether actual or perceived. There is also increasing demand from external stakeholders, including non-governmental organizations and investors, for transparency and corporate responsibility, which may be difficult to satisfy fully.\n\nWe are also subject to corporate governance laws and regulations and corruption risks. We are committed to conducting our operations in accordance with applicable anti-corruption laws and record-keeping requirements, and our management systems include a corporate code of conduct and other specific guidelines, policies, and directives designed to minimize and detect potential violations in a timely manner. However, there is no assurance that all of our employees, consultants, agents, or partners will comply with our corporate code of conduct and related policies, or that our management systems can fully prevent or effectively detect violations of anti-corruption laws and record-keeping requirements.\n\nThe ongoing investigations by the SEC and DOJ into various issues, including accounting and disclosures issues relating to our revenue recognition, financial reporting practices, and internal control over financial reporting (“**ICFR**”), the findings of our internal investigation regarding transactions entered into by former management, and the Indonesian legal proceedings involving alleged fraud and corruption at our Company each represent the types of incidents that present significant reputational risk. Negative publicity arising from any of these matters, or from any adverse outcome of any ongoing investigation or proceeding, whether or not ultimately resolved in our favor, could harm our reputation with customers, investors, employees, the Government, and other stakeholders. For more information on these matters, see “*— Financial Risks — If we fail to maintain an effective system of internal control over financial reporting, we may be unable to accurately report our financial results or prevent fraud*”, “*— Legal and Compliance Risks — We are and may be subject to legal proceedings, claims and investigations, including for allegations relating to our public disclosures and disputes and litigation with regulators, competitors and other parties. If the outcomes of these proceedings, claims and investigations are adverse to us, our business, results of operations and financial condition could be materially and adversely affected, including because we may be subject to criminal or civil sanctions, or be required to restate our financial statements from prior periods,*” “*Item 8. Financial Information – A. Consolidated Statements and Other Financial Information – Legal Proceedings”*and “*Item 15. Controls and Procedures*.”\n\nIf we fail to respond quickly and effectively to address reputational incidents, we may receive additional negative publicity, which could subject us to enforcement actions, legal proceedings, sanctions, fines, or penalties, compliance\n\n30\n\n[Table of Contents](#TOC)\n\nconditions, or other restrictions, and we may incur substantial costs regardless of the ultimate outcome of any ongoing investigation or proceeding. Damage to our reputation could harm customer relations, reduce demand for our services and products, reduce investor confidence in us, and impair our ability to compete for customers and highly skilled employees. Any of the foregoing could have material adverse effects on our business, operating results, financial condition, reputation, and brand.\n\nWe face a number of risks relating to our internet-related services, including negative associations with and claims arising from content carried over our network or on the websites we host.\n\nSince we provide connections to the internet and host websites for customers, we may be perceived as being associated with the content carried over our network or displayed on websites that we host. For example, in the past, due to an escalation in spam messages generated from email addresses on the Telkom network, Telkom was placed on certain IP blacklists which blocked all email generated from Telkom addresses for almost a week until remedial measures could be put into place. This issue has persisted into 2025, with instances of spam generation and subsequent blacklisting continuing to occur. Although we have implemented administrative and technical preventative measures to identify and combat spam, these measures may not always be effective and we could be placed on IP blacklists again in the future, disrupting our services.\n\nIn addition, the content carried over our network or the websites that we host may contain materials or information which may be illegal, defamatory, impermissible or infringe on third-party copyrights. We cannot and do not screen all of this content and may face litigation claims due to a perceived association with such content. These types of claims can be costly to defend, divert management resources and attention, and may damage our reputation.\n\nRevenue leakage might occur due to internal weaknesses or external factors and if this risk were to materialize, it could have a material adverse effect on our operating results.\n\nWe may face revenue leakage or problems with collecting all the revenues to which we may be entitled due to the possibility of inaccurate billing, delays in transaction processing, dishonest customers, or other factors. Further, our services might be susceptible to piracy and unauthorized usage. Such piracy and unauthorized usage may lead to a loss of revenue for our Group. For example, in recent years we have lost revenue as a result of fraudsters’ use of simboxes, which are electronic boxes that use mobile phone antennae or a BTS on which local operator SIM cards are installed so that international calls can be fraudulently routed to local numbers, enabling fraudsters to bypass interconnection rates in the destination country. Such revenue leakages constitute a loss of potential revenue that is difficult to quantify and may lead to a loss of revenue for our Group, which may affect our financial conditions and results of operations.\n\nExpected benefits from investment in new networks and technologies may not be realized.\n\nWe pursue new growth opportunities in the communications industry, including introducing services and products employing new technologies, such as next-generation network technologies, virtualization, software-defined networking, cloud-based technologies, new video and content delivery platforms, digital marketing, home fiber, fixed-mobile convergence, and Wi-Fi 6. The implementation of these new technologies depends on a number of factors, including the development of our network and the launch of new and commercially viable products and services involving these technologies. We may have to incur substantial expenditures to develop our network, services, and products and to gain access to related or enabling technologies in order to successfully implement these new technologies.\n\nHowever, these service enhancements and product launches may not occur as scheduled or at the cost expected due to many factors, including delays in determining equipment and wireless handset operating standards, supplier delays, increases in network equipment and handset component costs, regulatory permitting delays for tower sites or enhancements, or labor-related delays. We may not be successful in modifying our network infrastructure in a timely and cost-effective manner to facilitate such implementation, which could materially and adversely affect our quality of service, financial condition, and results of operations.\n\n31\n\n[Table of Contents](#TOC)\n\nFurther, we may face the risk of unforeseen complications in the deployment of new technologies. Any newly adopted technology may not perform as expected, and we may not be able to successfully or on a timely basis develop the new technology to effectively and economically deliver services based on such technology. For example, the deployment of our 5G network requires significant capital expenditures for the development of network infrastructure. See also *“— Risks Related to Our Business — Operational Risks– The telecommunications industry is characterized by intense competition and rapid technological change, and our ability to compete effectively is dependent on significant capital investment, access to sufficient spectrum, and successful adaptation to new technologies and market entrants.”*\n\nFurthermore, we are also reliant on the Government for allocation of relevant spectrum through auctions. Deployment of new technology may also adversely affect the performance of the network for existing services. If we cannot acquire the required spectrum for network technologies or deploy the technologies and services that customers desire on a timely basis and at a reasonable price, then our ability to attract and retain customers, and therefore maintain and improve our operating margins, could be materially and adversely affected.\n\nWe rely on third parties to supply and maintain our network infrastructure, and they may be difficult to replace.\n\nWe rely on a limited number of leading international telecommunications equipment manufacturers, including Huawei, ZTE Corporation and Ericsson, for equipment and services required to maintain and expand the infrastructure required for our mobile network and 5G deployment. The successful build-out and operation of our networks depend heavily on obtaining adequate supplies of core and transmission telecommunications equipment, fiber, switching equipment, radio access network solutions, base stations and other services and products on a timely basis. Most of this equipment cannot be sourced locally.\n\nOur business could be materially impacted by disruptions to our key suppliers’ businesses or supply chains due to a number of factors, including:\n\n●*Geopolitical Events, Sanctions, and Trade Restrictions.* Our supply chain is exposed to geopolitical risk, including export controls, sanctions, and trade restrictions that are largely beyond our control. Shifts in government administrations, particularly in the United States, can produce sudden changes in foreign policy and trade priorities. The U.S. Department of Commerce has added certain telecommunications equipment manufacturers to its \"Entity List,\" substantially restricting the transfer of U.S.-sourced items to those entities. The U.S. government has also imposed, and may in the future impose, broad tariffs on telecommunications equipment and components, a significant share of which is sourced from China and other countries that have been or may be targeted. Any such actions could impair our key suppliers' ability to serve us and materially increase our equipment costs.\n\n●*Global Supply Chain Disruptions*. Geopolitical conflicts have disrupted global supply chains for critical components, including semiconductors essential to our network infrastructure. The conflict in Ukraine has curtailed supplies of key semiconductor inputs, such as neon gas, of which Ukraine was a major producer, and palladium, of which Russia is a leading supplier, constraining semiconductor production capacity and contributing to delays in our data center expansion, including our Cikarang data center in 2023. The escalation of hostilities involving Israel, Iran, and the United States in 2026, including restrictions and controls on shipping in the Strait of Hormuz, has driven oil price volatility, increasing international logistics and freight costs for the network equipment and components we procure, which may compress our margins to the extent such costs cannot be passed through to customers.\n\nIf any of these disruptions persist or intensify, we may be unable to obtain the components needed to maintain and upgrade our network infrastructure and roll out 5G technologies, resulting in higher costs, extended project timelines, and possible service interruptions. Finding alternative suppliers, whether due to geopolitical restrictions, epidemic or pandemic-related constraints, or other factors, may not be possible on a timely basis or on commercially acceptable terms. Any of the foregoing could negatively affect our operations, financial condition, and competitive position.\n\n32\n\n[Table of Contents](#TOC)\n\nOur satellites have limited operational lives and they may be damaged or destroyed during in-orbit operation or suffer launch delays or failures. The loss or reduced performance of a satellite, whether caused by equipment failure or its license being revoked, may adversely affect our financial condition, results of operations and ability to provide certain services.\n\nWe operate three satellites: Telkom-3S, Telkom Merah Putih and Telkom Merah Putih-2. These satellites have limited operational lives, and their design lives are expected to end in 2032, 2033 and 2040 approximately, respectively. A number of factors affect the operational lives of satellites, including the quality of their construction, durability of their systems, sub-systems and component parts, on-board fuel reserves, accuracy of their launch into orbit, exposure to micrometeorite storms, or other natural events in space, collision with orbital debris, and the manner in which the satellite is monitored and operated.\n\nWe use satellite transponder capacity on our satellites in connection with many aspects of our business, including direct leasing of such capacity and routing for our international long distance and cellular services. International Telecommunications Union regulations specify that a designated satellite orbital slot has been allocated for Indonesia, and the Government has the right to determine which party is licensed to use such slot. While we hold a license to use the designated satellite orbital slot, in the event any of our satellites experience technical problems or failure, the Government may determine that we have failed to optimize the existing slot under our license, which may result in the Government withdrawing our license. In the future, we may not be able to maintain use of the designated satellite orbital slot in a manner deemed satisfactory by the Government, which could significantly impact our business operations.\n\nActual or perceived health risks or other problems relating to radio emissions could lead to litigation or decreased mobile communications usage.\n\nThe effects of, and any damage caused by, exposure to an electromagnetic field were and are the subject of careful evaluations by the international scientific community. While as of the date hereof we are not aware of any substantiated link between exposure to electromagnetic signals at the levels transmitted by our BTS and mobile handsets and long-term damage to health, we cannot rule out that exposure to electromagnetic fields or other emissions originating from BTS or wireless handsets will not be identified as a health risk in the future.\n\nThe actual or perceived health risks of mobile communications devices and generally negative public perception could adversely affect us through a reduction in subscribers, reduced usage per subscriber, increased difficulty in the leasing and acquisition of site locations for BTS and base stations, and exposure to potential liability and associated legal proceedings and costs. For instance, there have been health-related lawsuits filed worldwide against wireless carriers and manufacturers of wireless devices. Furthermore, we may not be able to obtain insurance with respect to such liability on commercially reasonable terms or at all.\n\nThese factors could have a material adverse effect on our business, prospects, and financial condition.\n\nHealth epidemics or pandemics and the economic disruption caused by various measures to reduce its spread have had and may continue to have adverse consequences of uncertain magnitude and duration on our operations.\n\nHealth epidemics or pandemics, such as the global outbreak of COVID-19 in early 2020, have in the past and may in the future affect macroeconomic conditions, consumer behavior, labor availability and supply chain management, all of which can adversely affect our business, operations, prospects, and results of operations. For example, COVID-19 caused a decline in purchasing power, which contributed to us having to bolster our allowance for doubtful accounts as some of our customers became unable to pay invoiced amounts that they owe us. Further, our distribution network and retail outlets also experienced significant disruption as physical distancing measures and other containment measures were required.\n\nGovernmental responses to health epidemics or pandemics, including operational restrictions, can also affect the foregoing and adversely affect our business, operations, prospects, and results of operations. Moreover, predicting the\n\n33\n\n[Table of Contents](#TOC)\n\nduration and scope of a health epidemic or pandemic can be challenging, as it depends on many factors, including the emergence of new variants and the availability, acceptance, and effectiveness of preventative measures. Further, the negative impact of health epidemics or pandemics on the global economy may increase counterparty risks or increase difficulties in collecting fees, which may negatively impact our cash flows, delay certain of our projects, and reduce our ability to access capital or increase financing costs.\n\nRisks Related to our Fixed and Cellular Telecommunications Business\n\nContinuing growth in and the converging nature of wireless and broadband services will require us to deploy increasing amounts of capital and require ongoing access to spectrum in order to provide attractive services to customers.\n\nTelecommunications services are undergoing rapid and significant technological changes and a dramatic increase in usage, in particular, the demand for faster and seamless usage of video and data across mobile and fixed devices. We continually invest in our networks in order to improve our wireless and broadband services to meet this increasing demand and remain competitive. Improvements in these services depend on many factors, including continued access to and deployment of adequate spectrum and the capital needed to expand our network to support our ability to offer these services. We must maintain and expand our network capacity and coverage for transport of video, data and voice between cell and fixed landline sites. To this end, we have participated in spectrum auctions, at increasing financial cost, and continue to deploy technology advancements in order to further improve our network. Further, we must pay an annual right of usage fee for the license when we win additional spectrum, such as the additional 5 MHz spectrum in the 2.1 GHz frequency band that we won in November 2022.\n\nIf we are unable to win new spectrum allocations or if no such allocations are made available in a timely fashion, our growth strategy will be negatively impacted, which could have a material adverse impact on our competitive position, the quality of our services, results of operations, financial condition and prospects.\n\nOur continued investments in the construction of our infrastructure network may not adequately address the issues resulting from the substantial increases in data traffic or otherwise achieve the desired economic returns.\n\nWe expect a continued and substantial increase in data traffic not only as a result of changes in consumption habits and consumers’ behavior but also as a result of our efforts to make our data services affordable at a time where purchasing power and disposable income have been negatively affected. Since we launched our 4G/LTE services in 2014, the substantial increase in data traffic resulting from the growth of our wireless data traffic business, our 4G/LTE business and the proliferation of smartphones had significantly strained the existing capacity of our telecommunications network infrastructure.\n\nAs a result, based on our anticipation of further significant growth in data traffic, we have made and will continue to make substantial investments in the development of our infrastructure network, including our 4G/LTE and 5G infrastructure, to carry the increasing data traffic. However, our ability to improve or expand our infrastructure network is subject to various factors, a number of which are not within our control, such as regulations and changes in regulations, changes to the competitive environment or technological developments that could materially and adversely affect our ability to improve or expand our infrastructure network as expected or desired and achieve anticipated returns on our investments.\n\nRisks Related to the Development of New Businesses and Acquisitions\n\nWe may not succeed in our efforts to develop new businesses.\n\nWe believe that efforts to develop new businesses other than in the telecommunications sector, such as in the areas of digital life, smart platforms, and enterprise ICT, as well as efforts to pursue international expansion, are necessary to support continuing business growth. Risks related to new business development include competition from established players, suitability of our business model, competition from disruptive new technologies or business models, the need to\n\n34\n\n[Table of Contents](#TOC)\n\nacquire new expertise in new areas of operation, the inability to successfully organize and streamline our subsidiaries to create value from our multiple businesses, and risks related to online media which include intellectual property, consumer protection and confidentiality of customer data. Further, we have to focus on securing new enterprise customers. If we are unable to secure new contracts, or we are unable to renew our existing contracts with similar contract value, size, or margins to existing ones, this may adversely affect our business, results of operations and financial condition.\n\nFocusing on international expansion is one of our strategic business initiatives. In particular, we have expanded into a number of jurisdictions in telecommunications or data related areas, namely Australia, Dubai, Hong Kong, Malaysia, Myanmar, Singapore, Taiwan, Timor-Leste, and the United States. Expanding our operations internationally exposes us to a number of risks associated with operating in new jurisdictions. For example, our international operations could be adversely affected by political or social instability and unrest, regulatory changes (such as an increase in taxes applicable to our operations), macroeconomic instability, limitations on or controls on the foreign exchange trade, competition from local operators, difference in consumer preference and a lack of expertise in the local markets in which we will operate. Any of these factors could limit our expected returns from our expansion and materially and adversely affect our business, results of operations and financial condition.\n\nExpected benefits from partnerships with global technology companies may not be achieved.\n\nWe partner and collaborate with various global technology companies as part of our strategy of providing digital IT services to our businesses. Global technology companies have capabilities and scale that we may not be able to create and develop organically, whether in the near-term or at all, and such partnerships are necessary to achieve some of our strategic goals. Our reliance on global technology companies is especially critical for major projects, such as developing a vertical digital ecosystem in Indonesia, fostering digitalization by providing wider access to digital tools for businesses and Government agencies, and generally supporting Indonesia’s digital development through our contribution to the One Data Indonesia initiative, the Government’s plan for digitizing Government data and facilitating transfers of such data, and the Government’s implementation of the National Digital Platform.\n\nHowever, we may be unable to identify suitable partners for achieving such strategic goals or we may not benefit as expected from our partnerships with selected global technology companies. For example, there may be differences between our interests and our partners’ interests as a result of pursuing different strategies, developing competing services, competing for the same customers, or other reasons outside of our control.\n\nAs we strategically focus on the development of digital products, services and the development of a digital ecosystem, we may also become increasingly reliant on technology owners with whom we partner, in particular if we are not able to develop certain digital capabilities organically or if we do not develop or attract digital talents.\n\nDelays and failures in the implementation of national strategic plans such as the National Digital Platform, the development of an E-Government architectural framework for the central Government, local governments, agencies and state-owned companies, and the successful implementation of the Government’s inclusive digital transformation strategy for Indonesia could also negatively impact our own strategic initiatives and partnerships to the extent they rely on the success of such national initiatives.\n\nUltimately, if we are unable to realize gains from our partnerships with global technology companies, our ability to achieve strategic growth initiatives, provide digital products, and attract and retain customers could be materially and adversely affected.\n\nDue to intense competition for highly skilled personnel, we may fail to attract, recruit, retain and develop qualified employees, which could materially and adversely impact our business, prospects, financial condition and results of operations.\n\nOur strategic focus in 2025 was on undertaking a significant corporate transformation, highlighted by the partial spin-off of our Wholesale Fiber Connectivity business and assets to our subsidiary, PT Telkom Infrastruktur Indonesia\n\n35\n\n[Table of Contents](#TOC)\n\n(“**TIF**”). This initiative, part of our broader strategy to unlock value in our digital infrastructure, alongside our continued focus on FMC, data center expansion, and B2B digital services, requires specialized expertise to manage both the complex transition and the operations of the restructured entities.\n\nWe face significant competition for suitably skilled personnel, such as software engineers, electrical engineers working in digital signal processing, developers and digital talents in general. The Indonesian high-tech and digital industry has experienced significant economic growth, including through some strategic partnerships initiated by local companies with leading regional technology companies. This accelerated economic growth of Indonesian technology companies has led to an intense competition among Indonesia-based employers to attract locally qualified employees.\n\nThe implementation of our strategic initiatives, particularly the partial spin-off of a business segment to our subsidiary, TIF, involves the transfer of certain employees and requires specialized expertise to manage the transition. For more details on this transaction, see *“—Risks Related to our Corporate Structure—Our efforts to streamline our corporate structure may not create expected synergies and efficiencies in a timely fashion or at all.”*\n\nAs a result, we may not succeed in recruiting additional experienced or professional personnel, retaining current personnel, or effectively replacing current personnel who may depart with qualified or effective successors. Our efforts to retain and develop personnel may also result in significant additional expenses, which could adversely affect our profitability. There can be no assurance that qualified employees will continue to be employed or that we will be able to attract and retain qualified personnel in the future. Failure to retain or attract qualified personnel could have a material adverse effect on the implementation of our business strategies, our business, prospects, financial condition, and results of operations.\n\nIf we are unable to manage our growth effectively, our business and financial results may be adversely affected.\n\nTo continue to grow sustainably, we are expanding our operational, research, sales and marketing efforts, accounting and financial systems, procedures, controls and other internal management systems. For more information on our growth strategy, see “*Item 4.B. Business Overview – Strategy.”*This may require substantial managerial and financial resources, and our efforts in this regard may not be successful. Our current systems, procedures and controls may not be adequate to support our future operations. Unless our growth results in an increase in our revenues that is proportionate to the increase in our costs associated with this growth, our operating margins and profitability will be adversely affected. If we fail to adequately manage our growth effectively, improve our operational, financial and management information systems, or effectively train, motivate and manage our new and future employees, it could adversely affect our business, financial condition and results of operations.\n\nOur acquisition activities expose us to various risks.\n\nWe have in the past pursued, and may continue to pursue, acquisitions of complementary assets and businesses. In February 2023, Mitratel acquired 997 telecommunications towers from Indosat, and in November 2023, Mitratel further acquired 803 telecommunications towers from PT Gametraco Tunggal. In 2024, Mitratel acquired a 100% equity stake in PT Ultra Mandiri Telekomunikasi from PT PP Infrastruktur.\n\nThe success of these acquisitions will depend, in part, on our ability to realize the anticipated growth opportunities and synergies from combining the acquired businesses with our existing businesses. Based on the size and complexity of certain businesses, integrating them into our existing business could require substantial time, expense and effort from our management. The process of integrating an acquired business may also involve unforeseen costs and delays or other operational, technical and financial difficulties that may require a disproportionate amount of management attention as well as financial and other resources. If our management’s attention is diverted or there are any difficulties associated with integrating these businesses, our results of operations could be adversely affected.\n\nEven if we are able to successfully integrate these businesses, it may not be possible to realize the full benefits we expect to result from such acquisitions and strategic transactions or realize these benefits within the time frame that we\n\n36\n\n[Table of Contents](#TOC)\n\nexpect. Moreover, such businesses generally remain subject to unforeseeable factors outside of our control. Our acquisitions and strategic transactions, including those entered into in recent periods, may turn out to be unprofitable. Any failure to successfully incorporate the acquired businesses and assets into our existing operations, to enhance operating efficiencies from consolidation savings, minimize any unforeseen operational difficulties and realize the anticipated benefits on time, or at all, could materially and adversely affect our business, financial condition, results of operations, prospects and cash flows.\n\nFinancial Risks\n\nIf we fail to maintain an effective system of internal control over financial reporting, we may be unable to accurately report our financial results or prevent fraud.\n\nOur internal investigation conducted with the assistance of outside counsel and a forensic accounting firm in connection with the SEC and DOJ investigations (the \"**Internal Investigation**\") also focused on the review of approximately 140 transactions originating from 2014 through 2021, and primarily between 2016 and 2019. Certain of these transactions were entered into by our former management or the former management of certain of our subsidiaries, primarily related to the enterprise business segment, were executed in circumvention of IFRS, our policies, and ICFR to manage reported earnings. Other members of former management, including those who were in place during later periods, failed to take corrective action when these transactions were identified as improper or potentially improper. These transactions and this absence of corrective measures reflected deficiencies in our control environment. For more information, see *“Item 3D — Risk Factors — Risks Related to Our Business — Operational Risks — Damage to our reputation could negatively impact our business, financial condition, and results of operations”, “Item 3D — Risk Factors — Risks Related to Our Business — Legal and Compliance Risks — We are and may be subject to legal proceedings, claims and investigations, including for allegations relating to our public disclosures and disputes and litigation with regulators, competitors and other parties. If the outcomes of these proceedings, claims and investigations are adverse to us, our business, results of operations and financial condition could be materially and adversely affected, including because we may be subject to criminal or civil sanctions, or be required to restate our financial statements from prior periods”, “Item 8. Financial Information – A. Consolidated Statements and Other Financial Information – Legal Proceedings” and “Item 15. Controls and Procedures.”*\n\nWe have taken disciplinary action against involved employees and have implemented and continue to implement other remediation measures, such as the hiring of additional qualified accounting, finance, and legal personnel, engagement of technical accounting consultants, and streamlining of our organizational structure to improve oversight of our accounting and controlling functions. In 2025, we also created the Directorate of Legal & Compliance and a new Chief Integrity Officer position to strengthen our corporate governance and compliance program. Our full remediation plan is described in “*Item 8. Financial Information – A. Consolidated Statements and Other Financial Information – Legal Proceedings – Remediation”* in this Form 20-F. However, there can be no assurance that these efforts will be successful or will prevent the recurrence of similar issues.\n\nIf we are unable to maintain an effective internal control environment, fully identify, or assess the impact of, transactions that did not or do not comply with IFRS and our policies and guidelines, we could suffer material misstatements in our financial statements, fail to meet our reporting obligations, and cause investors to lose confidence in our reported financial information, which could limit our access to capital markets, harm our results of operations, lead to a decline in the trading price of our securities, and expose us to increased risk of fraud, potential delisting, regulatory investigations, and civil or criminal sanctions.\n\nOur independent registered public accounting firm, after conducting its own independent testing, may also issue a qualified report if it is not satisfied with our internal controls or the level at which our controls are documented, designed, operated, or reviewed, or if it interprets the relevant requirements differently from us.\n\n​\n\n37\n\n[Table of Contents](#TOC)\n\nDeterioration of the financial condition of our customers could adversely affect our operating results.\n\nChallenging macroeconomic conditions and financial market volatility due to several factors such as increased interest rates, global inflationary trends, geopolitical tensions, the conflicts in the Middle East and Ukraine, changes in or new tariffs, and ongoing trade disputes between China and the United States, could negatively impact the Indonesian economy and our customers, including reducing the purchasing power of our subscribers.\n\nIn addition, our corporate restructuring involves the transfer of certain enterprise customer contracts. In connection with our partial spin-off, the agreements with customers of the Wholesale Fiber Connectivity business will be transferred to our subsidiary, TIF. For more details, see *“—Risks Related to our Corporate Structure—Our efforts to streamline our corporate structure may not create expected synergies and efficiencies in a timely fashion or at all.”*\n\nA deterioration in the financial condition of our enterprise customers, including those whose contracts are transferred to TIF, or of our subscribers, whether due to the macroeconomic factors described above or otherwise, has and may continue to adversely impact our business, including by negatively affecting the collection of accounts receivable. This could also result in our customers and subscribers purchasing fewer of our products and services or delaying such purchases, which could have a material adverse effect on our business, financial condition, results of operations and prospects. For the years ended December 31, 2024 and 2025, our total trade and other receivables, net of allowance for expected credit losses were Rp12,829 billion and Rp11,410 billion (US$684 million), respectively. We regularly review the collectability and creditworthiness of our customers and trade receivables generated by specific projects and transactions, on a case-by-case basis, to determine an appropriate allowance for estimated credit losses. We assess and calculate sufficient provision for impairment of our receivables to cover losses incurred arising from uncollectible accounts based on existing data on credit losses. The allowance for expected credit losses was Rp7,196 billion (US$432 million) as of December 31, 2025, representing an increase by approximately 14.3% compared to our allowance for expected credit losses as of December 31, 2024. Otherwise, the written-off uncollectible accounts in 2025 increased by 43.1%, from Rp401 billion in 2024 to Rp574 billion (US$34 million) in 2025. We believe that the allowance for expected credit losses of trade receivables is adequate to cover losses on uncollectible accounts. If our uncollectible accounts were to exceed our current or future allowance for credit losses, our operating results would be negatively impacted.\n\nFurther, recent global inflationary trends and financial market volatility have resulted in funding constraints that may affect the timing and scale of new purchases of our products and services by some of our existing or prospective enterprise customers. The effects of recent macroeconomic uncertainties on our customers have also resulted in delays to contract negotiations or customer orders and may result in further delays. These factors could materially and adversely affect our financial condition and operating results.\n\nWe are exposed to interest rate risk in relation to our bank borrowings.\n\nOur debt includes bank borrowings used to finance our operations, and we have a mix of our fixed-rate loans and floating-rate loans in our bank borrowings. As of December 31, 2025, approximately 49.4% (based on the aggregate then outstanding principal) of our total bank borrowings were floating-rate loans. Any future increases in interest rates would likely cause our financial expenses to increase as we enter into new loan agreements, including fixed-rate loans and credit facilities. Furthermore, while our 2025 share buyback of up to Rp3.0 trillion was funded by internal cash and not debt, the use of these internal funds could reduce our liquidity and may require us to seek external financing for future business development or operational needs, potentially at higher interest costs.\n\nWorldwide macroeconomic changes driven by conflicts in the Middle East and Ukraine, coupled with a global economic slowdown, have led to rising energy and food prices, resulting in sustained global inflation and supply chain disruptions impacting Southeast Asia, including Indonesia. To support the Indonesian Rupiah and domestic economic growth, Bank Indonesia (“**BI**”) has adjusted interest rates several times in recent years. In February 2021, the BI benchmark seven-day (reverse) repo rate reached a historic low of 3.50% per annum (the “**BI-Rate**”). Subsequently, BI gradually increased the benchmark rate in response to global inflationary pressures, exchange rate volatility, and tightening global monetary conditions, with the BI-Rate reaching 6.00% in early 2025. During 2025, BI gradually reduced the benchmark\n\n38\n\n[Table of Contents](#TOC)\n\ninterest rate to support economic growth and maintain financial system stability, bringing the BI-Rate down to 4.75% by the end of 2025. As of April 2026, BI has maintained the BI-Rate at 4.75% amid continued global economic uncertainty, volatility in international financial markets, and pressure on the Rupiah foreign exchange rate. Although inflation is expected to remain within BI’s target range and certain economies, including the United States and the European Union, have experienced easing inflation and lower interest rates, there can be no assurance that interest rates in Indonesia will continue to decline or remain stable. Future increases in interest rates may occur in response to domestic or global economic pressures, including inflationary risks, geopolitical tensions, exchange rate volatility, and capital outflows. Lower than anticipated interest rate reductions, or any future increases in interest rates, may cause our financing costs to remain higher than expected or increase financial expenses associated with floating rate borrowings, which could adversely affect our financial condition and results of operations.\n\nWe may be unable to fund the capital expenditures needed for us to remain competitive in the telecommunications industry in Indonesia.\n\nThe delivery of telecommunications services is capital intensive. In order to be competitive, we must continually expand, modernize, and update our telecommunications infrastructure technology, which involves substantial capital investment. For the years ended December 31, 2023, 2024, and 2025, our consolidated capital expenditures totaled Rp32,858 billion, Rp24,436 billion, and Rp24,577 billion (US$1,475 million), respectively. Our capital expenditure in 2025 was driven by allocation for the development, expansion and modernization of our telecommunications infrastructure and digital platforms. Key initiatives undertaken in 2025 included investments in radio access networks (RAN), core network solutions, gateway and signaling systems, and fixed broadband infrastructure (including fixed broadband core and submarine cable systems). Additionally, capital expenditures were directed to supporting digital service platforms like online charging systems, customer relationship management, and service control points, as well as emerging technology deployments such as Starlink-based services. A portion of the expenditure also supports large-scale infrastructure projects, including data center construction and operational technology networks, along with associated technical support and rollout services to ensure network reliability and scalability.\n\nOur ability to fund capital expenditures in the future may depend on our future operating performance and our ability to select projects that result in the optimal allocation of such capital expenditures, both of which are subject to prevailing economic conditions, levels of interest rates and financial, business and other factors, many of which are beyond our control, and upon our ability to obtain additional external financing. Securing new loan facilities and additional financing may prove more difficult than in the past, and new debt funding may not be available to us in the future on commercially acceptable terms, or at all, particularly if interest rates keep rising in the near future or market sentiment is negative due to challenging macroeconomic conditions. In addition, we can only incur additional financing in compliance with the terms of our debt agreements.\n\nAccordingly, in the future we may not have sufficient capital resources to improve or expand our telecommunications infrastructure technology or update our other technologies to the extent necessary to remain competitive in the Indonesian telecommunications market. Our failure to do so could have a material adverse effect on our business, financial condition, results of operations and prospects.\n\nLegal and Compliance Risks\n\nWe are and may be subject to legal proceedings, claims and investigations, including for allegations relating to our public disclosures and disputes and litigation with regulators, competitors and other parties. If the outcomes of these proceedings, claims and investigations are adverse to us, our business, results of operations and financial condition could be materially and adversely affected, including because we may be subject to criminal or civil sanctions, or be required to restate our financial statements from prior periods.\n\nAs of the date hereof, we are subject to ongoing government investigations and legal proceedings in the United States and Indonesia and cannot provide any assurance about their outcomes, which may have a material adverse effect on our reputation, business, results of operations, or financial condition.\n\n39\n\n[Table of Contents](#TOC)\n\nIn October 2023, we received a document request from the SEC relating to Telkom Infra’s involvement in a project with the Indonesian Information and Telecommunication Accessibility Agency of the MoCD (“**BAKTI** **Kominfo**”) regarding the provision of 4G BTS infrastructure. The SEC has since expanded its investigation to include accounting and disclosure issues relating to our revenue recognition, financial reporting practices, and ICFR, as well as public reports regarding certain Indonesian legal proceedings involving our Company, various subsidiaries and affiliates, and certain of our clients and suppliers. Beginning in May 2024, we also received requests for information from the DOJ focused on compliance with the U.S. Foreign Corrupt Practices Act (“**FCPA**”). Each U.S. authority is aware of the other agency’s investigation. We are cooperating with the SEC and DOJ and have been carrying out our Internal Investigation into these issues.\n\nAs of the date hereof, the Internal Investigation is substantially complete. The Internal Investigation focused on the review of approximately US$324 million of revenues, spread across approximately 140 transactions originating from 2014 through 2021, and primarily in 2016 through 2019, impacting historical trade receivables and revenues, to determine whether goods and services associated with these transactions were delivered or otherwise recorded in accordance with IFRS and whether such transactions were consistent with our policies, procedures, and ICFR. Our internal audit team also completed investigations for certain of these transactions, and those conclusions have been considered as part of the Internal Investigation.  \n\nAs of the date hereof, based on the results of our Internal Investigation, we believe that substantially all of these approximately 140 transactions that we have identified as lacking economic substance resulted in an overstatement of certain financial information, including revenues, gross trade receivables and net trade receivables, as set out in our consolidated financial statements relating to prior financial years. For a full description of the Internal Investigation findings, see “*Item 8. Financial Information – A. Consolidated Statements and Other Financial Information – Legal Proceedings.*”\n\nWe are also responding to various requests from the SEC and DOJ relating to their investigations. The requests primarily relate to the regulators’ investigations into accounting and disclosure issues relating to our revenue recognition, financial reporting practices, and ICFR, as well as public reports regarding certain Indonesian legal proceedings involving our Company, various subsidiaries and affiliates, and certain of our clients and suppliers. The SEC’s and DOJ’s investigations remain ongoing, and we continue to cooperate fully with the SEC and DOJ.\n\nWe cannot predict the duration, outcome, or impact of these investigations. Potential consequences include the imposition of material fines or penalties, monitorship, civil or criminal enforcement actions, restrictions on our business, potential delisting, additional government investigations or enforcement actions, or an inability to finalize our financial results in a timely manner, including a delay in complying with our periodic reporting obligations, any of which could have a material adverse effect on our business, financial condition, results of operations, and the market price of our shares and American Depositary Shares. An investigation or inquiry by the SEC or DOJ, even if ultimately resolved favorably, could adversely impact our reputation, business, prospects, financial condition, and results of operations.\n\nIn February 2025, the U.S. administration issued an executive order titled “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security,” pausing DOJ enforcement of the FCPA for 180 days (renewable for an additional 180 days). Shortly thereafter, the DOJ and SEC informed our Company of an indefinite pause on the FCPA-related aspects of their investigations. We cannot be certain how any resulting changes to FCPA enforcement will affect the DOJ’s investigation of our business.\n\nWe have cooperated with, and continue to cooperate with, and have in certain instances self-reported to, government authorities in Indonesia, including, among others, the Indonesian National Police, the Public Prosecution Service, and the Corruption Eradication Commission, various matters involving alleged or potential violations of Indonesian laws and regulations by our business units, subsidiaries, and affiliates, including anti-corruption, alleged fraud, embezzlement, and issues associated with trade receivables, some of which are related to the matters under investigation by the SEC and DOJ. In May 2025, the DKI Jakarta High Prosecutor’s Office designated eleven individuals as suspects and detained them in connection with alleged corruption involving fictitious financing at our Company, relating to conduct\n\n40\n\n[Table of Contents](#TOC)\n\nthat primarily took place between 2016 and 2019, following our submission of internal audit findings in support of the Government’s *Bersih-bersih BUMN* program. In April 2026, the Central Jakarta District Court issued its verdict against these eleven individuals. We have taken, and continue to take corrective actions including disciplinary action against involved employees, hiring additional qualified accounting, finance, and legal personnel to provide additional capacity and expertise to enhance our accounting and reporting review procedures, engaging consultants to provide additional technical accounting expertise, receivables collection effort, streamlining and delayering our organizational structure to improve oversight of our accounting and controlling functions, and other changes to our internal procedures. We fully support the applicable legal processes in Indonesia and continue to cooperate with Indonesian authorities. The outcomes of these proceedings remain uncertain and could expose us to additional liability, reputational harm, or operational disruption. In connection with the foregoing self-reporting and ongoing cooperation with Indonesian authorities, the OJK, as the regulator with supervisory powers over the capital markets sector, may also request clarifications or additional information from us regarding the reported matters.\n\nAny adverse outcomes of these matters could result in negative publicity, regulatory actions, reputational damage, and claims, fines, damages, and lawsuits, any of which could have material adverse effects on our business, results of operations, and financial condition. For more information, see also “*Item 3D. — Risk Factors — Risks Related to Our Business — Operational Risks — Damage to our reputation could negatively impact our business, financial condition, and results of operations*”, “*Item 3D. — Risk Factors — Risks Related to Our Business — Financial Risks — If we fail to maintain an effective system of internal control over financial reporting, we may be unable to accurately report our financial results or prevent fraud*”, “*Item 8. Financial Information – A. Consolidated Statements and Other Financial Information – Legal Proceedings”*and “*Item 15. Controls and Procedures*.”\n\nIf we are found liable for anti-competitive practices, we may be subjected to substantial liability which could have an adverse effect on our reputation, business, financial condition, results of operations and prospects. ****\n\nWe are subject to laws and regulations relating to anti-competitive practices and anti-monopoly. The Business Competition Law prohibits agreements and activities that amount to unfair business competition and an abuse of a dominant market position. Pursuant to the Business Competition Law, the KPPU was established as Indonesia’s antitrust regulator, with the authority to enforce the provisions of the Business Competition Law.\n\nWe have experienced occasional KPPU inquiries into alleged infringements of the Business Competition Law. While none of these inquiries have resulted in rulings adverse to our interests as at the date hereof, they may divert our management’s attention away from our business operations. In the future, if we are found to have violated the Business Competition Law, we may be subject to substantial liability in the form of payments of fines, the amount of which will be subject to the discretion of the courts, and which in turn could have a material adverse effect on our reputation, business, financial condition, results of operations, and prospects.\n\nRegulatory Risks\n\nChanges to our legal and regulatory environment may result in increased competition, reduced margins and operating revenue, asymmetric reduction in costs incurred by our competitors and increased regulatory and enforcement uncertainty.\n\nSince the enactment of Law No. 36 of 1999 on Telecommunications, as later amended by the Job Creation Law 2023 (the “**Telecommunications Law**”) Indonesia’s telecommunications industry has seen significant liberalization, further amplified by Presidential Regulation No. 10 of 2021 on Investment Business Activity as amended by Presidential Regulation No. 49 of 2021 (“**Presidential Regulation No. 10/2021**”), which eliminated foreign ownership limitations on various telecommunications business activities, such as fixed and mobile telecommunications networks. Given such changes, foreign investors may increase their ownership of telecommunications companies in excess of 67% or engage in various telecommunications activities independently, without having to establish joint ventures with local partners. This may attract new foreign investors or lead to increased foreign ownership of competitors in Indonesia or new market entrants with potentially larger resources competing for market share. As foreign investors explore opportunities in the Indonesian\n\n41\n\n[Table of Contents](#TOC)\n\ntelecommunications sector, the industry may experience increased competition, placing pressure on profit margins and operating revenues for existing players. The asymmetric reduction in costs incurred by our competitors, coupled with the potential influx of new, well-resourced entrants, may require us to further enhance our operational efficiency, differentiate our service offering, and explore collaborative ventures, which may lead to additional costs and necessitate the implementation of new strategies in response to increased competition.\n\nThe introduction of new or modified regulations to keep pace with technological advancements adds a layer of regulatory complexity and uncertainty, which may impact our financial and operational performance. Notable regulatory changes include MoCD Regulation No. 5/2021 mandating that all interconnection services must be migrated from TDM-based to IP-based platforms by December 31, 2024, posing challenges and potential revenue impacts for incumbents like us. For example, in order to comply with MoCD Regulation No. 5/2021, we had to significantly change our existing infrastructure (which our competitors rely on in providing conventional interconnection services and for which they pay tariffs to us) to adopt the new technologies. Consequently, our revenue from interconnection services has increased, but we will need to expend further capital resources to change our infrastructure. MoCD Regulation No. 5/2021 also provides that during the transition period, the Interconnection Offering Document (*Dokumen* *Penawaran* *Interkoneksi*) issued by Telkom will be recognized by the MoCD as a reference for determining interconnection rates. This regulation requires that the interconnection costs charged by us must remain the same as those agreed in the existing Interconnection Offering Document and Interconnection Agreement, limiting our ability to pass on the additional costs to those to whom we provide interconnection services.\n\nFurthermore, transitioning from TDM-based to IP-based platforms will likely result in a reduction in transit revenue in the future, as IP-based interconnection eliminates the need for intermediary operators for traffic routing, allowing other operators to bypass our infrastructure. This shift could adversely affect our revenue from interconnection services over time.\n\nAdditionally, the enactment of the General Data Protection Regulation (“**GDPR**”) in the EU and Indonesia’s own Law No. 27 of 2022 on Personal Data Protection (the “**PDP Law**”), as well as recent amendments to Law No. 11 of 2008 on Electronic Information and Transactions Law through Law No. 1 of 2024 (the “**EIT Law**”) and the recent MoCD Circular Letter No. 9 of 2023 on AI Ethical Guidelines (“**MoCD AI Circular Letter**”), underscores the increasing regulatory scrutiny around personal data protection and ethical AI use, necessitating significant compliance efforts. Alongside Indonesian regulations, our business operations and services are subject to international laws where we operate or serve customers. Notably, global jurisdictions are intensifying their examination of how businesses handle personal data. This rigorous oversight could lead to new legal obligations, impacting our operations. One prominent example is the EU’s GDPR, effective May 25, 2018, which governs the handling of personal data within EU member states, introducing strict compliance requirements and significant penalties for non-compliance.\n\nIn Indonesia, the primary regulatory framework for personal data protection is the PDP Law, which governs both digital and physical personal data management. However, as of this date, detailed implementing regulations have not yet been issued. The PDP Law took full effect on October 17, 2024, requiring us, as personal data controllers, to adapt our business practices to promote compliance throughout all stages of personal data processing. As a personal data controller, we are obligated to inform data subjects of the purpose and legality of data processing, obtain their consent, and process data in a limited, specific, lawful, and transparent manner. We are also required to notify data subjects promptly in the event of a data breach. Additionally, the PDP Law mandates the appointment of a Data Protection Officer (“**DPO**”) for companies that handle large-scale personal data, perform regular and systematic monitoring, or process data related to public services. To comply with the PDP Law, we have implemented a comprehensive data protection policy that governs personal data processing and helps establish compliance with legal and consent requirements. In 2024, Telkom appointed a DPO and formed a Data Protection Unit under the Corporate Secretary department. See also *“Item* *16K – Cybersecurity”* for further details. However, despite these measures, there remains a risk of cybercrime, data breaches, or human error that could result in violations of personal data protections. Non-compliance with the PDP Law could result in sanctions, including written warnings, temporary suspension of data activities, deletion of personal data, or administrative penalties.\n\n42\n\n[Table of Contents](#TOC)\n\nIn 2025, MoCD’s Legal Bureau conducted a series of harmonization meetings on the draft Government Regulation intended to supplement the PDP Law and establish more comprehensive standards for data controllers and processors. The draft Government Regulation also outlines the proposed establishment of a Personal Data Protection Authority, which is intended to provide institutional certainty and support consistent enforcement of personal data protection rules. As of May 2026, the draft Government Regulation has not yet been finalized. While the implementing regulations under the PDP Law have not yet been finalized, we have been subject to the obligations under, and have continued to comply with, the PDP Law since it became fully effective. In anticipation of the implementing regulations and evolving regulatory expectations, since 2024 we have undertaken various preparatory and compliance measures relating to the anticipated requirements under the PDP Law. However, full compliance with the detailed requirements to be set out in the final Government Regulation may require additional resources and investments, possibly delaying specific projects. Any such additional expenditures or delays could adversely impact our operational results and, in turn, materially and adversely affect our business, financial condition, results of operations, and prospects.\n\nAs of the date hereof, MoCD is in the process of developing a new regulation on AI ethics. According to MoCD’s Press Release No. 201/HM-KKD/10/2025, dated October 29, 2025, Nezar Patria, the Vice Minister of MoCD, stated that the Government was then in the process of drafting two regulatory instruments related to AI, which will cover, among others, the national development of AI and the ethical use of AI, with the objective of ensuring privacy protection, security, accountability, and ethical standards in the utilization of AI. As of the date hereof, the regulatory framework on AI ethics is limited to the MoCD AI Circular Letter and EIT Law. These regulations aim to promote ethical AI usage and protect children on digital platforms. They require Electronic System Operators (“**ESOs**”), including us, to implement preventive measures against risks to children posed by electronic systems. Additionally, they grant the Government significant oversight of electronic systems in Indonesia. For example, the MoCD AI Circular Letter outlines obligations for businesses using AI-based systems in public and private sectors. These include ensuring human oversight and validation of AI-driven decisions that may affect individuals, thereby prohibiting fully autonomous decision-making by AI systems without human involvement.\n\nThe recent amendments to the EIT Law significantly increase the responsibilities of ESOs, with a particular focus on child protection online. The amendments address the digital landscape’s changing dynamics and aim to protect children from potential harm. To be fully implemented, these amendments will be supported by forthcoming Government, Presidential, and Ministerial Decrees. A critical amendment to the EIT Law, Article 16A, directly targets the safety of children in the digital sphere by mandating ESOs to implement robust child protection mechanisms from the development to the operational stages of their systems. In response, our subsidiaries that manage distribution platform services, such as gaming and entertainment contents, have implemented data updates to display user age ratings. Instances of non-compliance with these requirements could lead to severe administrative penalties, including the possibility of system suspension or shutdown. Furthermore, the amendments emphasize the Government’s broader regulatory authority within Indonesia’s digital environment and grants the Government the power to compel ESOs to modify their operations, with penalties for non-compliance. While intended to promote a safe, fair, and innovative digital space, the broad scope of these powers has generated concerns over potential Government overreach and its implications for innovation and business growth within the sector.\n\nCybersecurity threats are a particular concern in Indonesia, where increasing digital adoption and policy developments have exposed weaknesses in cybersecurity infrastructure and practices. Indonesia has experienced several high-profile data breaches, including a significant cyberattack on PT Bank Syariah Indonesia Tbk in May 2023. This incident disrupted banking operations and raised concerns over the security of financial institutions, highlighting vulnerabilities in the country’s digital security framework. The attack resulted in operational downtime, financial losses, and reputational damage, emphasizing the need for enhanced cybersecurity measures and incident response protocols, as well as the importance of proactive threat detection, robust backup systems, and regulatory compliance to mitigate the impact of cyberattacks. Similarly, in June 2024, a ransomware attack targeted the Temporary National Data Center (*Pusat Data Nasional Sementara* or PDNS), a Government system solely administered by the MoCD and hosted at our Data Center 2 in Surabaya under a private cloud subscription arrangement. Although we were not directly responsible for the system’s administration, this incident reinforced the broader need for heightened cybersecurity measures across both the private and public sectors in Indonesia. The increasing frequency of cybercrime in the country, coupled with evolving\n\n43\n\n[Table of Contents](#TOC)\n\nregulatory frameworks and enforcement measures, adds uncertainty to the operating environment, emphasizing the necessity for continuous improvements in cybersecurity resilience. See *“— Risks Related to Our Business — Our networks and equipment face potential physical and cybersecurity threats such as theft, vandalism, and acts intended to disrupt our operations, which could materially and adversely affect our operating results*.*”*\n\nThe degree of Governmental oversight and the details of the Government’s new requirements and standards are uncertain, presenting obstacles to our strategic and financial planning efforts. This evolving regulatory landscape may result in an increase in operational costs and the need for strategic adjustments to comply with stricter legal and regulatory standards, which may in turn have a material adverse effect on our financial condition, results of operations and growth prospects.\n\nMoreover, licenses obtained by us under applicable Indonesian laws and regulations may be subject to conditions, compliance with which may be expensive, difficult or, depending on future regulatory changes, practically impossible. It is possible that Governmental authorities could take enforcement actions against us for our failure to comply with such regulations, including the aforementioned conditions. These enforcement actions could result, among other things, in the imposition of fines or the revocation of our licenses. Compliance with such regulations could require us to make substantial capital expenditures and consequently divert funds from our planned construction projects. We could also experience delays in our business schedules as a result of such compliance efforts. Each of the above could materially and adversely affect our business, prospects, financial condition, and results of operations.\n\nIndonesian regulations require telecommunications service providers such as ourselves to share our network infrastructure and capacity with our competitors, and the enforcement of these regulations remain uncertain.\n\nGovernment regulations, including the Job Creation Law of 2023 and its implementing regulation, Ministry of Communication and Informatics Regulation No. 5 of 2021, require telecommunications providers to share network infrastructure. We are required to grant other operators access to our passive infrastructure, such as ducts, towers, and poles, on a fair, reasonable, and non-discriminatory basis. Furthermore, we may be mandated to provide access to our active infrastructure and network capacity based on mutual agreement between operators.\n\nAs the operator with the most extensive infrastructure in Indonesia, these sharing mandates could allow competitors to expand their coverage and services by leveraging our network without incurring the significant capital expenditure required to build their own. The regulations grant the Ministry of Communication and Informatics the authority to determine tariffs if a commercial agreement cannot be reached between operators, creating a risk that we may not be able to charge rates that we consider commercially acceptable. If we are mandated to share our infrastructure and lease capacity at regulated, non-commercial rates, it could diminish our competitive advantage, erode our revenue, and have a material adverse effect on our financial condition and results of operations.\n\nApplicable regulations on tariffs and their implementation as supervised by the MoCD may affect our revenues and earnings.\n\nMoCD Regulation No. 5/2021 governs tariffs for the provision of access to both telecommunications networks and telecommunications services. Tariffs on provisions of telecommunications networks consist of leased network and interconnection fees, whereas the tariffs on provisions of telecommunications services consist of tariffs for basic telephony, value-added telephony, and multimedia services, including internet services for retail customers. MoCD Regulation No. 5/2021 sets out formulas that telecommunications operators like us must refer to in determining the tariff for our services.\n\nUnder MoCD Regulation No. 5/2021, the Director General of Post and Informatics Operations (“**DGPIO**”) of MoCD supervises the implementation of tariffs. In its supervisory role, MoCD may take further action as it sees fit if it deems any of our actions to be potentially disruptive to fair competition in the telecommunications market. Accordingly, our promotional tariffs will need to be carefully planned and calculated to avoid any possible “predatory pricing” or anticompetition claim. If we violate the tariff rules, we may be subject to administrative sanctions under MoCD Regulation No. 5/2021.\n\n44\n\n[Table of Contents](#TOC)\n\nChanges in regulated tariffs also directly impact our revenue. For instance, we derive substantial revenue from interconnection services, as we have the largest telecommunications network in Indonesia and our competitors must pay tariffs to connect to our network. The implementation of IP-based interconnection initiated on January 1, 2025. However, until such implementation is fully completed, our network will continue to operate partially on legacy systems. While this does not immediately impact our revenue, future regulations — particularly the MoCD’s decision on tariffs for full IP-based interconnection — could affect our interconnection revenue model.\n\nRegulated SMS interconnection rates have been decreasing in recent years and may decrease further in the future. Such decrease has had and will have, if continued, a negative impact on our revenue.\n\nMoCD Regulation No. 5/2021 also allows the public to participate in the supervision process by providing them the right to submit complaints and take other actions regarding tariffs that they may view as being unfairly charged by us. In its role of ensuring fair competition in the telecommunications industry and protecting the public interest, the MoCD may have the authority to set upper and lower limits on the tariffs we charge.\n\nRegulations for the configuration of BTS towers may delay the installation of new BTS towers or changes in the placement of existing towers, and may erode our leadership position by requiring us to share our towers with our competitors.\n\nIn accordance with Government Regulations, the construction of BTS towers requires permits from local governments. Obtaining these permits may be cumbersome and take an inordinate amount of time and may adversely affect the allocation, development, and expansion of our BTS towers. We may also be prohibited from setting up new BTS towers in certain areas, thereby restricting our expansion. Our existing BTS towers may also be adversely affected if local governments require any changes to their placement.\n\nIn addition, Government regulations require us to allow other telecommunications operators to lease space on our telecommunications towers in a manner that provides equal opportunity to and without any discrimination among such other telecommunications operators. These regulations enable our competitors to broaden their networks by using our infrastructure, thus avoiding the cost of constructing their own towers. This advantage is particularly significant in urban areas, where securing new tower locations is challenging, allowing competitors to swiftly expand and grow their operations. Moreover, our subsidiary PT Dayamitra Telekomunikasi Tbk (“**Mitratel**”) faces infrastructure sharing obligations for its passive infrastructure including towers and fiber optics. The implementation of these requirements, coupled with the potential issuance of multiple 5G licenses, could limit the availability of new sites for BTS towers in certain regions. Additionally, any mandates for the retrofitting of existing towers to accommodate multiple operators could lead to our incurrence of additional expenses.\n\nIn order to operate our telecommunications towers, Indonesian regulations allow local governments to impose three types of fees: property tax (*Pajak Bumi dan Bangunan*), fees charged in connection with the grant of building approvals (*Persetujuan Mendirikan Bangunan Gedung*), and telecommunications tower control fees. These fees are determined on a cost basis subject to a formula provided by the MoF and the location of the telecommunications towers. While local governments that have imposed such fees have not charged material amounts as at the date hereof, such fees could become material in the future. In addition, there could be material differences in the amount of fees that we would be liable to pay to the relevant local governments. If these risks were to materialize, it could have a material adverse effect on our operating results.\n\nWe may experience local community opposition to some of our tower sites.\n\nWe have experienced, and may in the future experience, local community opposition to our existing sites or the construction of new towers on new sites for various reasons, including aesthetic and alleged health concerns. As a result of such opposition, we could be required by the local authorities to dismantle and relocate certain towers. Opposition to the construction of new towers could also cause delays in the availability and completion of new towers. In extreme cases,\n\n45\n\n[Table of Contents](#TOC)\n\nvandalism could result in damaged equipment. In the year ended December 31, 2025, we were involved in 61 community disputes.\n\nOpposition has also materialized regarding the site locations of some of Mitratel’s towers and the acquisition by Mitratel of other existing towers, mainly due to insufficient engagement with nearby residents concerning construction-related issues and the transfer of ownership rights from previous owners to Mitratel. If we are required to relocate a material number of our towers and cannot locate replacement sites that are acceptable to our customers, and/or local communities, or litigation proceedings, production delays or damages to equipment occur, it could materially and adversely affect our business, prospects, results of operations, and financial condition.\n\nOur electronic money business is highly regulated.\n\nWe are subject to multiple rules and regulations in respect of our electronic money (“E-Money”) business. The specific regulation of E-Money is mainly governed by BI. In 2021, BI introduced new rules allowing parties with payment system business activities to obtain one license for multiple types of payment services, compared to the previous rules requiring parties to obtain one license for each type of payment service they provided (e.g., separate licenses for each E-Money, payment gateway,  e-wallet, and remittance business).\n\nAny party that wishes to conduct E-Money business activities in Indonesia must first obtain a payment service provider (*Penyedia Jasa Pembayaran* or “**PJP**”) license granted by BI which may, depending on its category, cover specific payment system business activities such as E-Money. Our subsidiary Telkomsel holds a majority equity stake in PT Fintek Karya Nusantara (“**Finarya**”). Finarya has obtained a PJP Category 1 license from BI which covers E-Money and remittance services. However, BI has the authority to take further actions as it sees fit, such as revoking a license, shortening the license period, or limiting the license holder’s activity. If BI imposes any such actions on Finarya, our ability to conduct our ordinary course E-Money business would be limited, which may adversely affect our business, financial condition, and results of operations. See also *“Item 4B. Information on the Company — Licensing — Payment Method Using E-Money”* for more details on BI’s requirements for licensing.\n\nBI regulations governing payment system providers in Indonesia impose multiple requirements on BI license holders, including certain restrictions on shareholding and corporate governance as well as risk management and information system capability requirements. If we, through Telkomsel and Finarya, fail to comply with any of these obligations, we will be subject to administrative sanctions. Any sanction imposed on Finarya could materially and adversely affect our business, financial condition, results of operations and prospects.\n\nWe are subject to numerous non-tax state revenue payments and USO Contribution and any disagreement with the relevant authorities relating to such payments and/or failure to make such payments could subject us to the revocations of certain of our licenses, with limited recourse.\n\nWe are subject to multiple rules and regulations authorizing the Government to collect non-tax state revenue from us. The Government collects non-tax revenue from, among other things, tests for telecommunications devices, telecommunications operations and use of radio frequency spectrum. As a result, every licensed telecommunications operator must pay the Telecommunications BHP and USO Contribution. Telecommunications operators that use a communications satellite must also pay a satellite orbit fee.\n\nAccording to the Telecommunications Law, a telecommunications operator that fails to make the non-tax state revenue payment and participate in USO Contribution may be subject to administrative sanctions; the most adverse sanction is revocation of an operator’s telecommunications-related licenses issued by MoCD (though this should be preceded by written warnings). While we have not previously failed to make the requisite payments or disagreed with the computation of such payments, any failure by us to comply with these obligations may cause our licenses to be revoked. In addition, to our knowledge, procedures for challenging the assessment of any such obligations or for challenging sanctions that are assessed against operators with the relevant authorities have not been tested. Any revocation of such licenses could have a material adverse effect on our financial condition, results of operations and liquidity.\n\n46\n\n[Table of Contents](#TOC)\n\n**Risks Related to our Corporate Structure and Governance**\n\nWe are subject to the control of the Government and its interests may not necessarily align with the interest of our other shareholders or our own interests.\n\nAs of the date hereof, the Government is our ultimate controlling shareholder. This control is exercised through a dual-layer structure comprising both direct and indirect mechanisms that grant the Government substantial influence over our governance, operations, and strategic direction.\n\nDirectly, the Government, through the SOE Regulatory Agency, holds our single, non-transferable Dwiwarna Share. This share grants the Government special rights under our Articles of Association and Indonesian law, including the power to approve the appointment, removal, and nomination of all members of our Board of Directors and Board of Commissioners, as well as veto rights over amendments to our Articles of Association, decisions on mergers or dissolution, and changes to our capital structure. These rights allow the Government to exert direct and decisive influence over fundamental corporate governance matters.\n\nIndirectly, the Government exercises control through its majority ownership of our Series B Shares. Pursuant to a restructuring formalized by Law No. 16 of 2025 and its implementing regulations, the Government’s majority stake in our Series B Shares is held by PT Danantara Asset Management (“**DAM**”), an operational holding company. DAM, in turn, is wholly owned by the Daya Anagata Nusantara Investment Management Agency (*Badan Pengelola Investasi Daya Anagata Nusantara* or “**BPI Danantara**”), which is a Government-owned entity vested with the statutory authority to establish strategic guidelines and policies for SOEs, including our Company. As a result, the Government, acting through BPI Danantara and DAM, is able to exert significant influence over our operational management and strategic direction.\n\nThe Government also holds a Dwiwarna Share in our competitor, PT Indosat Tbk (“**Indosat Ooredoo Hutchison**” or “**IOH**”), and may have the ability to exercise similar control over IOH.\n\nThe interests of the Government, as our ultimate controlling shareholder, may differ from the interests of our other shareholders. The Government may prioritize broader public policy objectives or national interests, such as the development of the telecommunications sector in a manner that favors one operator over another, which may not align with our commercial objectives or the goal of maximizing shareholder value. Should the Government cause us to pursue initiatives or enter into transactions that prioritize public policy considerations without adequate commercial justification or compensation, or if its control over us and our competitors, such as IOH, leads to market conditions or specific directives that favor any other telecommunications operator, our business, financial condition, results of operations and prospects could be materially and adversely affected.\n\nWe may experience further changes in governance as an SOE.\n\nThe Government enacted Law No. 1 of 2025 on the Third Amendment to the SOE Law, introducing a restructuring framework for SOEs, including the establishment of Operational Holding and Investment Holding entities under the management of BPI Danantara. As part of this restructuring, Government Regulation No. 15 of 2025 on the Additional State Capital Participation of the Republic of Indonesia into the Share Capital of PT Biro Klasifikasi Indonesia (Persero) (“**BKI**”) for the Establishment of an Operational Holding (“**GR 15/2025**”) mandated the transfer of the Government’s Series B shares in various SOEs, including our Company, to DAM (previously known as BKI) through in-kind state capital participation, thereby designating DAM as an operational holding responsible for overseeing the operational activities of assigned SOEs. In addition, Government Regulation No. 16 of 2025 on State Capital Participation of the Republic of Indonesia in BPI Danantara (“**GR 16/2025**”) further formalised DAM’s status as an operational holding by transferring all of its Series B shares to BPI Danantara, resulting in BPI Danantara becoming DAM’s majority shareholder, while the Government retained ultimate control through the Dwiwarna Share. Collectively, these regulatory actions constituted the initial phase of the restructuring of SOE governance under the new statutory framework.\n\n47\n\n[Table of Contents](#TOC)\n\nOn October 16, 2025, the Government enacted Law No. 16 of 2025 on the Fourth Amendment to the SOE Law, which introduced further adjustments to the SOE governance framework, including the transformation of the former MSOE into the SOE Regulatory Agency. Under this amendment, the SOE Regulatory Agency was established as a Governmental body mandated to perform regulatory, supervisory, and policy-formulating functions in the SOE sector. Given its status as a Government agency and the absence of any statutory indication that it constitutes a separate legal entity, the SOE Regulatory Agency effectively assumes the legal and functional position previously held by the MSOE, including acting as the Government’s representative in exercising the rights attached to the Dwiwarna Share in SOEs. Its authorities largely mirror those of the former MSOE, with certain enhanced powers such as approving the work plan of BPI Danantara. As a regulator established under statutory law, the SOE Regulatory Agency also exercises regulatory authority consistent with the broader legislative framework under Law No. 12 of 2011 on the Establishment of Laws and Regulations.\n\nThe Fourth Amendment to the SOE Law also reallocates certain strategic governance rights, previously attached to the Government’s Dwiwarna Share to BPI Danantara. Under the revised framework, BPI Danantara is vested with statutory authority to formulate strategic guidelines and policies for SOEs, including in areas such as legal compliance, accounting and finance, operational planning, and risk management. This constitutes a material shift in the governance architecture of SOEs and may affect our corporate governance framework, as strategic directions or policy determinations issued by BPI Danantara could influence our internal policies, operational priorities, and management processes. The involvement of BPI Danantara in certain of our decision-making processes could also impact the pace of our decision-making processes. For example, pursuant to amendments to our Articles of Association adopted at our Extraordinary General Meeting of Shareholders on December 12, 2025, and restated in Notarial Deed No. 07 dated January 6, 2026, any write-off of our uncollectible receivables, including bad principal receivables, interest receivables, fines, fees, and other non-principal receivables written off for purposes of restructuring or settlement, must first obtain the prior approval of BPI Danantara before the Board of Commissioners may grant its own approval. These changes may also alter the coordination dynamics among BPI Danantara, the SOE Regulatory Agency, and operational holding entities, potentially affecting the balance between shareholder rights and Governmental regulatory authority.\n\nWhile the transformation of the MSOE into the SOE Regulatory Agency is not expected to have a material impact on our governance structure, the expansion of BPI Danantara’s statutory authority introduces uncertainty into the future governance landscape for SOEs, including our Company. At this stage, no implementing regulations have been issued to clarify the scope, mechanisms or practical application of BPI Danantara’s newly vested strategic policy-setting authority. As a result, we cannot predict how BPI Danantara will exercise such authority going forward, whether future strategic directives may materially affect our operations, compliance frameworks or financial policies, or how coordination among the SOE Regulatory Agency, BPI Danantara and Operational Holding entities will function in practice. We continue to monitor the issuance of implementing regulations under the amended SOE Law, as these may further define the scope of BPI Danantara’s authority and introduce governance adjustments that could affect our operations, strategic planning and internal processes.\n\nWe are dependent on our subsidiary, Telkomsel, a cellular telecommunications services and cellular telecommunications networks company.\n\nWe derived 74.9%, 73.1% and 72.2% of our revenue in 2023, 2024 and 2025 respectively, from our mobile business through our 69.9% majority-owned subsidiary, Telkomsel. The remaining 30.1% interest in Telkomsel is held by Singapore Telecom Mobile Pte. Ltd. (“**Singtel**”). In addition, in line with our FMC initiative, we entered into an agreement with Telkomsel to combine our fixed broadband and mobile broadband services into a single business entity, by transferring a portion of our assets and liabilities allocated to the IndiHome business segment to Telkomsel (the “**IndiHome Integration**”). After the IndiHome Integration, there has been an increase in the contribution from Telkomsel to our consolidated revenue, including in 2025, compared to Telkomsel's contribution prior to the IndiHome Integration. See *“Item 5A—Operating Results.”*\n\nSingtel, a telecommunications company based in Singapore, may seek to influence the management, operation, and performance of Telkomsel. In the event that there are differences between us and Singtel regarding the business,\n\n48\n\n[Table of Contents](#TOC)\n\nstrategy, and operations of Telkomsel, these issues may take time to resolve, or may not result in a positive outcome for our Group. These factors could materially and adversely affect our business, financial condition, revenue and operating results.\n\nOur efforts to streamline our corporate structure may not create expected synergies and efficiency in a timely fashion or at all.\n\nTo foster efficiency and increase synergies, we constantly assess opportunities to streamline our corporate structure, for instance by eliminating duplication of business management processes and internal administrative processes, and also by simplifying our corporate ownership structure. This exercise allows us to rationalize administrative costs and consolidate assets and activities used in the same businesses to use our resources and unlock their value more efficiently. In April 2023, in line with our FMC initiative, we entered into an agreement with Telkomsel to combine our fixed broadband and mobile broadband services into a single business entity, by transferring a portion of our assets and liabilities allocated to the IndiHome B2C business segment to Telkomsel.\n\nAs we focus on the development of our digital service offerings, including smart platforms and digital services, we have started regrouping our teams, resources, and assets under one corporate entity. We also aim to enhance our regional entities to better tailor our service offerings to local market dynamics and respond more effectively to competitive changes in such markets, such as challenges from local competitors or the expansion of the service offerings or networks of national or regional competitors in such markets. On June 4, 2024, a transaction was carried out to increase Telkom’s contributed capital in TDE by Rp1,626,900,000,000 to continue the development of the Cikarang Hyperscale Data Center with an additional IT Load capacity of 18 MW.\n\nA cornerstone of this strategy in 2025 has been the partial spin-off of our Wholesale Fiber Connectivity business and assets to our controlled subsidiary, TIF. We signed a Conditional Spin-Off Agreement on October 20, 2025, for this transaction, valued at approximately Rp35.79 trillion, which represents a key phase in our plan to establish TIF as a dedicated digital infrastructure company. The spin-off is intended to create a more focused business, unlock the value of our fiber assets, and improve operational efficiency. This initiative is part of a multi-phase plan, with subsequent stages of asset transfers to TIF anticipated in 2026, subject to further assessment and approvals.\n\nThese streamlining efforts, however, have been delayed, and we may experience further delays or unforeseen challenges. In addition, during transition periods, we may incur costs inherent to the implementation of such streamlining efforts without realizing the anticipated benefits to our business, competitiveness, costs, and synergies, which could have a negative effect on our financial condition and results of operations.\n\nOur Articles of Association contain certain anti-takeover provisions that could adversely affect the rights of holders of our ordinary shares and ADSs.\n\nOur Articles of Association contain certain anti-takeover provisions that could adversely affect the rights of holders of our ordinary shares and ADSs. These provisions could have the effect of delaying, preventing or deterring a change in control, and could limit the opportunity for our shareholders to receive a premium for their ADSs and/or shares, and could also materially decrease the price that some investors are willing to pay for our ADSs and/or shares.\n\n**Risks Related to Indonesia**\n\nPolitical and Social Risks\n\nCurrent political and social events in Indonesia may adversely affect our business.  \n\nIndonesia has, from time to time, experienced political instability. Indonesia also has many political parties, and securing a clear electoral majority has been proven challenging for any political party to date. These events have heightened political dynamics, contributing to general social and civil unrest on certain occasions in recent years. For example, since\n\n49\n\n[Table of Contents](#TOC)\n\n2000, thousands of Indonesians have participated in demonstrations in Jakarta and other cities, expressing both support and opposition to former presidents Abdurrahman Wahid, Megawati Soekarnoputri, Susilo Bambang Yudhoyono, Joko Widodo, and the current President Prabowo Subianto, who was recently inaugurated as Indonesia’s eighth president for the 2024–2029 term.\n\nPublic demonstrations have frequently been triggered by social and political concerns, including regional election laws, civil rights, democratic processes, and controversial public policies. Although many demonstrations have remained peaceful, some have escalated into violence. Most recently, beginning on August 25, 2025, large-scale demonstrations took place outside the national parliament in Jakarta in response to public dissatisfaction over legislative compensation and broader governance concerns. These protests escalated into violent clashes between demonstrators and security forces, prompting the authorities to deploy significant police and military personnel and impose traffic restrictions around key Government areas. The demonstrations subsequently extended over several days and spread to multiple cities, where public anger widened to include criticism of law-enforcement practices and perceived lack of Government accountability. Reports indicated the use of tear gas and water cannons by security forces, road closures affecting mobility, arrests of participants, and continued unrest across affected regions. These events underscore the potential for political grievances to escalate and generate broader disruptions.\n\nIn addition to evolving political dynamics, Indonesia continues to face significant social and civil unrest, particularly in Papua, where separatist tensions have intensified. In the first quarter of 2025, over 86,000 people were internally displaced due to armed confrontations between Indonesian National Military (*Tentara Nasional Indonesia* or “**TNI**”) and the West Papua National Liberation Army (*Tentara Pembebasan Nasional Papua Barat – Organisasi Papua Merdeka* or “**TPNPB-OPM**”) separatist group, with serious clashes reported in Intan Jaya and ultimatums issued by separatist elements to the military. In April 2025, members of the TPNPB-OPM killed approximately 15 civilian gold miners in Yahukimo Regency, prompting calls from civil society and Papuan leaders for a more peaceful, humanitarian approach. Senior regional officials have publicly questioned the continued deployment of security forces, noting that the current strategy has not sufficiently reduced violence and has contributed to civilian suffering. These developments highlight ongoing challenges to stability and unity across Indonesia’s culturally and regionally diverse population, and the escalation of conflict in Papua poses risks to our operations, including security concerns, potential supply chain disruptions, and reputational exposure.\n\nMoreover, during the course of President Prabowo Subianto and Vice President Gibran Rakabuming Raka’s administration, the direction and pace of policy implementation remain in transition. The Government has announced numerous policy initiatives, including reforms in food security, defense modernization, fiscal spending and budget allocation, social welfare programs, infrastructure development, and energy transition plans, many of which have not yet been accompanied by detailed implementing regulations. This combination of policy breadth and regulatory uncertainty may create short-term volatility and unpredictability in the business environment. In addition, the incumbent administration has initiated several changes to existing legislation, including the fourth amendment to the SOE Law, which may result in further adjustments to the regulatory framework. Challenges in implementation, coupled with frequent judicial reviews, may further affect the stability and predictability of the legal and regulatory environment, potentially impacting business operations across sectors.\n\nGiven these political and social dynamics, including public demonstrations and social events, there is potential for disruption to our operations or those of our customers and could affect the financial condition of Indonesian companies in general, depressing the prices of Indonesian securities on the Indonesia Stock Exchange (“**IDX**”) and the value of the Rupiah relative to other currencies. This could in turn materially and adversely affect our business, financial condition, results of operations, and prospects.\n\n​\n\n50\n\n[Table of Contents](#TOC)\n\nTerrorist activities in Indonesia could destabilize Indonesia, which would adversely affect our business, financial condition and results of operations, and the market price of our securities.\n\nThere have been a number of terrorist incidents in Indonesia in the past two decades, which resulted in deaths and injuries, including a bombing at a Catholic church in Makassar on March 28, 2021 that injured more than 20 people and a bombing in Bandung, West Java on December 7, 2022, that killed one person and injured seven people.\n\nAlthough the Government has successfully countered some terrorist activities in recent years and arrested several of those suspected of being involved in these incidents, terrorist incidents may continue and, if serious or widespread, might have a material adverse effect on investment and confidence in, and the performance of, the Indonesian economy and may also have a material adverse effect on our business, financial condition, results of operations and prospects and the market price of our securities.\n\nWe may be affected by uncertainty in the delineation of the respective prerogatives and responsibilities of, and the balance of power between, local governments and the central Government in Indonesia.\n\nSince 1999, Indonesia has undergone significant reforms in fiscal decentralization, devolution of power to local governments, and regional autonomy. As of the date hereof, there is uncertainty in respect of the responsibilities and the balance of power between the local and central governments regarding several subject matters. Those include procedures for renewing licenses, approvals, and levies imposed by local governments on our telecommunications towers.\n\nFor example, in 2023, local governments, including the government of Surabaya City, introduced regulations for calculating lease fees for land used for telecommunications infrastructure, whether on state-owned or public land. This model has been adopted by 59 other regencies/cities, such as Sidoarjo Regency, leading to increased levies on our digital infrastructure. The potential for more local governments to enact similar regulations raises concerns about regulatory inconsistencies and compliance difficulties. In addition, local governments have from time to time sought to levy additional taxes or obtain new contributions, including for the utilization of certain land owned by the local government in the construction of our towers. This ongoing uncertainty could complicate our compliance efforts and raise questions about the legality of new taxes or the authority of local governments to enact further regulations impacting our business. These factors may adversely affect our business operations, financial health, and future growth prospects.\n\nMacroeconomic Risks\n\nNegative changes in global, regional or Indonesian economic activity could materially and adversely affect our business.\n\nOur business performance is susceptible to downturns in the Indonesian, regional and global macroeconomic environment. In the past, Indonesia's economy has faced major external shocks, such as the Asian economic crisis of 1997 and the global economic crisis in 2008, leading to recession, currency depreciation, high interest rates, and social unrest. While the Indonesian economy continues to recover, certain internal and external pressures could have an adverse effect on our business, financial condition, results of operations and prospects.\n\nDownside risks persist that could deteriorate the economic situation in Indonesia, Asia and globally. Key concerns include global trade disputes that disrupt global financial markets, expectations relating to the monetary and interest rate policies of the United States, concerns over China's economic health, economic protectionism, and the military conflicts in Gaza and Ukraine and related geopolitical tensions.\n\nFor instance, ongoing trade disputes between major economies, particularly the United States and China, continue to create uncertainty and volatility in global financial markets. Since 2025, these tensions have significantly intensified, with the U.S. imposing sweeping additional tariffs on Chinese goods and China implementing retaliatory measures, including increased tariffs and export restrictions on critical goods. In 2026, this trajectory has accelerated: a broad-based U.S. tariff reset, partially triggered by U.S. court proceedings and executive action, has disrupted global trade patterns and\n\n51\n\n[Table of Contents](#TOC)\n\ncreated significant volatility in emerging market currencies and capital flows. U.S.-China bilateral ties remain structurally adversarial, and any resumption of active trade hostilities could further reduce capital inflows and investment in emerging markets such as Indonesia, exerting downward pressure on the Rupiah, disrupting regional supply chains, and increasing external financing costs.\n\nFurther, the U.S. Federal Reserve's monetary policy decisions continue to impact global markets. Through 2025 and into 2026, the U.S. Federal Reserve has navigated a complex policy environment, balancing residual inflation concerns, tariff-induced price pressures, and signs of slowing U.S. economic growth, resulting in a prolonged period of elevated interest rates relative to the pre-2022 baseline. This sustained higher-rate environment causes fluctuations in capital flows and currency values in emerging markets, including Indonesia. Persistent inflationary pressures in Indonesia and higher borrowing costs remain a concern, potentially impacting our profitability if we are unable to pass on increased financing expenses.\n\nIn addition, China's economic slowdown persisted into 2026, with ongoing challenges in its property sector, consumer demand, and financial markets. This has had ripple effects across the region, dampening business sentiment and investment appetite. The sluggish recovery in China continues to strain global supply chains and weighs on regional economic growth, creating uncertainty for countries reliant on trade with China, including Indonesia.\n\nThe conflicts in Ukraine and the Middle East remain significant, carrying broader regional and global implications. The ongoing conflict in Ukraine continues to drive disruptions in global energy and agricultural markets, with enduring economic sanctions affecting supply chains. Meanwhile, volatility in the Middle East has intensified, with ongoing conflict and geopolitical escalation in the region in 2025 and into 2026 continuing to exert upward pressure on global energy prices and contributing to intermittent supply disruptions. These geopolitical tensions increase uncertainty in global markets, contributing to inflationary pressures and reducing global business and consumer confidence. The reconfiguration of global security arrangements, including shifts in NATO commitments, increased defense spending across Europe and Asia, and heightened great-power competition, has introduced an additional layer of structural unpredictability into the global trade and investment environment. Further regional escalations could pose a significant downside risk to global growth and stability, with cascading effects on developed and emerging economies, including Indonesia and other Southeast Asian markets.\n\nFollowing the pressures in the U.S. and global banking sector in 2023, the global financial system has faced ongoing challenges. While regulatory measures have been implemented to enhance stability, concerns about the resilience of financial institutions remain. Banks in both developed and emerging markets have imposed tighter lending conditions, resulting in reduced credit availability, increased market volatility, and heightened risks for businesses that rely on capital access and financing.\n\nThese adverse economic conditions, geopolitical developments, and internal strategic and governance risks could suppress business activity, disposable income, and consumer purchasing power, which may reduce demand for communication services, including our services. Such a decline in demand, or a failure to successfully execute our strategic initiatives, could have a material adverse effect on our business, financial condition, results of operations and prospects. Prolonged global uncertainties or future economic instability could have a material and adverse impact on the performance of our business.\n\nFluctuations in the value of the Indonesian Rupiah may materially and adversely affect us.\n\nOur functional currency is the Indonesian Rupiah. Historically, the Indonesian Rupiah has been subject to significant depreciation and volatility against the U.S. Dollar and other foreign currencies. From a 2021 high of Rp14,219 to US$1.00 on December 24, 2021, the Rupiah depreciated to a low of Rp16,676 to US$1.00 on December 31, 2025, (based on the middle exchange rate published by Reuters Refinitiv), due to, among other factors, the slowing global economy and strong U.S. Dollar. The Indonesian Rupiah may continue to soften in the future.\n\n52\n\n[Table of Contents](#TOC)\n\nIn addition, while the Indonesian Rupiah has generally been freely convertible and transferable, from time to time, BI has intervened in the currency exchange markets in furtherance of its policies, either by selling Indonesian Rupiah or by using its foreign currency reserves to purchase Indonesian Rupiah. The current floating exchange rate policy of BI may be modified, and the Government may take additional action to stabilize, maintain or increase the Indonesian Rupiah’s value, and any of these actions, if taken, may not be successful. Modification of the current floating exchange rate policy could result in significantly higher domestic interest rates, liquidity shortages, capital or exchange controls, or the withholding of additional financial assistance by multinational lenders. This could result in a reduction of economic activity, an economic recession, loan defaults or declining subscriber usage of our services, and as a result, we may also face difficulties in funding our capital expenditures and in implementing our business strategy. Any of the foregoing consequences could materially and adversely affect our business, financial condition, results of operations and prospects.\n\nRapid and excessive increases in levels of inflation and interest rates in Indonesia could materially and adversely affect our financial condition and results of operations.\n\nInterest rates are affected by the inflation rate. Historically, Indonesia has experienced periods of high inflation. The inflation rate (measured by the year-on-year change in the consumer price index) remains volatile with an annual inflation rate of 1.57% and 2.92% in the years ended December 31, 2024 and 2025, respectively. Based on ongoing economic pressures in the wake of the military conflict in Ukraine, it is anticipated that inflation may continue to rise in the near future. Interest rates have increased rapidly and substantially as central banks in several countries and regional blocks raised interest rates in an effort to subdue inflation. If inflation causes interest rates to further increase significantly and results in a rapid increase in benchmark rates, it could have a material adverse effect on Indonesia’s economy, business climate and consumer confidence.\n\nEven if we have not yet experienced any such impact on our revenues in 2025*,* higher inflation rates generally lead to a reduction in purchasing power, thus increasing the likelihood of a lower level of demand for our products and services in Indonesia, which would have a negative impact on our revenues. Further, any increase in our costs and expenses due to inflationary pressures that we would not be able to match (partially or fully) by increasing our prices would decrease our profit margin. Eventually, tighter monetary policy and potentially higher long-term interest rates may drive a higher cost of capital for our business. As a result, a high inflation rate in Indonesia could have a material adverse effect on our business, financial condition, results of operations and prospects.\n\nDowngrades of credit ratings of the Government or Indonesian companies could materially and adversely affect our business.\n\nAs of the date of this annual report on Form 20-F, Indonesia’s sovereign foreign currency long-term debt was rated “Baa2” with negative outlook by Moody’s, “BBB” with stable outlook by Standard & Poor’s and “BBB” with negative outlook by Fitch.\n\nThese ratings reflect an assessment of the Government’s overall financial capacity to pay its obligations and its ability or willingness to meet its financial commitments as they become due. Moody’s, Standard & Poor’s, Fitch and other statistical rating organizations may change or downgrade the credit ratings of Indonesia or Indonesian companies. In particular, the credit ratings of Indonesia or Indonesian companies, have been and may be downgraded in the future. Any downgrade could have an adverse impact on liquidity in the Indonesian financial markets, the ability of the Government and Indonesian companies, including us, to raise additional financing, and the interest rates and other commercial terms at which such additional financing is available. Interest rates on our floating-rate Rupiah-denominated debt would also likely increase. Such events could materially and adversely affect our business, financial condition, results of operations, prospects and/or the market price of our securities.\n\nUncertainty in respect of manpower legislation in Indonesia could materially and adversely affect our business.\n\nThe Job Creation Law in Indonesia has undergone significant changes and extensive judicial review since its introduction. Initially enacted in 2020 to encourage investment and stimulate economic growth, the Job Creation Law has\n\n53\n\n[Table of Contents](#TOC)\n\nbeen amended numerous times and has faced numerous legal challenges, drawing substantial criticism for its potential to undermine labor rights. The enactment of the Job Creation Law in 2020 triggered widespread protests across Indonesia in 2020 and 2021. Labor organizations argued that the Job Creation Law favored business interests at the expense of worker protections, leading to nationwide mass demonstrations and calls from trade unions and civil society groups for judicial review by the Constitutional Court.\n\nIn 2021, the Constitutional Court ruled the law “conditionally unconstitutional,” allowing it to remain in effect while requiring the Government and the House of Representatives to redraft it within two years. To address global economic challenges that could significantly impact Indonesia’s economy and job creation, the Government issued Government Regulation in Lieu of Law (*Peraturan Pemerintah Pengganti Undang-Undang*) No. 2 of 2022 on Job Creation (“**Lieu of Law No. 2/2022**”) to support domestic economic growth.\n\nOn March 31, 2023, the Government enacted the Job Creation Law 2023, replacing the previous Job Creation Law and incorporated the provisions of Lieu of Law No. 2/2022. However, civil society groups and labor unions criticized the Job Creation Law 2023 for disadvantaging workers, prompting the Labor Party and unions to file for judicial review in the Constitutional Court. On October 31, 2024, the Constitutional Court upheld 21 of the 71 contested provisions, focusing on provisions related to wage eligibility and minimum wage adjustments to promote proportionality and adequate living standards for employees. The Constitutional Court also directed the Government and legislature to draft a standalone manpower law by 2026, adding further uncertainty to the Indonesian labor regulatory framework.\n\nAs of September 30, 2025, the Government has formed an official drafting team comprising representatives from relevant ministries and tripartite stakeholders, and has commenced a series of public consultations with labor unions, employer associations, business chambers, and civil society groups. These consultations remain ongoing, and the scope, structure, and substantive policy direction of the forthcoming manpower law continue to be subject to further deliberation. Given the early stage of the drafting process and the possibility of material revisions arising from stakeholder negotiations, the timing and final content of the new manpower law remain uncertain and may result in additional regulatory changes affecting employment arrangements, wage determinations, outsourcing practices, and other labor-related obligations applicable to employers in Indonesia.\n\nThe evolving regulatory landscape creates significant uncertainties in Government oversight and compliance standards, which could affect our strategic and financial planning. The mandate to enact a standalone manpower law by 2026 adds another layer of complexity, as potential changes to core labor provisions could require adjustments to our employment practices. New labor regulations may increase operational costs as we adjust to meet stricter compliance requirements, particularly in areas such as employee compensation, benefits, and severance. We may need to make additional investments in human resources and compliance systems to address these challenges. The changes necessitated by the evolving labor regulatory landscape could have a material and adverse effect on our cost base, which would in turn materially and adversely affect our business, financial condition, results of operations, and prospects.\n\nRisks relating to Natural Disasters and Climate Change\n\nIndonesia is vulnerable to natural disasters and events beyond our control, which could materially and adversely affect our business and operating results.\n\nMany parts of Indonesia, including areas where we operate, are prone to natural disasters such as floods, lightning strikes, typhoons, earthquakes, tsunamis, volcanic eruptions, fires, droughts, power outages, and other events beyond our control. The Indonesian archipelago is one of the most volcanically active regions in the world as it is located in the convergence zone of three major lithospheric plates. It is subject to significant seismic activity that can lead to destructive earthquakes, tsunamis or tidal waves. Flash floods and more widespread flooding also occur regularly during the rainy season from November to April. Cities, especially Jakarta, are frequently subject to severe localized flooding which can result in major disruption and, occasionally, fatalities. Landslides regularly occur in rural areas during the wet season. In November 2025, following a cyclone, floods caused fatalities and damages in Sumatra. From time to time, natural disasters have killed, affected or displaced large numbers of people and damaged our equipment. These events in the past have\n\n54\n\n[Table of Contents](#TOC)\n\ndisrupted, and may in the future, disrupt our business activities, cause damage to equipment, and adversely affect our financial performance and profit.\n\nFor example, the island of Java has been impacted by strong earthquakes in November and December 2022, and the region remains prone to heavy rains, flooding, and volcanic eruptions. In 2024, several natural disasters and incidents disrupted telecommunications infrastructure, including earthquakes affecting STO Bawean and Kebalen on March 22, 2024, Witel West Sumatra on May 12, 2024, and Witel Mataram on May 14, 2024. Given the geography of Indonesia, we are highly reliant on the use of submarine cables to provide services across the Indonesian archipelago. These submarine cables may be damaged by volcanic activity or friction with the ocean floor caused by earthquake tremors or otherwise, which may disrupt our ability to provide services to customers.\n\nTo prepare for natural disasters, we have implemented a business continuity plan and a disaster recovery plan, which we test regularly, and we have insured certain of our assets to protect from any losses attributable to natural disasters or other phenomena beyond our control. However, our business continuity and disaster recovery plans may not allow us to immediately recover from resulting damages and disruptions, our insurance coverage may be insufficient to cover potential losses, the premium payable for these insurance policies upon renewal may increase substantially in the future, and natural disasters may significantly disrupt our operations.\n\nFuture natural disasters may have a significant impact on us, Indonesia or the Indonesian economy. A significant earthquake, other geological disturbance or weather-related natural disaster in any of Indonesia’s more populated cities and financial centers could severely disrupt the Indonesian economy and undermine investor confidence, thereby materially and adversely affecting our business, financial condition, results of operations and prospects.\n\nWe are exposed to the potential for financial loss and further non-financial detriments arising from climate change and society’s response to it.\n\nThis risk consists principally of (i) physical risks, being the risks arising from increasing frequency and severity of acute weather-related events and longer-term chronic shifts in climate patterns, and (ii) transition risks, being the risks arising from the process of adjustment to a low-carbon economy. Together, these are referred to as “**Climate Risk.**”\n\nClimate Risk continues to be a core focus of regulatory policy-making across all jurisdictions in which we operate, including as a result of initiatives relating to various United Nations climate summits advocating for global actions to limit temperature rise. For example, many countries are incorporating environmental targets into their domestic policies, with increased pressure to set ambitious sustainability goals. We anticipate that the climate-related regulatory environment in which we operate will be subject to further regulatory developments. Such regulatory developments, together with existing guidance and expectations, may increase the potential transition risks for us, by mandating investments of resources for regulatory compliance, potential GHG emission taxes, and additional environmental monitoring and reporting obligations. These developments may raise the costs associated with energy consumption, notably as expenses on electricity represent a substantial portion of our operational costs. In addition, customer and public perceptions of our efforts to mitigate climate change may limit demand for our products and services, particularly if people perceive our efforts to be less effective than those of our competitors.\n\nIf governments fail to enact policies that limit the impact of global warming, our operations may be particularly susceptible to the physical risks of climate change such as droughts, floods, sea level change and average temperature change. For example, severe weather events have caused increased volatility in commodity prices, exacerbated disruptions in global supply chains, and impacted regions in which we operate, and may damage our infrastructure by causing failures of our fixed wireline and wireless networks. Should severe natural disasters occur in quick succession, we may not have sufficient resources to repair and restore our infrastructure in a timely and cost-effective manner.\n\nIn addition, rising temperatures could increase our operating costs by intensifying the cooling requirements of our network equipment and heightening the incidence of equipment failures, leading to write-offs and premature replacements. This upsurge in equipment failures could increase the risk of service disruption. The occurrence or\n\n55\n\n[Table of Contents](#TOC)\n\ncontinuance of any of the above-mentioned risks could have a material adverse effect on our financial condition, results of operations and, if severe or prolonged, our prospects.\n\n**Risks Related to our ADSs**\n\nThe trading price of our ADSs may be volatile, which could result in substantial losses to you.\n\nThe trading price of our ADSs may fluctuate widely due to factors beyond our control. As a result of this volatility, investors may not be able to sell their ADSs at or above the price paid for the ADSs or ordinary shares, respectively. In addition to the factors discussed in this “Risk factors” section and elsewhere in this annual report on Form 20-F, these factors include:\n\n·\n\nVariations in our revenue, earnings, cash flow and operating data;\n\n·\n\nRegulatory or legal developments in Indonesia, jurisdictions where we carry out our operations or in the United States;\n\n·\n\nAnnouncements of new investments, acquisitions or strategic partnerships by us or our competitors;\n\n·\n\nGeneral economic, political, and market conditions and overall fluctuations in the financial markets in Indonesia, the United States, and other countries where we carry out our operations;\n\n·\n\nSales volumes of our ADSs or ordinary shares, or sales of our ADSs or shares by our senior management, directors, or our large shareholders, or the anticipation that such sales may occur in the future;\n\n·\n\nStock market price and volume fluctuations of comparable companies and, in particular, companies that operate in the telecommunications industry or with most of their operations in Indonesia;\n\n·\n\nInvestors’ general perception of us and our business;\n\n·\n\nAnnouncements of new products, services and expansions by us or our competitors;\n\n·\n\nChanges in financial estimates or recommendations by securities analysts;\n\n·\n\nDetrimental adverse publicity about us, our services or our industry;\n\n·\n\nAdditions or departures of key personnel; and\n\n·\n\nPotential litigation or regulatory investigations.\n\nAny of these factors may result in large and sudden changes in the volume and price at which our ADSs or ordinary shares will trade.\n\nIf securities or industry analysts do not publish research reports about us or our business, or if they adversely change their recommendations regarding our ADSs, the market price for our ADSs and trading volume could decline.\n\nThe trading market for our ADSs could be influenced by research reports that industry or securities analysts publish about us or our business. If one or more analysts who cover us downgrade our ADSs or ordinary shares, the market price for our ADSs would likely decline. If one or more of these analysts cease to cover us or fail to regularly publish reports on us, we could lose visibility in the financial markets, which in turn could cause the market price or trading volume for our ADSs to decline.\n\n56\n\n[Table of Contents](#TOC)\n\nThe different characteristics of the capital markets in Indonesia and the U.S. may negatively affect the trading prices of our ADSs and shares.\n\nAs a dual-listed company, we are subject to IDX and NYSE listing and regulatory requirements concurrently. The IDX and the NYSE have different trading hours, trading characteristics (including trading volume and liquidity), trading and listing rules, and investor bases (including different levels of retail and institutional participation). As a result of these differences, the trading prices of our ADSs and our ordinary shares differ from time to time due to currency fluctuations and other factors.\n\nFluctuations in the price of our ADSs due to circumstances peculiar to the U.S. capital markets could materially and adversely affect the price of the shares, or *vice versa*. Certain events that have significant negative impact specifically on the U.S. capital markets may result in a decline in the trading price of our shares notwithstanding that such event may not impact the trading prices of securities listed on the IDX generally or to the same extent, or *vice versa*.\n\nOur financial results are reported to the OJK in conformity with the Indonesian Financial Accounting Standard (“IFAS”), which differs in certain respects from IFRS, and we distribute dividends based on profit for the year attributable to owners of the parent company and net income per share determined in reliance on IFAS.  \n\nIn accordance with the regulations of the OJK and the IDX, we are required to report our financial results to the OJK in conformity with IFAS. We have provided the OJK with our financial results for the year ended December 31, 2025, on May 12, 2026. We furnished such financial results to the SEC on a Form 6-K dated May 12, 2026, which contains our Consolidated Financial Statements as of and for the year ended December 31, 2025, which were prepared in conformity with IFAS. IFAS differs in certain significant respects from IFRS and, as a result, there are differences between our financial results as reported under IFAS and IFRS, including profit for the year attributable to owners of the parent company and net income per share. We distribute dividends based on profit for the year attributable to owners of the parent company and net income per share determined in reliance on IFAS.\n\nBased on the financial statements prepared in accordance with IFAS, our profit for the year attributable to owners of the parent company amounted to Rp23,186 billion and Rp22,403 billion (as restated) in 2023 and 2024, respectively, and Rp17,814 billion (US$1,068 million) in 2025. Our earnings per share were Rp234.0 and Rp226.1 (as restated) in 2023 and 2024, respectively, and Rp179.8 in 2025. For the fiscal year ended December 31, 2023, dividends declared per share were Rp178.5 and dividends declared per ADS were Rp17,850. For the fiscal year ended December 31, 2024, dividends declared per share were Rp212.47 and dividends declared per ADS were Rp21,247. The dividends for the fiscal year ended December 31, 2025 will be decided at the 2026 AGMS, scheduled for June 8, 2026.\n\nAs a foreign private issuer in the U.S., we are permitted to, and we have relied and will rely on exemptions from certain NYSE corporate governance standards applicable to domestic U.S. issuers. This may afford less protection to holders of our ADSs.\n\nWe are exempted from certain corporate governance requirements of the NYSE by virtue of being a foreign private issuer in the U.S. We are required to provide a brief description of the significant differences between our corporate governance practices and the corporate governance practices required to be followed by domestic U.S. companies listed on the NYSE. See also *“**Item 16D. Exemptions from the Listing Standards for Audit Committees”* and *“Item 16G. Corporate Governance.”* The standards applicable to us are considerably different than the standards applied to domestic U.S. issuers. For instance, we are not required to: have a majority of the board of be independent (although all of the members of the audit committee must be independent under the Exchange Act), have a compensation committee or a nominating or corporate governance committee consisting entirely of independent directors, have regularly scheduled executive sessions for non-management directors, or have executive sessions of solely independent directors each year.\n\nWe have relied on and intend to continue to rely on some of these exemptions. As a result, holders of our ADSs may not be provided with the benefits of certain corporate governance requirements of the NYSE.\n\n57\n\n[Table of Contents](#TOC)\n\nAs a foreign private issuer in the U.S., we are exempt from certain disclosure requirements under the Exchange Act, which may afford less protection to holders of our ADSs than they would enjoy if we were a domestic U.S. company.\n\nAs a foreign private issuer in the U.S., we are exempt from, among other things, the rules prescribing the furnishing and content of proxy statements under the Exchange Act and the rules relating to selective disclosure of material non-public information under Regulation FD under the Exchange Act. In addition, our executive officers, directors and principal shareholders are exempt from the reporting and short-swing profit and recovery provisions contained in Section 16 of the Exchange Act. We are also not required under the Exchange Act to file periodic reports and financial statements with the SEC as frequently or as promptly as domestic U.S. companies with securities registered under the Exchange Act. For example, in addition to annual reports with audited financial statements, domestic U.S. companies are required to file with the SEC quarterly reports that include interim financial statements reviewed by an independent registered public accounting firm and certified by the companies’ principal executive and financial officers. By contrast, as a foreign private issuer, we are not required to file such quarterly reports with the SEC or to provide quarterly certifications by our principal executive and financial officers. As a result, holders of our ADSs may be afforded less protection than they would under the Exchange Act rules applicable to domestic U.S. companies.\n\nThe voting rights of holders of our ADSs are limited by the terms of the Deposit Agreement.\n\nHolders of our ADSs may exercise their voting rights with respect to the ordinary shares underlying their ADSs only in accordance with the provisions of the Deposit Agreement. Upon receipt of voting instructions from them in the manner set forth in the Deposit Agreement, the depositary for our ADSs will endeavor to vote their underlying ordinary shares in accordance with these instructions. Under our Articles of Association, minimum notice periods apply for convening a general meeting or an extraordinary general meeting of shareholders. When such meetings are convened, holders of our ADSs may not receive sufficient notice of a shareholders’ meeting to allow them to exercise their voting rights with respect to any specific matter at the meeting. In addition, the Depositary may not be able to send voting instructions to holders of our ADSs or carry out their voting instructions in a timely manner. Furthermore, the Depositary will not be responsible for any failure to carry out any instructions to vote, for the manner in which any vote is cast or for the effect of any vote. If no voting instructions are received by the Depositary from a holder of our ADSs on or before the date specified by the Depositary, subject to certain exceptions, the Depositary shall deem that such holder has instructed the Depositary to give a discretionary proxy to a person designated by us with respect to the shares underlying such holder’s ADSs. As a result, holders of our ADSs may not be able to exercise their rights to vote and they may lack recourse if the ordinary shares underlying their ADSs are not voted as they requested. \n\nHolders of our ADSs may be subject to limitations on transfer of their ADSs.\n\nADSs are transferable on the books of the Depositary. However, the Depositary may close its transfer books at any time or from time to time when it deems expedient in connection with the performance of its duties. In addition, the Depositary may refuse to deliver, transfer or register transfers of ADSs generally when our books or the transfer books of the Depositary are closed, or at any time if we or the Depositary deems it advisable to do so because of any requirement of law or of any government or governmental body, or under any provision of the Deposit Agreement, or for any other reason.\n\nHolders of our ADSs may not receive distributions on our ordinary shares or any value for them if it is illegal or impractical to make them available to the holders.\n\nThe Depositary of our ADSs has agreed to pay holders of our ADSs the cash dividends or other distributions it receives on our ordinary shares or other deposited securities after deducting its fees and expenses, and subject to certain tax withholdings, as applicable. Holders of our ADSs will receive these distributions in proportion to the number of our ordinary shares that their ADSs represent. However, the Depositary is not responsible for making these payments or distributions if it is unlawful or impractical to make a distribution available to any holders of ADSs. For example, it would be unlawful to make a distribution to a holder of ADSs if it consists of securities that require registration under the U.S. Securities Act but that are not properly registered or distributed pursuant to an applicable exemption from registration. We\n\n58\n\n[Table of Contents](#TOC)\n\nhave no obligation to take any action to permit the distribution of our ADSs, ordinary shares, rights or anything else to holders of our ADSs. This means that holders of our ADSs may not receive the distributions we make on our ordinary shares or any value for them if it is illegal or impractical for us to make them available. These restrictions may materially reduce the value of the ADSs.\n\nHolders of our ADSs may experience dilution of their holdings due to their inability to participate in rights offerings.\n\nWe may, from time to time, distribute rights to our shareholders, including rights to acquire securities. Under the Deposit Agreement, the Depositary will not distribute rights to holders of ADSs unless the distribution and sale of rights and the securities to which these rights relate are either exempt from registration under the Securities Act with respect to all holders of ADSs or are registered under the provisions of the Securities Act. The Depositary may, but is not required to, attempt to sell these undistributed rights to third parties, and may allow the rights to lapse. We may be unable to establish an exemption from registration under the Securities Act, and we are under no obligation to file a registration statement with respect to these rights or underlying securities or to endeavor to have a registration statement declared effective. Accordingly, holders of ADSs may be unable to participate in our rights offerings and may experience dilution of their holdings as a result.\n\nThe time required for the exchange between ADSs and shares might be longer than expected and investors might not be able to settle or effect any sale of their securities during this period.\n\nThere is no direct trading or settlement between the NYSE and the IDX on which our ADSs and the shares are respectively traded. In addition, the time differences between Indonesia and New York and unforeseen market circumstances or other factors may delay the deposit of shares in exchange of ADSs or the withdrawal of shares underlying the ADSs. Investors will be prevented from settling or effecting the sale of their securities during such periods of delay. In addition, any exchange of shares into ADSs (and *vice versa*) may not be completed in accordance with the timeline investors may anticipate.\n\nWe are established in Indonesia and it may not be possible for investors to effect service of process or enforce judgments on us, our Commissioners, Directors or officers within the United States, or to enforce judgments of a foreign court against us or any of these persons in Indonesia.\n\nWe are a state-owned limited liability company established in Indonesia, operating within the framework of Indonesian laws governing companies with limited liability, and all of our significant assets are located, and most of our current operations are conducted, in Indonesia. In addition, all of our current Commissioners and Directors reside in Indonesia, are nationals of countries other than the United States and a substantial portion of the assets of such persons are located outside the United States. As a result, it may be difficult or impossible for investors to effect service of process, or enforce judgments on us or such persons within the United States, or to enforce against us or such persons in the United States, judgments obtained in United States courts.\n\nWe have been advised by our Indonesian legal advisors that Indonesia is not a party to any bilateral or multilateral treaties for the reciprocal recognition and enforcement of foreign court judgment. Therefore, judgments of courts outside Indonesia are neither recognized nor enforceable in Indonesia, although such judgments could be admissible as evidence in a proceeding on the underlying claim in an Indonesian court if the Indonesian court, in its sole discretion, deems it appropriate under the circumstances.\n\nFurthermore, there is uncertainty regarding whether Indonesian courts will render judgments in original actions brought in Indonesian courts based solely upon civil liability provisions within the United States or similar claims in other jurisdictions. In the absence of a direct enforcement mechanism for foreign judgments, parties seeking enforcement in Indonesia would need to retry the case on its merits in Indonesia. The prior foreign judgment would be considered admissible as evidence during the subsequent enforcement proceedings in Indonesia. However, it is important to note that the Indonesian courts retain the discretion to assess the appropriateness of a foreign judgment under the given circumstances.\n\n59\n\n[Table of Contents](#TOC)\n\nThis process essentially requires the successful party in the foreign jurisdiction to initiate a new legal action in Indonesia, presenting their case anew, and relying on the foreign judgment as supporting evidence during the proceedings. There can be no assurance that the claims or remedies available under Indonesian Law will be the same, or as extensive, as those available in other jurisdictions.\n\nAs a result, it may be difficult or impossible for you to bring an action against us or against our Commissioners, Directors, or officers in the United States in the event that you believe that your rights have been infringed under the U.S. federal securities laws or otherwise. Even if you are successful in bringing an action of this kind, under the laws of the Republic of Indonesia you may be unable to enforce a judgment against our assets or the assets of our Commissioners, Directors or officers as claimants would be required to pursue claims against us or such persons in Indonesian courts.\n\n​\n\n​\n\n**ITEM**** ****4.              INFORMATION ON THE COMPANY**\n\n**A.****           ****HISTORY AND DEVELOPMENT OF THE COMPANY**\n\n**Profile of Telkom**\n\n​\n\nTelkom is the largest telecommunications company in Indonesia, in terms of revenue and number of subscribers, as of December 31, 2025. We provide fixed and mobile telecommunications services and solutions and ancillary services. We are innovative and continue to strengthen and optimize our portfolio businesses, services and solutions by creating strategic programs that aim to maximize synergies and active portfolio management. Our existential purpose is to build Indonesia into a more prosperous and competitive nation while delivering the best value to our stakeholders. Our long-term vision is to be the most preferred digital telecommunications company and empower Indonesian society. To achieve this vision, we focus on three missions that cover many aspects of empowering society, including rapidly building sustainable digital infrastructure and smart platforms that are affordable and accessible to a wide range of customers, nurturing best-in-class digital talents to help develop Indonesia’s digital capabilities and increase the adoption of digital technologies and services, and orchestrating a comprehensive digital ecosystem to deliver a superior customer experience.\n\n​\n\nIn order to achieve our vision and missions, we continue to work to transform key aspects of our business: technology, organization, operations, people, and culture.\n\n**Company Name**\n\n**:**\n\nPerusahaan Perseroan (Persero) PT Telekomunikasi Indonesia Tbk\n\n**Abbreviated Name**\n\n**:**\n\nPT Telkom Indonesia (Persero) Tbk\n\n**Commercial Name**\n\n**:**\n\nTelkom\n\n**Line of Business**\n\n**:**\n\nTelecommunications and informatics networks and services\n\n**Tax Identification Number**\n\n**:**\n\n01.000.013.1-093.000\n\n**Business Identification Number**\n\n**:**\n\n9120304490415\n\n**Business License**\n\n**:**\n\n9120304490415\n\n**Domicile**\n\n**:**\n\nBandung, West Java\n\n**Address**\n\n**:**\n\nJl. Japati No. 1, Bandung 40133, Indonesia\n\n**Telephone**\n\n**:**\n\n+62-22-4527117\n\n**Call Center**\n\n**:**\n\n+62-21-147\n\n**Website**\n\n**:**\n\nwww.telkom.co.id\n\nThe information found on our website does not form part of this Form 20-F and is not incorporated by reference herein.\n\n**E-mail**\n\n**:**\n\ncorporate_comm@telkom.co.id; investor@telkom.co.id\n\n**Ratings**\n\n**:**\n\n*International Ratings: “*Baa1 (Stable)” by Moody’s, “BBB (Stable)” by Fitch, “BBB” by MSCI ESG Ratings for 2025, and “Medium Risk” ESG Risk Rating by Sustainalytics, Carbon Disclosure Project (CDP) rating “b” for climate and “c” for Water in 2025 (CDP Supporter for 2025), and “Very\n\n60\n\n[Table of Contents](#TOC)\n\nGood” rating by the Indonesian Institute for Corporate Directorship in the Asean Corporate Governance Scorecard (ACGS) with a 101.98 rating.\n\n*Domestic Rating:* “idAAA” by PT Pemeringkat Efek Indonesia (“Pefindo”) for 2025.\n\n**Date of Legal Establishment**\n\n**:**\n\nNovember 19, 1991\n\n**Legal Basis of Establishment**\n\n**:**\n\nBased on Government Regulation No. 25 of 1991, the status of our Company was converted into a state-owned limited liability corporation (“Persero”), based on the Notarial Deed of Imas Fatimah, S.H. No.128 dated September 24, 1991, as approved by the Ministry of Justice of the Republic of Indonesia by virtue of Decision Letter No. C2-6870.HT.01.01.Th.1991 dated November 19, 1991 and as announced in the State Gazette of the Republic of Indonesia No. 5 dated January 17, 1992, Supplement to the State Gazette No.210\n\n**Ownership**\n\n**:**\n\nAs of December 31, 2025:\n\n–    PT Danantara Asset Management – 52.09%\n\n-\n\nGovernment - 0.00% (one share)\n\n–    Public – 47.91%\n\n**Listing on Stock Exchanges**\n\n**:**\n\nOur shares of common stock were listed on the IDX and the New York Stock Exchange (the “**NYSE”**) on November 14, 1995\n\n**Stock Codes**\n\n**:**\n\n–    \"TLKM\" on the IDX\n\n–    \"TLK\" on the NYSE\n\n**Authorized Capital**\n\n**:**\n\n1 Dwiwarna Share and 389,999,999,999 shares of common stock\n\n**Issued and Fully Paid Capital**\n\n**:**\n\n1 Dwiwarna Share and 99,062,216,599 shares of common stock\n\n**Offices**\n\n**:**\n\n-\n\n1 Head Office\n\n-\n\n5 Telkom Regional Offices and 31 Telecommunications Areas\n\n**Service Centers**\n\n**:**\n\n-\n\n10 Global Offices in Indonesia, Australia, Dubai, Hong Kong, Malaysia, Myanmar, Singapore, Taiwan, Timor-Leste, and the United States, a total of 5 Sales Representatives in Canada, India, the Philippines, Vietnam, and the United Kingdom, and 1 Sales Representative of Telkomsel in Saudi Arabia\n\n-\n\n463 GraPARI centers in Indonesia\n\n**Other Information**\n\n**:**\n\n–  **Registered Public Accounting Firm**\n\nPublic Accounting Firm (**“KAP”**) Purwanto Susanti dan Surja (a member firm of Ernst & Young Global Limited) (PCAOB ID 1381) (“**EY Indonesia**”)\n\nIndonesia Stock Exchange Building, Tower 2, 7th Floor, Jl. Jend. Sudirman Kav. 52–53, Jakarta 12190, Indonesia\n\n​\n\n​\n\n–  **Securities Administration Bureau**\n\nPT Datindo Entrycom\n\nJl. Hayam Wuruk No.28, 2nd Floor, Jakarta 10120, Indonesia\n\n​\n\n​\n\n–  **Trustee**\n\nPT Bank Tabungan Negara (Persero) Tbk.\n\nMenara BTN, 18th Floor, Jl. Gajah Mada No.1, Jakarta 10130, Indonesia\n\nPT Bank Permata Tbk.\n\nGedung WTC II, 28th Floor, Jl. Jend. Sudirman Kav. 29-31, Jakarta 12920, Indonesia\n\n​\n\n​\n\n–  **Custodian**\n\nPT Kustodian Sentral Efek Indonesia\n\nIndonesia Stock Exchange Building, Tower 1, 5th Floor, Jl. Jend. Sudirman Kav. 52–53, Jakarta 12190, Indonesia\n\n​\n\n​\n\n–  **Rating Agencies**\n\n*PT Pemeringkat Efek Indonesia*\n\nPanin Tower Senayan City, 17th Floor, Jl. Asia Afrika Lot. 19, Jakarta 10270\n\n*Moody’s Investors Service Singapore Pte. Ltd.*\n\n61\n\n[Table of Contents](#TOC)\n\n50 Raffles Place #23-06, Singapore Land Tower, Singapore 048623\n\n*Fitch Hong Kong Ltd.*\n\n19/F Man Yee Building, 68 Des Voeux Rd, Hong Kong\n\n*CDP*\n\n127 West 26th Street, Suite 300, New York, NY 10001, United States\n\n*MSCI*\n\n7 World Trade Center 250 Greenwich Street New York, NY 10007, United States\n\n*Sustainalytics*\n\nFour World Trade Center 150, Greenwich Street, Floor 48, New York, NY 10007\n\nIICD\n\nGedung Prof. M. Sadli (Gedung Magister Akuntansi) 1st Floor, Jl. Salemba No. 4 Jakarta Pusat, Indonesia\n\n​\n\n​\n\n–  **A****DR Depositary**\n\n*The Bank of New York Mellon Corporation*\n\n240 Greenwich Street, NY, USA – 10286\n\n​\n\n​\n\n–  **Authorized Agent for Service of Process in the United States**\n\n*Cogency Global Inc.*\n\n122 E. 42nd St. 18th Fl. New York, NY 10168, USA\n\n**Employee Union**\n\n**:**\n\nThe Telkom Employees Union (*Serikat Karyawan Telkom* or “**SEKAR”**)\n\nWe are subject to the periodic reporting and other informational requirements of the Exchange Act as applicable to foreign private issuers. Under the Exchange Act, we are required to file reports and other information with the Securities and Exchange Commission (“**SEC**”). Specifically, we are required to annually file a Form 20-F within four months after the end of each fiscal year. Copies of reports and other information, when so filed with the SEC, can be inspected and copied at the public reference facilities maintained by the SEC at 100 F Street, N.E., Room 1580, Washington, D.C. 20549. You can request copies of these documents, upon payment of a duplicating fee, by writing to the SEC. The public may obtain information regarding the Washington, D.C. Public Reference Room by calling the Commission at 1-800-SEC-0330. SEC maintains a website (http://www.sec.gov), which contains reports, proxy and information statements, and other information regarding us that are filed electronically with the SEC.\n\n**Telkom’s Milestones**\n\nIn 1965, the Government created the first state-owned company specifically focused on telecommunications services as part of a restructuring of the state-owned telecommunications industry in Indonesia.\n\nIn 1974, PN Telekomunikasi became Perusahaan Umum Telekomunikasi Indonesia, which provided domestic and international telecommunications services, and subsequently spun-off PT Industri Telekomunikasi Indonesia, which manufactured telecommunications equipment, into an independent company.\n\nIn 1991, as a result of a transformation into a state-owned limited liability company and rebranding, we became Perusahaan Perseroan (Persero) PT Telekomunikasi Indonesia Tbk.\n\nIn 1995, we and Indosat established Telkomsel. We completed our initial public offering and our shares were listed on the Jakarta Stock Exchange and the Surabaya Stock Exchange (which have since merged to become the IDX). Our shares were also listed on the NYSE and the London Stock Exchange in the form of ADSs, and were publicly offered without listing on the Tokyo Stock Exchange.\n\nIn 1999, we launched the Telkom-1 satellite. We lost contact with this satellite in 2017, one year ahead of its planned decommissioning and replacement by the Telkom Merah Putih satellite which launched in 2018.\n\n62\n\n[Table of Contents](#TOC)\n\nIn 2001, we and Indosat eliminated joint ownership and cross-ownership in certain companies as part of the restructuring of the telecommunications industry in Indonesia and as a result, we also lost our exclusive rights as the sole operator of fixed-line services in Indonesia.\n\nIn 2004, we launched an international direct dialing service for fixed lines with the access code of 007.\n\nIn 2005, we launched the Telkom-2 satellite. This satellite was retired in 2021 when it reached the end of its operational life.\n\nIn 2009, we transformed from an information telecommunications company to a Telecommunications, Information, Media and Edutainment (“**TIME**”) company. We also rebranded, introducing a new corporate logo and the slogan “the world in your hand.”\n\nIn 2011, we launched the Telkom Nusantara Super Highway project to unite the Indonesian archipelago through the deployment of multiple submarine cables. We also launched the True Broadband Access project to provide internet access with a capacity of between 20 Mbps and 100 Mbps to customers throughout Indonesia.\n\nIn 2012, we began installing Wi-Fi access points around Indonesia to create a public wireless network called Indonesia Wi-Fi as part of our “Indonesia Digital Network” program. We also expanded our business portfolio from TIME to TIMES.\n\nIn 2014, we became the first cellular operator in Indonesia to commercially launch 4G/LTE service.\n\nIn 2015, we launched the retail brand “IndiHome,” under which we market fixed voice, fixed broadband, IPTV, and consumer digital services in a bundled package.\n\nIn 2017, we launched the Telkom-3S satellite and commenced operations on schedule.\n\nIn 2018, we launched the Telkom Merah Putih satellite, which began providing coverage for all of Indonesia, Southeast Asia and South Asia. We also inaugurated The Telkom Hub, a smart office complex for developing digital entrepreneurs and fostering a digital culture in line with digital Government initiatives such as “Making Indonesia 4.0,” “2020 Go Digital Vision,” and “One Data Indonesia.”\n\nIn 2019, we reconfigured our business portfolio from TIMES to a five-segment portfolio of mobile, consumer, enterprise, wholesale, international business, and other.\n\nIn 2021, Telkomsel became the first cellular operator to commercially launch 5G service in Indonesia. Telkomsel also refreshed its brand and conducted a product simplification. Mitratel, our subsidiary, conducted an initial public offering in November 2021 which provided Rp18,463 billion in proceeds to be used for organic and inorganic business expansion.\n\nIn 2022, Telkom launched a cable gateway in Manado, the second international communication gateway that we own. We completed the first stage of our HyperScale data center, in Jakarta, and our subsidiary, PT Telkom Data Ekosistem (“**TDE**”), began construction of our second HyperScale data center, in Batam. We also established strategic partnerships with several global technology companies such as Microsoft.\n\nIn April 2023, in line with our FMC initiative, we entered into an agreement with Telkomsel to combine our fixed broadband and mobile broadband services into a single business entity, by transferring a portion of our assets and liabilities allocated to the IndiHome business segment to Telkomsel. See also *“Item 10C. — Material Contracts.”*\n\nIn August 2023, our subsidiary Metranet collaborated with edtech startup PT Cerdas Digital Nusantara (“**Cakap**”) to provide digital educational content, and in October 2023, we completed the construction of our PATARA-2 submarine\n\n63\n\n[Table of Contents](#TOC)\n\ncable system connecting multiple islands across eastern Indonesia. In November 2023, we collaborated with KT Corp, a South Korean telecommunications company, to form a joint task force team to generate a business model for the data centers in Nusantara, Indonesia’s new capital.\n\nIn February 2024, we launched our Merah Putih-2 satellite. In December 2024, Mitratel acquired 100.0% of the shares in PT Ultra Mandiri Telekomunikasi from PT PP Infrastruktur. This acquisition added 12,524 km of fiber optic network, increasing Mitratel's fiber optic network to over 59,486 km and strengthening its fiber-to-the-tower business. Additionally, in 2024, we signed an MoU for the construction of the Indonesia Cable Express (“**ICE**”) Cable System, NDP Batam, CLS Pluit, and Minahasa.\n\nIn October 2025, the first data center building in Batam (BTM-1) reached the topping-off milestone, signifying the completion of the main structural phase of the Hyperscale Data Center development at the Kabil Industrial Estate. In December 2025, we obtained shareholder approval at our Extraordinary General Meeting of Shareholders for the partial spin-off of our wholesale fiber connectivity business and assets to our subsidiary, TIF. This is the first phase of a broader plan to transfer the entire wholesale fiber connectivity business to this subsidiary. See also “*Item 10C. — Material Contracts.*”\n\nFor the years ended December 31, 2023, 2024, and 2025, our consolidated capital expenditures totaled Rp32,858 billion, Rp24,436 billion, and Rp24,577 billion (US$1,474 million), respectively. TelkomGroup’s capital expenditures primarily consisted of expenditures relating to the construction of Telkomsel's BTS infrastructure for 4G and 5G networks, the development of a hyperscale data center in Batam, the expansion of hyperscale data center capacity in Cikarang, the addition of towers and supporting infrastructure capacity, as well as the development of international submarine cable system projects, including the TOPAZ, BIFROST, and SJC2 submarine cables. See also *“Item 5B. Operating and Financial Review and Prospects — Liquidity and Capital Resources — Capital Expenditures”* for more information on our capital expenditures for the year ended December 31, 2025.\n\nB.**BUSINESS OVERVIEW**\n\n**Strategy**\n\nAs the largest telecommunications company in Indonesia in terms of revenue and number of subscribers, our objective is to be the preferred digital telecommunications company in Indonesia, contribute to national development, and deliver value to our stakeholders. Our strategy focuses on developing sustainable and efficient digital infrastructure and smart platforms that are accessible and affordable to a wide range of customers. We also aim to support Indonesia’s digital growth by fostering digital talent through workforce planning, skill development, and strategic partnerships. We expect these efforts to promote the wider adoption of digital technologies across different sectors. In addition, we seek to improve customer experience by building a comprehensive digital ecosystem, which includes offering services such as gaming and IPTV and collaborating with strategic partners to deliver innovative solutions.\n\nWe aim to continue transforming to meet the evolving needs of Indonesian consumers and businesses as Indonesia’s leading digital telecommunications company. Our strategy is anchored in five business pillars: (1) Integrated B2C Services, providing comprehensive consumer connectivity and digital solutions; (2) B2B ICT Services, delivering innovative ICT solutions, including connectivity, IT services, and value-added offerings; (3) Digital Infrastructure, optimizing assets to support connectivity solutions and enable an integrated digital ecosystem; (4) International Business, strengthening global presence by driving focused and strategic regional expansion; and (5) Other (Non-Core) Business, enabling portfolio refocusing and reformatting to maximize enterprise value for our Group. Together, these pillars guide our efforts to drive sustainable growth, unlock stakeholder value, and foster inclusive digitalization across Indonesia.\n\nOur core programs for implementing our strategy are as follows:\n\n●**Execute FMC offerings & Beyond Connectivity services to increase customer productivity, supported by efficient territory management to ensure sales quality in both mobile and fixed markets:** As growth\n\n64\n\n[Table of Contents](#TOC)\n\nopportunities in the core connectivity business become increasingly limited, we intend to expand into Beyond Connectivity businesses as part of our growth strategy. We expect to drive this expansion through the development of FMC offerings and Beyond Connectivity services, with a focus on enhancing customer experience to strengthen customer loyalty and improve customer retention. In parallel, we aim to implement more efficient territory management practices to optimize resource allocation and improve market coverage. Through these initiatives, we expect to improve sales quality in both the mobile and fixed markets, and to strengthen our competitive position and market leadership.\n\n●**Improve B2B competitiveness by strengthening consultative selling and streamlining business processes and technology systems:** To strengthen our competitive position and capture growth opportunities in the B2B market, we intend to enhance our overall business competitiveness. We expect these enhancements to be driven by strengthening our consultative selling capabilities to better understand customers’ business needs and address their challenges through end-to-end solutions, supported by a competitive B2B product and service portfolio. Simultaneously, we aim to accelerate the implementation of more efficient business processes and ensure the readiness of integrated IT tools. Through these initiatives, we expect to drive comprehensive B2B performance across our Group, particularly by improving financial visibility.\n\n●**Improve network efficiency and asset utilization, and strengthen Group-wide capital expenditure and procurement coordination to increase profitability****:** We believe our competitiveness is fundamentally driven by the efficiency, reliability, and quality of the infrastructure that underpins our businesses. Accordingly, we are focused on operating and managing our infrastructure in a cost-efficient and competitive manner through cost-leadership initiatives, higher asset utilization, and continuous improvements in infrastructure quality. In addition, we intend to manage capital expenditures more effectively and efficiently by strengthening collaboration in capital expenditure planning and aligning procurement processes across our Group. Through these initiatives, we expect to enhance our competitiveness and drive improvements in our overall profitability.\n\nIn 2025, we launched our “TLKM 30 Strategy,” a long-term transformation strategy aimed at repositioning Telkom as a strategic holding company that evolves into a more focused, agile, and globally competitive digital telecommunications company. As the foundation of this transformation, we established four key transformation pillars designed to strengthen operational and service excellence, streamline our business portfolio, unlock value from infrastructure assets, and support Telkom’s transition into a strategic holding company. Through this framework, we aim to enhance execution discipline, organizational clarity, governance alignment, operational effectiveness, customer experience, and long-term value creation across the TelkomGroup. We are implementing this strategy progressively in line with a defined strategic roadmap. During 2025, our priorities included strengthening business fundamentals through transition toward a strategic holding structure, sharpening the business focus of each Group operating company, accelerating the monetization of high-value infrastructure assets, and enhancing organizational and technological capabilities.\n\nFurther Development of 5G Services\n\nIn 2021, our majority-owned subsidiary, Telkomsel, became the first cellular operator to offer 5G services in Indonesia. Since then, we have strategically focused on expanding our 5G network, with deployment paced by factors such as ecosystem maturity, demand in B2B and B2C segments, and the availability of additional 5G spectrum.\n\nOur 5G development aims to support Indonesia’s broader digital ecosystem goals by integrating emerging technologies and scalable infrastructure. To achieve this, we are implementing end-to-end network automation and transitioning to autonomous networks to improve operational efficiency and deliver next-generation services.\n\nWe are expanding our 5G network through the Hyper 5G initiative in a focused and gradual manner. Since its commercial launch, Telkomsel’s Hyper 5G network has expanded to approximately 4,900 BTS covering more than 80\n\n65\n\n[Table of Contents](#TOC)\n\ncities and regencies. As of December 31, 2025, Telkomsel provides 5G services in locations including Bandung, Surabaya, and Batam. In December 2024, Telkomsel completed the expansion of its Hyper 5G network in the Greater Jakarta area. In the near future, Telkomsel plans to further extend its 5G network to other key locations across Indonesia.\n\nStrategic Partnerships\n\nIn 2025, we executed several key strategic partnerships to strengthen national digital infrastructure and expand our advanced technology capabilities and digital service offerings.\n\nA notable example is our collaboration with Fortinet in November 2025, which focuses on improving network security and SD-WAN services to support the growing demand for secure and reliable enterprise connectivity. In June 2025, we partnered with IBM to deliver a domestically operated sovereign AI platform powered by watsonx. We believe that these partnerships demonstrate our long-term strategy of leveraging global technology expertise combined with local market insight to expand digital services and create sustainable value for customers and Indonesia's digital ecosystem.\n\nThrough our subsidiary MDMedia, we have partnered with Accenture to develop AdXelerate, an AI-driven programmatic advertising platform. AdXelerate leverages Telkomsel's data insights to deliver more efficient, relevant, and targeted digital advertising solutions for advertisers. We believe that this collaboration strengthens our position in Indonesia's digital advertising ecosystem and accelerates the adoption of AI-based solutions for data-driven media advertising.\n\nIn 2025, Telkomsat partnered with Space42 to explore direct-to-device satellite connectivity and with Myriota to deliver low-power satellite IoT services in Indonesia. These collaborations strengthen Telkomsat's capabilities in expanding coverage, enabling new digital use cases, and enhancing satellite-based connectivity across remote and underserved areas. In May 2024, Telkomsat became an authorized Starlink reseller in Indonesia, having previously collaborated with SpaceX's Starlink to provide backhaul services.\n\nWe also reinforce our digital services ecosystem through strategic investments, including Telkomsel's investment in PT GoTo Gojek Tokopedia Tbk (“**GoTo**”). In November 2023, we partnered with KT Corp. to develop a sustainable smart city model for Nusantara, Indonesia's new planned capital.\n\nEnhancing our Assets through Acquisitions and Spin-offs\n\nIn April 2023, as part of the FMC initiative, we entered into an agreement with Telkomsel for the IndiHome Integration. As of the date hereof, we have realized synergies from this integration in areas including content optimization, cross-selling, and cost savings.\n\nIn our tower business portfolio, Mitratel has expanded its fiber optic and tower portfolio through various acquisitions. These acquisitions are expected to improve asset utilization and enhance Mitratel’s infrastructure portfolio value.\n\nEnvironmental, Social, and Governance (“ESG”) Matters\n\nOur sustainability strategy is guided by ESG principles. We focus on responsible business practices through three pillars: Save Our Planet, Empower Our People, and Elevate Our Business. We believe this approach enhances our competitiveness, strengthens stakeholder trust, and supports our long-term sustainability. Our oversight of environmental and social matters is centralized under the head of each relevant business unit, promoting clear accountability, consistent governance, and effective execution.\n\n​\n\n66\n\n[Table of Contents](#TOC)\n\nEnvironmental Stewardship\n\nOur strategy focuses on managing our environmental impact, with a focus on climate-related risks and waste management.\n\n**Climate Transition Pathway** \n\nWe established a Climate Transition Pathway that serves as a long-term strategic roadmap toward achieving Net Zero Emissions by 2060. It is guided by six strategic decarbonization levers: energy efficiency, equipment modernization, operational electrification, renewable energy adoption, and market-based mechanisms, including renewable energy certificates (“**RECs**”), power purchase agreements (“**PPAs**”), and carbon offsets. \n\nThe pathway is structured across three phases: \n\n●**Short-term (2023–2030):** We are targeting up to a 20% reduction in Scope 1 and Scope 2 emissions through energy efficiency improvements, network modernization, and initial solar photovoltaic (“PV”) deployment of more than 14 megawatts peak (“**MWp**”). \n\n●**Medium-term (2030–2050):** We aim to expand emissions reductions to between 40% and 70%, supported by electrification of our operational fleet, increased renewable energy use in our data centers, and continued efficiency improvements. \n\n●**Long-term (2050–2060):** We aim to achieve net zero emissions by minimizing residual emissions and offsetting them through verified carbon credits and nature-based solutions. \n\nWe believe this approach strengthens our resilience to climate-related risks, drives operational efficiency, and creates long-term sustainable value.\n\n**Energy and Emissions** \n\nWe continue to implement initiatives to reduce energy consumption. Our practices include using LED lighting, optimizing cooling systems, and replacing older network equipment with more energy-efficient alternatives. We also continue to assess the feasibility of installing rooftop solar panels. In 2025, we purchased 35,066 RECs to support the operations of 69 main PoPs across various regions of Indonesia. In addition, we calculated our Scope 3 GHG emissions across 12 categories, and our GHG emissions inventory was independently verified by TUV Rheinland Indonesia in April 2026.\n\n**Waste Management **\n\nWe manage waste responsibly, including electronic waste, and reduce paper use through digitalization, such as by providing paperless invoices and encouraging the use of online communication. These efforts are reinforced by the ISO 14001:2015 and ISO 45001:2018 certifications we obtained in 2025. During the same year, we reduced operational waste by 7,013 tons compared to 2024 (or 24% decrease), primarily as a result of decreased office and fiber optic cable waste. \n\n**Water and Biodiversity**\n\nOur water-saving initiatives include using automatic taps and recycling wastewater from our cooling systems for other uses. To support local ecosystems, we conduct mangrove planting and coral reef transplantation. In 2025, we planted 110,042 mangrove trees and transplanted 760 coral reefs.\n\n​\n\n67\n\n[Table of Contents](#TOC)\n\nSocial Responsibility\n\nWe focus on empowering our employees, customers, and society. Our goal is to provide a safe and productive workplace and use our digital capabilities to positively impact society.\n\nOur key human capital initiatives include:\n\n●**Workplace Environment and Employee Support**: Throughout 2025, we continued to strengthen our commitment to diversity, equality, and inclusion. In 2025, women represented 23.2% of managerial positions in our Group, supported by our DayCare facilities and the Srikandi Telkom program to promote gender inclusion. This commitment is reinforced through our Respectful Workplace Policy, which provides a structured approach to preventing, addressing, and reporting discrimination, violence, and harassment. In 2025, we also introduced our Digital Ways of Work: BISA (an acronym for Bravery, Integrity, Service Excellence, and Agility) as a behavioral framework to strengthen a digital mindset and support our ongoing streamlining and transformation initiatives.\n\n●**Talent Development**: Our Digital Talent program provides training and upskilling opportunities for our employees. In 2025, 20.2% of our digital workforce received training through this program.\n\n●**Workplace Safety**: We prioritize workplace safety in a manner that aligns with the ISO 45001:2018 Occupational Safety and Health Management System standard. In 2025, we recorded one work-related fatality.\n\nCorporate Governance\n\nWe believe that strong governance is fundamental to our business, and that it strengthens trust and supports long-term value creation. \n\n●**Ethical****Business Practice**: Anchored in the principles of transparency, accountability, and compliance, we implemented our business transformation agenda in 2025 to strengthen alignment with our Governance, Risk, and Compliance (“GRC”) framework. We also aimed to maintain ISO 37001:2016 Anti-Bribery Management System certification across our operations, including our subsidiaries. In line with our commitment to transparency and accountability, in 2025, all whistleblowing reports received through our reporting channels were reviewed and addressed in accordance with applicable procedures. \n\n●**Cyber and Data Privacy***:* Throughout 2025, we maintained robust data security controls, which resulted in no critical data breaches and ensured that all data processing activities were conducted securely.\n\n**Business Portfolios**\n\nOur business portfolios are organized by business lines that are categorized into five business pillars:\n\n·\n\n**Integrated B2C Services:**We provide comprehensive consumer connectivity and digital solutions. Our B2C services consist of (i) B2C Legacy, which comprises mobile voice, mobile SMS, and fixed voice services; (ii) B2C Data, which comprises mobile broadband and fixed broadband services; and (iii) B2C Digital Services, which comprises mobile digital services (e.g., music, gaming, digital ads) and fixed digital services, including IPTV;\n\n·\n\n**B2B ICT Services**: We deliver digital and ICT solutions to enterprise customers, including enterprise-grade connectivity, IT services, cloud services, cybersecurity, and other value-added offerings;\n\n68\n\n[Table of Contents](#TOC)\n\n·\n\n**Digital Infrastructure:**We optimize our infrastructure assets to support connectivity solutions and enable an integrated digital ecosystem. Our digital infrastructure segment includes wholesale domestic telecommunications network, wholesale FTTx, telecommunications tower operations, satellite services, data centers;\n\n·\n\n**International Business**: We strengthen our global presence by driving focused and strategic regional expansion. International business includes wholesale international telecommunications network and traffic services, wholesale international platform and services, and potential international play (data center, tower, and B2B ICT); and\n\n·\n\n**Other (Non-Core) Business**: This segment is designed to enable portfolio refocusing and reformatting to create focused businesses that aligned with our Core Businesses.\n\nHistorically, the Integrated B2C Services segment has generated the largest share of our total revenue and our business has not experienced significant seasonality.\n\nThe following is a brief overview of our product portfolios:\n\n1. Integrated B2C Services\n\nWe provide comprehensive consumer connectivity and digital solutions. Our B2C services consist of (i) mobile services, including mobile broadband, mobile digital, and legacy mobile services; and (ii) fixed services, including fixed broadband, fixed voice, and fixed digital services, including Internet Protocol Television (\"**IPTV**\").\n\n1.1 Mobile Services\n\nOur mobile services portfolio comprises legacy services such as voice and SMS, alongside digital products such as data and value-added services, provided through Telkomsel, our majority-owned subsidiary. In 2025, mobile services, particularly digital business revenue, which amounted to 92.0% of Telkomsel's total revenues, remained the principal driver of our revenue.\n\nTelkomsel's prepaid mobile services, branded as “SIMPATI” (relaunched in mid-2025) and “by.U” (introduced in 2019), accounted for approximately 95.0% of the total number of cellular subscribers as of December 31, 2025. Telkomsel's postpaid mobile services, branded as “Telkomsel Halo,” represented approximately 5.0% of the total number of cellular subscribers as of the same date. The total number of cellular subscribers decreased by 3.3 million subscribers from 159.4 million (comprising 151.4 million prepaid and 8.0 million postpaid subscribers) to 156.1 million (comprising 147.6 million prepaid and 8.4 million postpaid subscribers) as of December 31, 2025.\n\nThe decrease in our subscriber base is attributed to industry-wide adjustments going beyond an exclusive focus on price rationalization and aiming to remedy market disfunctions in the Indonesian telecommunications sector. In response, our strategies aimed at catering to market demand and addressing affordability concerns, while focusing on enhancing customer productivity through a wide variety of products and services, including digital offerings. Telkomsel's annual average revenue per user (\"ARPU\") decreased by 3.1% from 2024 to 2025, reflecting, among other things, the continued downward trend in legacy services and macroeconomic pressures on consumer purchasing power. Telkomsel recorded a 3.6% quarter-on-quarter increase in ARPU in the fourth quarter of 2025. This increase was attributable to the implementation of disciplined pricing strategies, sustained efforts to remain relevant amid shifting customer usage behavior, and continued industry adjustments, with the ARPU uplift signaling the early positive impact of a more rational and sustainable industry pricing environment. To maintain ARPU stability and support long-term growth amid challenging macroeconomic conditions and market competition, Telkomsel continues to expand its digital product portfolio, optimize customer value management (“**CVM**”) initiatives, implement the right pricing, deliver segmented offers, and unlock cross-selling opportunities, including leveraging fixed-mobile convergence (“**FMC**”) offerings to enhance customer productivity and strengthen ARPU resilience over time.\n\n69\n\n[Table of Contents](#TOC)\n\nOur mobile broadband services are supported by 5G, 4G, and 2G technology. Despite macroeconomic challenges, we have observed positive indicators of usage and productivity, driven primarily by increased data consumption. This is reflected in a year-on-year increase of 15.0% in data traffic, from 19,909 petabytes as of December 31, 2024 to 22,895 petabytes as of December 31, 2025. In 2025, Telkomsel continued to support and incentivize healthier market behavior aimed at strengthening business profitability and industry rationalization through selected price adjustments. Major competitors also implemented price rationalization initiatives in 2025.\n\nTelkomsel officially launched 5G services in May 2021, becoming the first cellular operator to offer 5G in Indonesia. As of 2025, Telkomsel has made 5G available by deploying 4,913 base transceiver stations (“**BTS**”) at selected locations in more than 80 cities and regencies in Indonesia, as part of its strategy to roll out 5G through a demand-based approach for B2C and B2B segments, including in the manufacturing, infrastructure, and education sectors. We intend to maximize the use of 5G and highlight the advantages of the 5G network to further encourage the growth of digital connectivity, digital platforms, and digital services in Indonesia, as well as the development of future technology solutions such as AI, cloud computing, and IoT. The deployment of 5G services will be gradual, based on assessable demand and ecosystem readiness, and will be conducted with our partners.\n\nIn addition to our digital connectivity business, we have established several digital service offerings within our mobile services with a specific focus on financial services, video on demand, music, gaming, advertising, and IoT. We offer on-demand video content through the MAXstream application, a platform that collaborates with partners to co-produce content with studios. We provide music and gaming services that offer a mobile entertainment experience by targeting various consumer segments and leveraging Telkomsel's billing system, including the Langit Musik music application and Dunia Games, which provides a comprehensive gaming ecosystem combining media content, distribution, payment facilities, e-sports, and gaming communities to enhance customer experience.\n\nOur mobile services segment previously comprised a financial payment platform, T-Cash, which pioneered digital payments when it was introduced in 2007 by Telkomsel. In 2019, T-Cash became LinkAja under Finarya. As of the date hereof, Telkomsel owns a 24.8% equity interest in Finarya. At its establishment, Finarya was formed through collaboration among several Indonesian SOEs across multiple sectors, including state-owned banks in the Himbara group (Bank Mandiri, BRI and BNI), infrastructure operators (Jasa Marga and Kereta Commuter Indonesia), oil and gas (Pertamina), and other financial services entities (IFG Life, Taspen, and Danareksa Capital). As its business continues to evolve, LinkAja has expanded its service ecosystem across various digital platforms, including MyTelkomsel and other strategic partners, through services such as account linking, payment balance, and the provision of digital products. In addition, LinkAja has strengthened its presence in the advertising business by developing advertising solutions that support the business growth of its partners.\n\nFollowing Telkomsel's investment in GoTo in November 2020 and May 2021, the two companies have deepened their strategic partnership with the shared objectives of accelerating MSME digitization and enhancing the digital experience for users, drivers, and merchants across Indonesia. Their collaboration encompasses co-created connectivity packages, advertising solutions, and co-branding initiatives designed to expand market reach and deliver value to both customer bases. Telkomsel’s connectivity packages are specifically designed to enhance Gojek driver productivity through tailored telco features and digital solutions. Telkomsel has also expanded its presence within GoTo's ecosystem by onboarding GoTo partners as Telkomsel product resellers, integrating MyTelkomsel with GoPay, and introducing connectivity privacy and security enhancements, including number-masking services. In addition, Telkomsel works with GoTo to deepen insights into customer behavior and consumption patterns to enable continuous refinement of our product and service offerings. Looking ahead, we plan to broaden this strategic partnership by driving digital initiatives that support innovation and customer-centric growth.\n\n1.2 Fixed Services\n\nOur fixed services portfolio comprises fixed voice, fixed broadband, IPTV, and consumer digital services, marketed under the retail brand “IndiHome,” which allows customers to choose one or more such services in a bundled package.\n\n70\n\n[Table of Contents](#TOC)\n\nIn April 2023, in line with our FMC initiative, we entered into an agreement with Telkomsel to integrate our fixed broadband and mobile broadband services into a single business entity via the IndiHome Integration, in order to create new synergies and improve our product and service offerings, customer experience, cost efficiency, and revenue. As part of the implementation of our FMC initiative, Telkomsel also launched “Telkomsel One” in July 2023, a product designed to encourage more equitable distribution of digital connectivity through a wide selection of customer-centric packages and a multi-screen approach for content optimization.\n\nThe IndiHome Integration aims to enhance customer engagement through cross-selling, integrated content delivery, and unified customer touchpoints, while driving operational and cost efficiencies, improving customer experience, and fostering synergies to deliver more competitive product offerings. As of the date hereof, we have realized synergies from content optimization, cross-selling, service integration, cost savings in CPE acquisition, and the streamlining of overlapping customer touchpoints across approximately 300 outlets.\n\nTelkomsel aims to accelerate fixed broadband penetration by targeting diverse customer segments with a targeted pricing strategy. This includes the launch of EZnet in 2024, which complements existing offerings to maintain competitiveness, capture new opportunities, and address affordability in mass-market segments within targeted customer groups and areas, while accelerating healthy growth in the fixed broadband customer base through higher-speed entry-level packages supported by improved network reliability. Concurrently, Telkomsel is enhancing its service offerings, aiming to maintain its standards to meet demand for reliable high-speed broadband by increasing customer productivity through more attractive digital products that elevate user experience, and delivering better-suited convergent offerings to enrich digital lifestyles, deepen customer engagement, and elevate perceived value across segments, including bundles with OTT and gaming platforms. In 2025, the number of IndiHome B2C subscribers increased by 7.4% while ARPU decreased, reflecting a shift in customer consumption patterns from triple-play (3P) to single-play (1P) services, in line with declining demand for fixed voice and IPTV services and a growing preference for internet-only offerings. This adjustment is aligned with IndiHome’s efforts to broaden fixed broadband penetration by expanding into entry-level segments, while maintaining a focus on building a healthy and sustainable customer base.\n\nTelkomsel also offers the wifi.id service to IndiHome customers, which is an add-on service that allows IndiHome customers to enjoy unlimited internet access at all wifi.id access points in Indonesia. Wifi.id (Indonesia Wi-Fi) is our wireless public internet network that provides public access to high-speed internet services and various other multimedia services.\n\n2. B2B ICT Services\n\nWe deliver digital and ICT solutions to enterprise customers, including enterprise-grade connectivity, IT services, cloud services, cybersecurity, and other value-added offerings.\n\nOur enterprise segment comprises primarily ICT and platform services that cover enterprise-grade connectivity services, satellite services, data center and cloud services, digital IT services, business process outsourcing, devices, and digital adjacent services.\n\nFor enterprise connectivity, we offer fixed broadband, Wi-Fi, ethernet, and data communication services, including a software-defined wide area network (“**SD-WAN**”) ecosystem that enables higher performance of wide area networks (“**WANs**”), leased channels such as Metro Ethernet, VPN-IP, high-capacity data network solutions providing point-to-point connections with high-capacity bandwidth, and fixed voice services, among others. We also provide satellite services as part of our enterprise connectivity product offering in certain segments, such as aviation, maritime, mining, and plantation, as well as other satellite-based services for domestic and international users.\n\nIn 2020, we launched FLOU Cloud to foster digital growth for Indonesian startups, small and medium enterprises (“**SMEs**”), large corporations, and Government entities by offering services such as cloud computing, data storage, networking, and data security. In 2022, Telkom Sigma upgraded FLOU Cloud's capabilities and performance to increase our market presence and strengthen data security. We have also obtained ISO 27001 certification in recognition of our\n\n71\n\n[Table of Contents](#TOC)\n\ndedication to data security, and have implemented Cloud Security Alliance Security, Trust, and Assurance Registry (“**STAR”**) measures. In partnership with major cloud service providers, we primarily target Indonesian customers in sectors we expect to grow, such as finance, manufacturing, Government, and communications, to whom we offer professional cloud management and consultancy services.\n\nOur connectivity services support critical functions across various industries. Our ICT and industry solutions function as horizontal platforms encompassing IoT, data centers, cloud services, big data, cybersecurity, and payment systems. Our platforms aim to facilitate innovation by providing state-of-the-art solutions for our customers' applications, digital marketing, finance, E-health, and entertainment, among others. We assist our customers with customer relationship management and IoT deployments, including setting up smart buildings for purposes of energy management and fleet management, backed by consolidated communication systems and enhanced IT security. Our digital and IT services capabilities enhance our E-health offerings, for example by simplifying healthcare claims processing.\n\nIn 2025, we focused on our ICT business, delivering specialized solutions for Government entities and the logistics, healthcare, education, financial, insurance, agriculture, and mining industries.\n\n3. Digital Infrastructure\n\nWe optimize our infrastructure assets to support connectivity solutions and enable an integrated digital ecosystem. Our digital infrastructure segment includes wholesale telecommunications network and traffic services, international business, wholesale platform and services, telecommunications tower operations, satellite services, data centers, and infrastructure and network management services.\n\n*3.1 Wholesale Network and Traffic Services*\n\nOur domestic and international wholesale traffic, wholesale network, and wholesale digital platform and services offerings comprise network services, data and internet services, interconnection services, value-added services, voice hubbing, application-to-person (“**A2P**”) SMS, and platforms and solutions. We earn revenue principally from interconnection services that we provide to other telecommunications operators that utilize our network and infrastructure in Indonesia, both for calls that terminate at and calls that transit via our network. Similarly, we also pay interconnection fees to other telecommunications operators when we use their networks to connect calls from our customers. Interconnection services that we provide to other telecommunications operators comprise domestic and international interconnection services.\n\nWe expect the continued deployment of 5G technology to provide additional growth opportunities to our wholesale segment. The deployment of 5G technology in Indonesia is subject to various factors and conditions, but we intend to become a leader in providing cost-efficient and phased 5G-related wholesale services in Indonesia.\n\n*3.2 Telecommunications Tower Business*\n\nWith respect to our telecommunications tower business, we lease space to other operators to place their telecommunications equipment on our towers, for which we receive a fee. As of December 31, 2025, we had approximately 44,702 towers, comprising approximately 40,230 towers owned by Mitratel and approximately 4,472 towers owned by Telkomsel.\n\nWe aim to continue to expand our telecommunications tower business, which we believe is a strategic business in the telecommunications industry, and we intend to increase our tower rental revenues. We also seek to improve our operation and maintenance efficiency by digitalizing our internal business processes.\n\n*3.3 Infrastructure and Network Management Services*\n\n72\n\n[Table of Contents](#TOC)\n\nTelin is a significant digital infrastructure provider in the Asia-Pacific (“**APAC**”) region, focused primarily on its submarine cable business. Through an extensive portfolio of international submarine cable systems and strategic landing points, Telin delivers high-capacity, low-latency connectivity linking key markets across Southeast Asia, Australia, East Asia, and beyond. Building on this core infrastructure, Telin offers a suite of derivative services including IPLC, Ethernet, IP Transit, and scalable cross-border connectivity solutions tailored for hyperscalers, OTT players, enterprises, and wholesale carriers. Telin continues to expand its submarine cable network and increase capacity utilization to meet growing demand for digital connectivity across the APAC region.\n\nWe provide managed infrastructure and network services by performing network construction and maintenance, including laying and maintaining submarine cables, and energy solutions for telecommunications infrastructure ecosystems. We accomplish this by leveraging existing businesses in our portfolio and developing in-house capabilities and innovative solutions. As part of our infrastructure portfolio, we provide energy management solutions supporting telecommunications infrastructure.\n\nIn 2023, we completed construction of our PATARA 2 submarine cable system connecting multiple islands across Indonesia, enhancing connectivity among the cities of Waisai, Manokwari, and Supiori. We plan to add additional landing points for redundancy and further deploy submarine cables in the future.\n\n*3.4 Satellite Services*\n\nTelkomsat provides satellite-based connectivity services to enterprise customers in segments such as aviation, maritime, mining, and plantation, as well as other satellite-based services for domestic and international users, while continuing its presence and support in cellular backhaul and Government services. In October 2025, Telkomsat and Myriota entered into a memorandum of understanding to collaborate on the development of satellite-based IoT services and to explore business and market opportunities in the IoT sector, including market analysis, business model development, and partnership strategy. In November 2025, Telkomsat entered into a partnership with Space42 to explore the use of Space42's Equatys platform to enable Direct-to-Device (“**D2D**”) satellite communication services to customers globally, and to assess the potential utilization of Telkomsat's satellite infrastructure and facilities in connection with that platform.\n\nWe believe that these collaborations strengthen Telkomsat's capabilities in expanding coverage, enabling new digital use cases, and enhancing satellite-based connectivity across remote and underserved areas. In May 2024, Telkomsat became an authorized Starlink reseller in Indonesia, having previously collaborated with SpaceX's Starlink to provide backhaul services.\n\n*3.5 Data Centers*\n\nSince 2021, we have consolidated and expanded our data center capabilities, including cloud services and marketplace services, under our subsidiary PT Telkom Data Ekosistem (“**NeutraDC**”). We transferred our then-under-construction Cikarang HyperScale data center to NeutraDC in 2021 and transferred our enterprise data center business in Sentul, Serpong, and Surabaya from Telkom Sigma in 2022. NeutraDC continues to expand the capacity of our HyperScale data center in Cikarang and has begun building a second HyperScale data center in Batam. In 2025, we signed a contract with PLN Batam to secure electrical support with a total capacity of 90 MVA for the Batam data center, and we are exploring renewable energy initiatives in collaboration with PLN Batam. In October 2025, the first data center building in Batam (BTM-1) reached the topping-off milestone, signifying the completion of the main structural phase of the HyperScale Data Center development at the Kabil Industrial Estate. The first campus of the NeutraDC Batam project is a three-campus development and became operational in 2026. This development aims to support digital transformation and economic development in Indonesia, particularly in Batam and the surrounding region, addressing demand from Singapore.\n\nIn 2024, we further expanded our neuCentrIX data center capacity and services through the deployment of three new neuCentrIX data centers. We also integrated our international data centers by transferring Telin Singapore's data center business to NeutraDC Singapore. As of the date hereof, we are continuing to build new neuCentrIX data centers in\n\n73\n\n[Table of Contents](#TOC)\n\nIndonesia that will provide carrier-neutral connectivity and custom-made services for enterprise clients throughout the Asia Pacific region. NeutraDC continues to explore data center expansion options at the regional level.\n\nTo support this expanding infrastructure, NeutraDC has entered into a range of strategic partnerships. In 2025, NeutraDC entered into a strategic partnership with Sembcorp Development Ltd. to develop low-carbon data centers across Southeast Asia, alongside ongoing collaborations with NAVER Cloud and Cisco to support cloud adoption and enterprise digital services. NeutraDC has also entered into agreements with Advanced Micro Devices and Cirrascale Cloud Services in 2024 to deliver accelerator infrastructure and GPU-as-a-Service capabilities for regional customers, including those operating in Singapore. NeutraDC has further partnered with DataCanvas for automated AI model development workflows, established cross-border GPU connectivity with the Ishikari Renewable Energy Data Center No. 1 in January 2026, and developed agentic AI framework capabilities in collaboration with Lynx Analytics in 2025. NeutraDC also uses application security and delivery technologies from F5, Inc. to support its multi-cloud infrastructure platform across Asia Pacific.\n\nAt NeutraDC Summit 2025, held in August 2025, NeutraDC introduced two new solutions built on this partnership ecosystem: Neutra Compute and Neutra Connect. Neutra Compute is a GPU-as-a-Service platform that allows enterprises to access high-performance AI computing resources without significant upfront capital investment. Neutra Connect is a data center interconnection service designed to provide faster and more reliable connectivity for enterprise customers. Together, these solutions are designed to address growing demand for AI and digital infrastructure across the region.\n\n4. International Business\n\nOur subsidiary, Telin, continues to reinforce its international business primarily through the expansion of its global subsea cable footprint, which serves as the backbone of Telin's digital infrastructure strategy. Telin is actively progressing the deployment of major international cable systems, including Bifrost, SJC2, and SEAMEWE 6, while advancing the ICE initiative, a multi-route program aimed at delivering low-latency, direct data center–to–data center connectivity across key regional corridors. Telin also aims to strengthen its network resilience by securing additional capacity on systems such as PEACE, TOPAZ, and the SEAUS East Segment, supporting global traffic flows across Asia, the Pacific, and intercontinental routes.\n\nComplementing its subsea investments, Telin continues to enhance its digital platform ecosystem. NeuAPIX, Telin's cloud-based Communications Platform as a Service (“**CPaaS**”), enables enterprises of all sizes to integrate omni-channel communication capabilities, including messaging, chatbots, voice, video, and WhatsApp Business API, into their operations. NeuTrafiX, Telin's digital marketplace, facilitates automated wholesale trading of global voice and mobility services. TNeX, Telin's next-generation digital connectivity platform, allows enterprises and hyperscalers to procure and monitor connectivity across more than 120 data centers in over 50 countries. In 2024, Telin expanded its CPaaS offering through the launch of WABA for Business in partnership with Meta, strengthening its position in over-the-top (“**OTT**”)-based communication services for wholesale and enterprise customers.\n\nTelin's platform and service capabilities are supported by its global infrastructure, which includes 58 international Points of Presence and data center operations in Hong Kong and Timor-Leste, along with continued service presence in Singapore following the divestment of the Telin-3 Data Center in 2024. These assets collectively enable Telin to deliver integrated, high-capacity connectivity services built upon its expanding subsea cable network.\n\nAs part of its transformation into One Telin in 2022, Telin has integrated and centralized its global operating model to deliver unified customer experiences worldwide. Although managed under a single global framework, Telin maintains operational presence in multiple jurisdictions through a combination of legal entities, branch offices, and sales representatives, enabling the delivery of international telecommunications, digital platform, and data connectivity services across key regions.\n\n74\n\n[Table of Contents](#TOC)\n\nTelin operates in several countries through formal legal entities, including Telin Singapore, Telin Hong Kong, Telin Australia, Telin Malaysia, Telin USA, Telin Taiwan, and Telkomcel in Timor-Leste, where it provides a mix of services such as international data connectivity, cloud and IP transit services, wholesale voice and mobility services, enterprise solutions, mobile services (including as an **MNO** and **MVNO**), and data center operations. In 2024, the Telin-3 Data Center in Singapore was divested, but Telin continues to serve the Singapore market through its integrated international infrastructure and platforms.\n\nAs of the date hereof, Telin also maintains branch offices in Myanmar and Dubai, supporting data connectivity, wholesale voice, enterprise solutions, and regional customer engagement. In addition, Telin extends its commercial reach through sales representatives located in the United Kingdom, the Philippines, Vietnam, Canada, and India, enabling Telin to engage customers and partners across Europe, South Asia, and Southeast Asia. Together, these international touchpoints allow Telin to operate as a unified global organization while sustaining local presence in strategic markets.\n\n5. Other (Non-Core) Business\n\nOur digital services portfolio primarily comprises media and edutainment services targeted to digital consumers, organized into smart platforms, digital content, and e-commerce.\n\n*5.1 Digital Services*\n\nOur digital services portfolio primarily comprises media and edutainment services targeted to digital consumers. Our digital portfolio is clustered into a smart platform and provides access to digital content and e-commerce. We manage our venture capital activities through our subsidiary, PT Metra Digital Investama Ventura (“**MDI Ventures**”), which serves as our corporate venture capital arm. MDI Ventures operates a multi-fund investment platform focused on technology-driven startups from early to growth stages, both in Indonesia and internationally, with the objective of delivering financial returns and strategic value for us. These investment activities are aligned with our long-term digital ecosystem strategy and are conducted under our governance framework, which includes defined investment processes, clear accountability, and oversight consistent with our Good Corporate Governance (“**GCG**”) principles.\n\nConsistent with our corporate strategy, our digital segment focuses on innovation through the development of digital products that support our B2B ICT solutions and the transformation of public services, including through engagement with Government mandates and Danantara. To drive AI-based innovation across our Group, we have established an AI Centre of Excellence (\"**AI CoE**\") as a strategic platform to orchestrate and accelerate the adoption of artificial intelligence across TelkomGroup. The AI CoE is intended to provide a more integrated approach to AI implementation by aligning initiatives across business units, strengthening talent development, facilitating ecosystem collaboration, and supporting the prioritization of use cases with clear relevance to business needs. Through this approach, the AI CoE is expected to enhance our Group’s ability to capture value from AI adoption while promoting a more structured, focused, and coordinated implementation model across the organization.\n\nThe AI CoE is implemented through five pillars, being AI Campus, AI Playground, AI Connect, AI Hub, and AI Native, that collectively support the AI value chain from capability building to solution development and internal adoption. AI Campus focuses on collaboration with universities for talent and applied research development. AI Playground supports experimentation and validation of AI capabilities. AI Connect facilitates ecosystem engagement with industry and communities. AI Hub supports the development of AI use cases into solutions with business applicability. AI Native embeds AI into internal operations to enhance effectiveness and efficiency. Through this structure, the AI CoE aligns AI initiatives across business units, strengthens talent development, and supports the prioritization of use cases with clear relevance to business needs, while also serving as a platform for collaboration across academia, industry, government, communities, startups, and strategic partners.\n\nBuilding on the AI CoE framework, we also operate AI BigBox, an ecosystem of AI and big data solutions that helps organizations analyze data, automate workflows, and improve decision-making. AI BigBox is an analytics-driven platform designed for cross-industry use across government, retail, technology, media, and financial services sectors,\n\n75\n\n[Table of Contents](#TOC)\n\ncombining packaged products with solution delivery and consultative support. AI BigBox's current product portfolio consists of four core products:\n\n●BigSocial is a social media analytics product that supports real-time social media monitoring, including public sentiment analysis, competitive benchmarking, brand reputation management, and trend insights for campaigns and service improvements.\n\n●BigAssistant is an AI chatbot platform that enables organizations to build, train, and deploy AI chatbots across communication channels. It features a chatbot builder, knowledge management, Application Programming Interface integration, and multi-channel endpoint support, and can be deployed via dashboards and channels including WhatsApp.\n\n●BigLegal is a legal analytics product designed for AI-enabled legal and policy work. It uses AI and natural language processing to support legal search, clause extraction, document review and summarization, and policy drafting workflows with automated checks for errors, duplication, and inconsistencies.\n\n●BigVision is a video and image analytics product that provides capabilities including object detection, optical character recognition (“**OCR**”), and face recognition. It supports use cases such as AI-enabled closed-circuit television (“**CCTV**”) analytics, e-KYC verification, and document extraction, and can be deployed across cloud or on-premise infrastructure.\n\nIn 2025, Metranet strengthened its digital solutions portfolio across the education and public service segments, reinforcing its role as a key vehicle of TelkomGroup in supporting national development priorities under the RPJMN 2025–2029 (*Rencana Pembangunan Jangka Menengah Nasional*, or the National Medium-Term Development Plan of Indonesia). In the public service segment, Metranet contributed to improving national health outcomes through the implementation of the Stunting Management Dashboard, an integrated platform deployed across 32 cities and regencies that enables central and local governments to monitor, report, and manage stunting programs through real-time, data-driven insights, further enhanced with advanced analytics and real-time field data collection. In the education segment, Metranet supported the digitalization of national education systems through the implementation of digital student admission solutions across more than 5,000 schools, delivering greater efficiency, transparency, and accessibility for institutions, students, and parents.\n\nTo remain adaptive to market dynamics and Government direction, Metranet has developed its digital business portfolio across Big Data, financial services, B2B e-commerce, and digital advertising. Xooply delivers end-to-end digital procurement and marketplace solutions for corporate, government, and education customers. Cazbox focuses on system integration and digital platform services for content and community-based ecosystems. Scala provides end-to-end digital transformation solutions, including advisory and operational support for public and private sector organizations. Uzone operates as an omnichannel digital media and advertising platform that delivers integrated marketing solutions.\n\nThe digital content portfolio is managed through PT Nuon Digital Indonesia (“**Nuon**”), which operates across three segments: Digital Games, Digital Music, and Digital Lifestyle. Nuon plays a strategic role connecting content creation, platform distribution, and monetization, supported by end-to-end capabilities including content sourcing, platform provisioning, payment processing, and marketing. Leveraging the TelkomGroup ecosystem, Nuon integrates distribution, billing, and user reach to enhance conversion, retention, and monetization, while also supporting the growth of Indonesia's creative industry.\n\nIn the music segment, Langit Musik is a digital streaming platform featuring licensed local and international content that has expanded through bundled subscription offerings and integration as a mini app across various platforms. The portfolio also includes Ring Back Tone/Nada Sambung Pribadi (NSP 1212), which offers personalized ringtone services. In the gaming segment, Upoint is a digital platform for game vouchers and in-game transactions, and Dunia Games combines game content, community engagement, and distribution services, further supported by local game publishing, e-sports activities, and partnerships for global gaming access. In the digital lifestyle segment, Tiketapasaja\n\n76\n\n[Table of Contents](#TOC)\n\noperates as an event ticketing platform and official partner for major concerts and festivals, and the portfolio has expanded into broader entertainment activities including film production and event ecosystem development.\n\n*5.2 Property Management*\n\nConsistent with our strategy to accelerate the creation of our digital ecosystem, we prioritize increasing the utilization of our network-related buildings and equipment to expand our digital capacity. We also construct data centers for data-intensive areas while leveraging our sizeable property asset portfolio in markets with lower data usage through external partnerships and collaborations.\n\nWe execute our leveraging initiatives and space reconditioning through our subsidiary, PT Graha Sarana Duta (“**Telkom Property**”), which offers property development, property leasing, retail and leasing services, transportation management, and property management.\n\nIn 2025, Telkom Property implemented the Digital Adjacent Portfolio Transformation strategy which prioritizes portfolio optimization and asset rationalization within Telkom's captive market. As part of this strategy, Telkom Property reviews its business models and addresses capability gaps to pursue new market opportunities through portfolio transformation and digital-led initiatives. Telkom Property also leverages Telkom's digital infrastructure, connectivity, and platform ecosystem to develop and commercialize integrated digital–property solutions tailored to customer and tenant needs. Telkom Property has also incorporated AI into its operations to improve operational efficiency, support data-driven asset management, and develop new property services.\n\nIn addition to generating income, our property business also serves internal customers as part of our Group synergy initiatives by providing efficient space allocation for our network equipment and a functional work environment for our employees, partners, and subsidiaries. These assets include buildings that function as our network nodes, sales points, customer service centers, headquarters and branch offices, and land banks. Through these initiatives, we seek to achieve cost efficiency, including through economies of scale**.**\n\n**Network Infrastructure and Development**\n\nIn line with our vision and mission, we classify our network infrastructure into two categories, namely: (i) our national network infrastructure (including IT, cybersecurity, and services), which supports our Indonesia Cyber Core program and (ii) our international network infrastructure, which supports our international expansion program.\n\nNational Network\n\nThroughout 2025, we continued to develop our Group IT infrastructure, advance internal digitalization initiatives, and enhance customer services while expanding our Next Generation Network capabilities. We sought to drive innovation in digital connectivity services, strengthen cybersecurity, enhance network quality, deploy our Future State Architecture, optimize capital and operating expenditures, modernize our operating model, and improve talent management.\n\nWe regularly conduct software, network vulnerability assessments, and provide cybersecurity training to all employees. Our dedication to network development aligns with the Indonesia Broadband Plan and is intended to support the expansion of broadband access nationwide. We have accelerated our digitalization initiatives, together with the deployment and expansion of 5G technology, to address Indonesia’s growing demand for advanced telecommunications infrastructure.\n\nOur digital business comprises Integrated B2C Services, B2B ICT Services, Digital Infrastructure and Other Non-Core Businesses, focusing on innovations that respond to evolving technology and information service requirements. We continue to promote digitalization in Indonesia through our Indonesia Cyber Core program, which comprises three main components, namely id-Service (“**id-SEV**”), id-Convergence (“**id-COV**”), and id-Network (“**id-NET**”), which are further described below:\n\n77\n\n[Table of Contents](#TOC)\n\n·\n\n**id-SEV**: encapsulates our strategy to enhance digital connectivity products and foster innovation in digital and cybersecurity services to provide improved customer solutions. Our offerings include broadband internet, data, voice communications, and Wi-Fi for both fixed and mobile customers. We aim to continue growing our digital portfolio with services such as gaming, media streaming, online education, e commerce, mobile payments, travel, crowdsourcing, and healthcare, supported by the development of innovative platform infrastructures for applications, data management, GPU farming, in memory databases, AI, and big data.\n\n●**id-COV**: outlines our strategy to strengthen our digital platform business by optimizing integration and reliability while expanding our data center facilities and cloud services. Our initiatives include the continued development of hyperscale data centers and the enhancement of capacities across our neuCentrIX data center network in parallel with our cybersecurity platforms. We have established a data governance council to strengthen data security and compliance. Our smart platform supports digital businesses in providing various services by offering an interconnected platform via cloud management, dedicated cybersecurity platforms, big data processing, and AI innovations.\n\n●**id-NET**: sets out our approach to constructing a comprehensive network architecture through the adoption of next generation technologies, including FTTx, 5G, IODN, satellite solutions, and re-engineered Multi Service Aggregation Networks. We are working to future proof our digital services with cloud-based network solutions (such as SDN/NFV and SD WAN), while prioritizing the expansion of national fiber optic coverage and the modernization of our networks through the adoption of new technologies to enhance network performance. To support domestic and international connectivity, we participate in various submarine cable consortiums and operate satellites and other infrastructure to provide ICT services to remote areas and reduce dependency on foreign operators and networks.\n\nCellular Network\n\nAs of December 31, 2025, our subsidiary Telkomsel continued to operate the widest cellular network in Indonesia, encompassing GSM/DCS, GPRS, EDGE, 4G/LTE, and 5G technologies with a diverse spectrum allocation. Telkomsel added 18,298 new 4G and 3,938 new 5G BTS in 2025. As of December 31, 2025, the Telkomsel network encompassed a total of 293,136 BTS, including 2G, 4G, and 5G.\n\nOur subsidiary Mitratel has expanded its national telecommunications infrastructure portfolio through the acquisition and development of telecommunications towers. These acquisitions have strengthened Mitratel's position as Indonesia's leading independent tower company in terms of number of towers and enabled Telkomsel and other mobile operators to focus on network optimization and digital services. In 2023, Mitratel purchased 997 telecommunications towers from Indosat for Rp1.6 trillion and 803 telecommunications towers from PT Gametraco Tunggal for Rp1.8 trillion.\n\nIn 2025, Mitratel focused on organic growth and did not undertake any acquisitions of towers or fiber assets. Growth was driven by the development of new towers and the selective rollout of fiber infrastructure to support tenancy demand.\n\nData and Internet Network\n\nIn 2025, we continued to improve the quality of our data network by installing additional capacity and expanding coverage. As of December 31, 2025, we provided broadband access through fiber optic cable to more than 40 million homes. Our Metro Ethernet network had an aggregate installed capacity of 539,960 Gbps as of December 31, 2025.\n\nWe utilize our Metro Ethernet network to provide broadband services throughout Indonesia and as the main link for our IndiHome broadband services, softswitches, and IMS related to voice services, video services, enterprise VPN services, and GPON broadband services related to mobile backhaul and corporate business solutions.\n\n78\n\n[Table of Contents](#TOC)\n\nAs of December 31, 2025, we had extended the capacity of our internet gateway to reach an aggregate installed capacity of 7,800 Gbps, specifically to manage expected peak surges in traffic. In 2025, we operated CDNs with an aggregate content delivery capacity of 35,041 Gbps in collaboration with major partners.\n\nAs of December 31, 2025, we had 64 Points of Presence in 50 cities in Indonesia. These include 12 main PoPs in Batam (at Batam Center and Bukit Dangas), Jakarta (at Jatinegara and Cikupa), Surabaya (at Rungkut and Kebalen), Manado (at Manado Centrum and Manado Paniki), Makassar (at Pettarani and Balaikota), and Banjarmasin (at Banjarmasin and Ulin). Additionally, we had 52 primary and secondary PoPs throughout Indonesia. In 2025, we conducted PoP simplification to improve traffic routing efficiency and brought two new primary PoPs in Kendari into operation.\n\nIn 2025, we deployed additional Wi-Fi access points across Indonesia to enhance our Wi-Fi coverage, in alignment with our broader fixed broadband and mobile infrastructure deployments. We also decommissioned certain access points that exhibited low utilization to improve service quality, asset productivity, and operational efficiency. In line with our wireless access service roadmap and ongoing technology evolution, we transitioned our Wi-Fi business toward a managed access point and optical network terminal (“**ONT**”) Premium-based model, shifting focus to recurring revenue and higher-value service offerings. We further expanded our portfolio by introducing Wi-Fi Managed Services through ONT Premium, enabling SMEs to procure Wi-Fi across various bandwidth tiers with value-added service options. We also extended our managed Wi-Fi capabilities with satellite backhaul solutions to serve maritime and rural areas and expanded our CPE portfolio to address sector-specific customer requirements. We continue to strengthen Wi-Fi as a connectivity foundation for our B2B IT and wholesale businesses, including through mobile traffic offload and international roaming initiatives, to support sustainable revenue growth. As of December 31, 2025, we had installed a total of 148,052 Wi-Fi access points, comprising 99,647 managed access points and 48,405 ONT Premium access points.\n\nData Centers\n\nAs of December 31, 2025, we operate 35 data centers both in Indonesia and overseas. Of these, five are located overseas, including facilities in Singapore, Timor Leste, and Hong Kong. Our neuCentrIX data centers in Indonesia had an aggregate capacity of 2,757 racks as of December 31, 2025. In addition to our Singapore data centers, which have an installed capacity of 17 MW, NeutraDC in Indonesia also operates three enterprise data centers classified as Tier 3 or Tier 4, with a total IT load capacity of 17 MW. NeutraDC also operates one Hyperscale Data Center, classified as Tier 3 or Tier 4, located in Cikarang, with a current IT load capacity of 10 MW.\n\nIn 2024, we further expanded our neuCentrIX data center capacity and services through the deployment of three new neuCentrIX data centers. We also integrated our international data centers by transferring Telin Singapore's data center business to NeutraDC Singapore.\n\nAs of the date hereof, NeutraDC is also developing a Hyperscale data center in Batam (NeutraDC Nxera Batam). In 2025, we signed a contract with PLN Batam to secure electrical support with a total capacity of 90 MVA for the Batam data center. We are also exploring renewable energy initiatives in collaboration with PLN Batam. In October 2025, the first data center building in Batam (BTM-1) reached the topping-off milestone, signifying the completion of the main structural phase of the Hyperscale Data Center development at the Kabil Industrial Estate. The first campus of the NeutraDC Batam project is a three-campus development and became operational in 2026. This development aims to support digital transformation and economic development in Indonesia, particularly in Batam and the surrounding region, addressing demand from Singapore.\n\nAs of the date hereof, we are continuing to build new neuCentrIX data centers in Indonesia that will provide carrier-neutral connectivity and custom-made services for enterprise clients throughout the Asia Pacific region. NeutraDC continues to explore data center expansion options at the regional level.\n\n​\n\n79\n\n[Table of Contents](#TOC)\n\nTransmission Network\n\nOur backbone telecommunications network consists of transmission networks, switching facilities, and core routers that connect multiple access nodes. The transmission links between nodes and switching facilities comprise a terrestrial transmission network, specifically fiber optic, microwave, and submarine cable systems, as well as satellite transmission networks and other transmission technologies.\n\nIn 2025, we continued to focus on reinforcing the reliability of our domestic backbone network and developing our broadband network, which serves as the foundation for our entire network infrastructure. We implemented preemptive measures to enhance network reliability and mitigate congestion, particularly in urban areas, including increasing network capacity and prioritizing sensitive areas to prevent service disruptions (e.g., for key Government agencies or ministries and critical backbone connection links within our network). We also allocated additional resources to monitor our network through integrated operation centers and field technicians to control the physical integrity of our systems and detect potential intrusions.\n\nWe have continued to benefit from the enhancements to our network infrastructure and intend to maintain the reliability of our network.\n\nCommunications Cable System\n\nAs of December 31, 2025, our transmission network comprised 28 backbone rings in Indonesia with an aggregate installed capacity of 413.8 Gbps. Our domestic fiber optic backbone network totaled 115,643 km (compared to 112,743 km as of December 31, 2024). This domestic network is supplemented by an international fiber optic backbone network totaling 95,200 km.\n\nSince 2019, we have been deploying several submarine cable systems to strengthen our fiber optic backbone, and we continue to make progress on the deployment of our fiber optic backbone in eastern Indonesia. In October 2023, we completed the construction of our PATARA-2 submarine fiber optic cable system connecting across North Papua, Indonesia. In 2024, we completed the construction of the Labuha Obi submarine cable. In 2025, we commenced the necessary permitting and survey work for the PASELA submarine fiber optic cable system, which is designed to serve South Papua and is expected to become operational in the first half of 2028.\n\nWe intend to leverage Indonesia’s strategic geographic location to provide an alternative direct broadband connection between Europe, Asia, and America.\n\nThe IGG cable system connects two major submarine cable systems, namely SEA-ME-WE 5 and SEA-US. The IGG cable system also connects 12 major cities within Indonesia, including Batam, Jakarta, Surabaya, and Manado, spanning a length of 5,403 km. This cable system increases our domestic traffic capacity and ability to offer broadband services.\n\nIn 2025, we continued to expand our international connectivity through participation in global submarine cable consortiums, including Bifrost and SEA-ME-WE 6, further strengthening our position in the international telecommunications ecosystem.\n\nSatellites\n\nIn 2025, we own three satellites, Telkom-3S, Telkom Merah Putih, and the Telkom Merah Putih-2, which was successfully launched in February 2024. Across 2024, we transitioned from using TPE to Gbps as the measurement metric for satellite capacity to reflect the different technological characteristics of the Merah Putih-2 satellite.\n\n​\n\n80\n\n[Table of Contents](#TOC)\n\nDetails on our satellites are listed below:\n\n**Satellite**\n\n**Launch**\n\n**Commencement of Commercial Operations**\n\n**Capacity**\n\n**Area of Coverage**\n\nTelkom-3S\n\nFebruary 2017\n\nApril 2017\n\n4.4 Gbps\n\nIndonesia\n\nTelkom Merah Putih\n\nAugust 2018\n\nSeptember 2018\n\n5.4Gbps\n\nIndonesia and South Asia\n\nTelkom Merah Putih-2\n\nFebruary 2024\n\nMarch 27, 2025\n\n32.4 Gbps\n\nIndonesia and parts of Southeast Asia\n\nWe control our satellites from a main control station in Cibinong, Bogor in West Java. To promote continuity of service, we operate a backup control station in Banjarmasin, South Kalimantan.\n\nAdditionally, we lease capacity of 26.04 TPE from the following satellites: JCSAT 4B (124 E) in the amount of 0.05 TPE, Chinasat-11 (98 E) in the amount of 11.43 TPE, Eutelsat-172B (172 E) in the amount of 11.56 TPE, and MySAT-1 (142 E) in the amount of 3 TPE. Furthermore, we also lease capacity of 5.36 Gbps from the following satellites: Apstar-5C HTS (138 E) in the amount of 1.7 Gbps and Merah Putih-3 (134 E) in the amount of 3.66 Gbps.\n\nIn 2022, Telkomsat obtained landing rights from MoCD for Starlink’s satellite constellation. This allowed Telkomsat to provide backhaul services using the Starlink network, which is expected to improve internet broadband connectivity, especially 4G cellular broadband connectivity in rural areas throughout Indonesia. In May 2024, Telkomsat leveraged its partnership with Starlink by becoming the first Authorized Starlink Reseller in Indonesia.\n\nInternational Networks\n\nThrough Telin, we continue to strengthen and expand our international network infrastructure, with a primary focus on building a resilient, high-capacity global subsea cable ecosystem to support our long-term strategy as a digital infrastructure and platform provider. The fast-growing demand for international bandwidth, driven by hyperscalers, digital enterprises, and data-intensive applications, has pushed utilization of Telin's existing subsea cable systems to between 80% and 90% in 2025. This level of utilization has accelerated our submarine cable expansion program, through both new builds and capacity acquisitions.\n\nIn 2025, Telin advanced the deployment of two submarine cable systems. Bifrost is a trans-Pacific system connecting Singapore, Indonesia, the Philippines, Guam, and Los Angeles, developed in partnership with Meta and Keppel, and became operational in the fourth quarter of 2025. SJC2 (South East Asia–Japan 2) is an intra-Asia system linking Singapore to Japan through multiple regional landing points, and became operational in the third quarter of 2025.\n\nBeyond these systems, Telin has initiated the development of seven new submarine cable systems under the ICE program. In 2024, we executed four MoUs for ICE1, ICE2, ICE3, and ICE4, covering routes such as Batam–Singapore, Batam–Manado, Manado–Japan, and Jakarta–Middle East, in partnership with regional operators and global carriers. These systems are designed to provide low-latency, direct data center-to-data center connectivity, strengthening Indonesia's role as an interconnection hub.\n\nTo secure near-term capacity while long-term projects are under construction, Telin acquired capacity on additional cable systems. In 2024, Telin acquired capacity on the PEACE Cable System (Singapore–Marseille), enhancing connectivity between Southeast Asia and Europe. Telin also acquired capacity on the TOPAZ trans-Pacific system (Japan–United States via Canada), which entered service in early 2025, and augmented capacity on the SEAUS East Segment (Guam–Los Angeles) to balance traffic with the SEAUS West Segment (Manado–Guam).\n\nTelin is also investing in expanding and upgrading capacity on existing systems, including SJC, IGG–SEAUS, and SEAMEWE-5, to meet rising bandwidth demand across Asia, the Pacific, and Europe. Supporting infrastructure —\n\n81\n\n[Table of Contents](#TOC)\n\nincluding Beach Manholes (“**BMH”**), CLS and inland fiber connectivity to major data centers — is being developed and upgraded across Batam, Jakarta, Surabaya, and Manado to connect landing points with data centers for global customers.\n\nAll submarine cable systems operated or co-owned by Telin utilize open cable technology, allowing flexible wavelength management and efficient capacity scaling. Network operations are monitored and supported 24 hours a day, seven days a week, by the Telin World Hub Operation and Command Center (“**TOCC”**), ensuring service reliability and real-time response across Telin's global infrastructure.\n\nAs of December 31, 2025, Telin operates 58 PoPs worldwide to support our international voice and data services. This includes 26 PoPs in Asia and the Middle East, comprising 11 in Indonesia (supporting the international network), four in Singapore, four in Hong Kong, two in Kuala Lumpur, and one each in Dili, Tokyo, Taipei, Yangon, and Dubai. We also have 19 PoPs in Europe, including facilities in London, Amsterdam, Frankfurt, Warsaw, Vienna, St. Petersburg, Bucharest, Prague, Switzerland, Milan, Manchester, Luxembourg, Brussels, Sofia, Marseille, Paris, Moscow, Helsinki, and Madrid. We maintain a further 13 PoPs in the United States and Canada, including facilities in Montreal, Toronto, Los Angeles, Palo Alto, Ashburn, San Jose, New York, Guam, Hawaii, Seattle, San Francisco, and Atlanta.\n\n**Geographic Distribution of Revenues**\n\nInternational expansion is a necessity for us to be able to maintain and sustain a high growth rate. We are developing and expanding our business outside of Indonesia to broaden and diversify our market.\n\nThe following table sets forth the distribution of our revenues by geographic markets for the years indicated therein*.*\n\n​\n\n​\n\n​\n\n​\n\n​\n\n​\n\n​\n\n​\n\n​\n\n​\n\n​\n\n**Years Ended December 31,**\n\n​\n\n​\n\n**2023**\n\n​\n\n**2024**\n\n**2025**\n\n​\n\n**  ​ ​ ​**\n\n**(Rp billion)**\n\n**  ​ ​ ​**\n\n**(Rp billion)**\n\n**  ​ ​ ​**\n\n**(Rp billion)**\n\n**  ​ ​ ​**\n\n**(US$ million)**\n\n**External Revenues**\n\n \n\n  \n\n \n\n  \n\n \n\n  \n\n \n\n​\n\nIndonesia\n\n \n\n141,157\n\n \n\n141,062\n\n \n\n137,858\n\n \n\n8,267\n\nAbroad\n\n \n\n8,059\n\n \n\n8,905\n\n \n\n8,884\n\n \n\n532\n\n**Total**\n\n** **\n\n149,216\n\n** **\n\n149,967\n\n \n\n146,742\n\n** **\n\n8,799\n\n**Revenue Controls**\n\nAs a customer-facing business, we may face revenue leakage as a result of being unable to collect some revenues to which we are entitled. We mitigate such potential revenue leakage by implementing control functions in all of our existing business processes, cooperating with and sharing information between operating units to detect potential fraud, using revenue assurance methods, employing adequate policies and procedures, and implementing certain information system applications.\n\n**Overview of Telecommunications Services Rates**\n\nUnder the Telecommunications Law and Government Regulation No. 52 of 2000 on Telecommunications Operations, as partially revoked by **GR No. 46/2021 (“GR No. 52/2000, as amended”)**, tariffs for operating telecommunications services are determined by providers based on the tariff type and structure, and with respect to the price cap formula set by the Government. However, the Government may determine the (i) formula to calculate the tariff, and (ii) an upper limit tariff or lower limit tariff for the provision of telecommunications services based on public interest and fair competition.\n\n​\n\n82\n\n[Table of Contents](#TOC)\n\nTelecommunications Services Tariffs\n\nUnder the MoCD Regulation No. 5/2021, telecommunications services tariff consists of basic telephony service tariffs, value-added telephony service tariffs, and multimedia service tariffs, as described below:\n\n·\n\nBasic telephony services tariffs, comprising tariffs for the provision of basic telephony services, which include:\n\nocore features, such as telephony, facsimile, SMS, and/or MMS; and\n\noadditional features, including but not limited to Rich Communication Services.\n\n·\n\nValue-added telephony services tariffs, comprising tariffs for the provision of value-added telephony services, which include but are not limited to Information call center services and premium call services; and\n\n·\n\nMultimedia services tariffs, comprising tariffs for the provision of multimedia services, which include but are not limited to ISP and NAP services.\n\nAll the aforementioned tariffs follow the below tariff structure:\n\n·\n\nActivation fee;\n\n·\n\nMonthly subscription charges; and/or\n\n·\n\nUsage charges.\n\nTelecommunications Network Tariffs\n\nUnder the MoCD Regulation No. 5/2021, telecommunications network tariffs consist of basic interconnection tariffs, and network lease tariffs, as described below:\n\nInterconnection Tariffs\n\nThe Indonesian Telecommunications Regulatory Authority (*Badan Regulasi Telekomunikasi Indonesia* or “**BRTI**”), in its letter No. 262/BRTI/XII/2011 dated December 12, 2011, mandated a shift to cost-based pricing for SMS interconnection tariffs among telecommunications providers, with a maximum tariff of Rp23 per SMS effective from June 1, 2012, applicable to all telecommunications service operators. In addition, based on Letter No. 118/KOMINFO/DJPPI/PI.02.04/01/2014 of the DGPIO, the DGPIO required our Company and Telkomsel to submit annual Reference Interconnection Offer (“**RIO**”) proposals to the BRTI for evaluation. The subsequent approvals of the RIO adjustments by the BRTI, as indicated in its letters No. 60/BRTI/III/2014 and No. 125/BRTI/IV/2014 approved our Company’s and Telkomsel’s RIO adjustments, set the SMS interconnection tariff at Rp24 per SMS (the “**2014 RIO Proposal**”). Furthermore, on January 18, 2017, through its letters No. 20/BRTI/DPI/I/2017 and No. 21/BRTI/DPI/I/2017, BRTI resolved to maintain the interconnection tariffs from the 2014 RIO Proposal between Telkom and Telkomsel, pending the establishment of new interconnection tariffs.\n\nNetwork Lease Tariffs\n\nMoCD Regulation No. 5/2021 establishes guidelines on the structure and pricing for network lease services, including the form, type, structure, and formula of tariffs for such services, which built upon Decree No. 115 of 2008 issued by the Director General of Post and Telecommunications in Indonesia on Agreement on Network Lease Service Type Document, Network Lease Service Tariff, Available Capacity of Network Lease Service, Quality of Network Lease\n\n83\n\n[Table of Contents](#TOC)\n\nService, and Provision Procedure of Network Lease Service Owned by Dominant Network Lease Service Providers in agreement with the Telkom proposal.\n\nTariffs for Other Services\n\nThe tariffs for satellite lease, telephony services, and other multimedia are determined by the service providers by taking into account the expenditures and market prices of such services. The Government only determines the tariff formula for basic telephony services. The Government does not determine the tariffs for other services.\n\n**Marketing, Sales and Distribution**\n\nWe have implemented a comprehensive marketing and promotional strategy to bolster our brand and increase sales of our products and services, including through digital marketing and the development of our distribution channels. We use a variety of marketing channels, including above-the-line and below-the-line methods, to promote our services to specific customers and communities. We also place advertisements in printed and electronic media and implement marketing methods such as point-of-sale broadcasting and promotional and sponsorship events.\n\nThe following provides a description of our marketing and promotional strategies by customer segment.\n\nMobile Customers\n\nIn 2025, Telkomsel continued to lead and support a more constructive competitive environment through disciplined pricing execution and a product simplification agenda as part of our efforts to stabilize and rationalize the mobile market. Following periods of heightened competition, we and certain of our major competitors have undertaken rationalization measures, including the recalibration of starter packs toward a more standardized price point and the continued streamlining of product offerings, aiming to improve effective yield and encourage more sustainable market conduct. As execution progressed, we observed early signs of stabilization, including sequential improvement in ARPU and yield productivity, supported by a strategic shift away from customers frequently switching between promotional offers toward customers renewing their existing plans. We also note that PT XL Axiata Tbk merged with PT Smartfren Telecom Tbk in 2025, a development we expect to foster a healthier industry environment by promoting market rationality and price stabilization.\n\nIn recent years, we have also enhanced our digital lifestyle content offerings, including video, games, and music. For a description of our digital lifestyle content offerings, including MAXstream, Dunia Games, and Langit Musik, see “– *Business Portfolios – 1. Integrated B2C Services –1.1 Mobile Services*.”\n\nIn 2025, we continued to develop Telkomsel Orbit, a home wireless internet service designed to leverage our network capacity and as a complementary broadband solution to cater demand in areas not penetrated by our fixed broadband services.\n\nAs of December 31, 2025, we had 156.1 million cellular subscribers, comprising 147.6 million prepaid cellular subscribers and 8.4 million postpaid cellular subscribers.\n\nWe implement personalized offerings for mobile customers through dynamic customer segmentation and customer value management. This data analytics-driven approach allows us to conduct targeted marketing campaigns. Concurrently, we address mass-market demand, work to strengthen our market presence, and address affordability concerns by delivering certain services and products designed to capture new customers, such as the Telkomsel Lite brand launched in early 2024. We also maintain focus on broad-based prepaid accessibility through targeted offerings, including our relaunch of the SIMPATI brand in 2025 as part of our product simplification initiatives, while reinforcing a strategy that prioritizes customer retention and revenue contribution over volume.\n\n84\n\n[Table of Contents](#TOC)\n\nOur focus remains on maintaining a stable subscriber base and promoting average revenue per user (“**ARPU**”) resilience, which we believe helps establish a solid foundation of quality subscribers and market share. Our strategy includes encouraging customer upgrades to higher-tier packages and enhancing our digital content to attract higher-value segments over time, thereby fostering growth in customer consumption. Other strategic initiatives include network optimization and the strengthening of our core broadband services. For more information, see *“Item**4B**. Business Overview – Business Portfolios – 1. Integrated B2C Services.”*\n\nConsumer Customers\n\nIn 2025, IndiHome remained our flagship consumer product, with a continued strategy focused on accelerating fixed broadband penetration by addressing diverse segments with targeted pricing strategies and bundling strategies, while balancing disciplined execution with fit-for-purpose household offers. Telkomsel’s strategy seeks to bridge the home and mobile connectivity experience, a continued effort to strengthen FMC as a key differentiator. This strategy aims to increase fixed broadband adoption supported by ongoing cross-selling and retention initiatives, given the relatively low penetration of fixed broadband services in Indonesia as compared to the saturated cellular service market.\n\nDespite intensifying competition in fixed broadband market, we strive to remain competitive through various offerings, including the launch of EZnet, which complements existing offerings to capture new opportunities and address affordability concerns for certain mass-market segments and targeted areas, while maintaining a focus on customer retention and quality acquisition. We believe this strategy has enabled us to maintain a leading market position in Indonesia in terms of subscriber base. We have also implemented network enhancements and service improvements, such as improved response times to customer complaints.\n\nOur service offerings range from 10Mbps up to 300Mbps and are designed to provide value and affordability for a broad range of customer segments, including through bundled content. The integration of our IndiHome business into Telkomsel has fostered a unified customer strategy, enhancing our ability to cross-sell and up-sell. We offer personalized services through advanced data analytics, enabling us to refine our customer segmentation and tailor offerings. Our problem resolution is supported by an end-to-end traceable customer relationship management process. While our strategy to accelerate fixed broadband penetration has led to an increase in our customer base, we are also focused on encouraging higher-end customers to upgrade to premium packages to enhance ARPU.\n\nFrom the integration of our IndiHome B2C business into Telkomsel on July 1, 2023 to December 31, 2023, the number of fixed broadband IndiHome B2C subscribers increased by approximately 0.4 million, resulting in 8.7 million IndiHome B2C subscribers as of such date. As of December 31, 2025, we had a total of 10.3 million fixed broadband IndiHome B2C subscribers.\n\nEnterprise Customers\n\nIn 2025, we continued to refine our enterprise customer approach by targeting high-value enterprise customers through strategic account management, which involves offering tailored solutions to deepen customer relationships.\n\nOur marketing strategy for enterprise customers aims to:\n\n●Spearhead digital transformation for enterprises, including SOEs, to pursue and develop a leading bandwidth share in the digital connectivity market;\n\n●Empower SMEs with digital platforms to improve access to markets, funding, and technology, contributing to Indonesia’s digital transformation; and\n\n●Partner with the Government as a trusted ICT provider to support key national digital initiatives.\n\nOur sales approach provides tailored support across various enterprise customer segments:\n\n85\n\n[Table of Contents](#TOC)\n\n●**Large Enterprises**: Enterprise account managers offer a single point of contact, delivering comprehensive service from relationship initiation to after-sales customer care;\n\n●**Government**: Government account managers cater to the ICT needs of Government agencies, with support from relationship officers to enhance service quality; and\n\n●**SMEs**: Business account managers and tele-account managers cater to the needs of SME customers, with support from third-party value-added resellers. These efforts are supplemented by digital channels and mobile applications.\n\nWholesale and International Business Customers\n\n**Our wholesale and international business segment serves domestic operators, service providers, digital entities, global wholesalers, carriers, and enterprises utilizing overseas data centers and international connectivity. Additionally, through our Non-Geostationary Orbit satellites, we cater to certain retail customers internationally.\n\nOur marketing and sales strategy for this segment focuses on:\n\n●Strengthening core wholesale revenue streams by optimizing our legacy voice and messaging businesses through disciplined business model and pricing strategies to maximize value amid structural shifts in usage;\n\n●Scaling digital infrastructure to capture long-term growth by selectively expanding data-center capacity, enhancing end-to-end network competitiveness, and increasing international subsea cable capacity to serve global demand;\n\n●Building a differentiated wholesale internet ecosystem by deepening content aggregation and CDN capabilities to improve service performance, resilience, and customer outcomes; and\n\n●Expanding infrastructure platforms for future value creation through the continued growth and transformation of our tower and satellite businesses, positioning them as integrated, end-to-end infrastructure solutions.\n\nDigital Service Customers\n\nOur marketing strategy for digital service customers focuses on strengthening and improving digital innovation, including by enriching digital content, creating unique digital services, and growing our digital services portfolio through investments in digital startups.\n\nWe tailor our sales strategy to each particular digital business. We offer customer care and channel management through various means, including contact centers, dedicated account management for large enterprises, websites, and social media. Our digital service program for consumers has focused on improving IndiHome services. For example, we promote digital touchpoints for IndiHome customers, which offer bundled packages that may include services such as Disney+ Hotstar, Indibox (a source of value-added services such as video content and games), GameQoo (a cloud gaming service), and IndiHome Smart (an Internet of Things, or IoT, home service).\n\nDistribution Channels\n\nOur primary distribution channels for products and services in 2025 included:\n\n●**Walk-in and Mobile Customer Service Points**: These include Plasa Telkom Digital outlets and GraPARI centers, which offer comprehensive Telkom and Telkomsel services. As of December 31, 2025, these included 463 GraPARI centers across Indonesia;\n\n86\n\n[Table of Contents](#TOC)\n\n·\n\n**Authorized Dealers and Modern Retail Channels**: These channels distribute Telkomsel products such as starter packs and prepaid top-up vouchers;\n\n·\n\n**Partnership Stores**: These extend our reach through various third-party marketing outlets, including electronics stores and bank ATMs;\n\n·\n\n**Contact Centers**: These facilities support customer access to our services;\n\n·\n\n**Specialized Teams**: Account management and sales teams provide tailored solutions to large enterprises, Government agencies, and wholesale customers;\n\n·\n\n**Channel Partners**: Third-party value-added resellers meet the needs of certain enterprise customers;\n\n·\n\n**Digital Touchpoints**: We provide customer service and account management through digital platforms such as, MyTelkomsel, MyTEnS for enterprise customers, MyIndibiz for SMEs, and MyCarrier for wholesale customers;\n\n·\n\n**Websites**: Our websites, including *www.telkom.co.id, www.telkomsel.com, www.telin.net*, and *www.indihome.co.id* offer e-services such as billing and support;\n\n·\n\n**Social Media and Instant Messaging**: We use platforms such as Facebook, Instagram, and WhatsApp for product interaction and support, including through our AI-powered chatbot, Veronika; and\n\n·\n\n**LinkAja**: Our e-money service allows customers to conduct transactions and service purchases digitally.\n\nFor the avoidance of doubt, the information contained on our websites referred to above is not a part of this annual report on Form 20-F, nor is such content incorporated by reference herein.\n\n**Licensing**\n\nTo provide national telecommunications services, we have product and service licenses that are consistent with applicable laws, regulations, and decrees.\n\nCellular\n\nTelkomsel holds licenses to operate a nationwide mobile cellular telephone network using 15 MHz of spectrum allocation in the 800/900 MHz frequency bands, 22.5 MHz of spectrum allocation in the 1.8 GHz frequency band, 20 MHz of spectrum allocation in the 2.1 GHz frequency band, and up to (depending on the region) 50 MHz additional spectrum in the 2.3 GHz frequency band, together won at auctions in October 2017, May 2021, and November 2022 as well as gained from PT Berca Indonesia in November 2022. The licenses do not have set expiry dates, but they are evaluated every 10 years. The validity of Telkomsel’s spectrum licenses/permits is subject to the applicable regulatory regime, including periodic evaluation and/or renewal requirements. In particular, Telkomsel renewed its Radio Frequency Band Permit for the 2.1 GHz 1st carrier starting from March 2026, for a 20-year usage period. In addition, Telkomsel holds permits and licenses from, and registrations with certain local governments and/or Government agencies, primarily in connection with its operations in such regions, the properties it owns and/or the construction and use of its BTS.\n\nFixed Network and Basic Telephony Services\n\nWe have the following licenses to operate fixed local networks, fixed long-distance direct line networks, fixed international call networks and fixed closed networks:\n\n·\n\nMoCD Decree No. 073/TEL.01.02/2021 (on licenses to operate fixed long distance direct line);\n\n87\n\n[Table of Contents](#TOC)\n\n·\n\nMoCD Decree No. 094/TEL.01.02/2021 (on licenses to operate fixed closed networks);\n\n·\n\nMoCD Decree No. 082/TEL.01.02/2021 (on licenses to operate fixed international networks); and\n\n·\n\nMoCD Decree No. 095/TEL.01.02/2021 (on licenses to operate circuit switched based local fixed-line networks).\n\nThese licenses do not have set expiry dates, but they are evaluated every five years.\n\nInternational Calls\n\nWe have a license to operate a fixed network to provide international call services pursuant to MoCD Decree    No. 082/TEL.01.02/2021.\n\nWe have a license to operate a fixed closed network pursuant to MoCD Decree No. 094/TEL.01.02/2021. This license allows us to lease installed fixed closed network to telecommunications network and service operators, among others, and to provide an international telecommunications transmission facility through a SCCS directly to Indonesia for overseas telecommunications operators.\n\nAccording to MoCD Regulation No. 5/2021, overseas telecommunications operators who wish to provide international telecommunications facilities through the SCCS directly to Indonesia are required to set up a partnership with a fixed network of international call services or closed fixed network provider. In line with MoCD Regulation No. 5/2021, the international telecommunications transmission facilities provided through SCCS are operated by us on the basis of landing rights we hold within Indonesia and that are attached to our license to operate fixed network of international call services.  \n\nDGPIO Decree No. 93 of 2016 on Limited Fixed Network Licenses granted our subsidiary Telin a license to operate a fixed closed line network which enables Telin to provide international infrastructure services. Separately, Telin secured landing rights in Indonesia from the DGPIO to provide international telecommunications transmission facilities through the Submarine Cable System (“**SCS**”).\n\nThe foregoing licenses do not have set expiry dates, but they are evaluated every five years.\n\nIDD Services\n\nWe have a license to provide IDD services under MoCD Decree No. 082/TEL.01.02/2021. We offer IDD fixed-line services to customers using the “007” IDD access code.\n\nVoIP\n\nWe are licensed to provide internet telephony services for public utilization for commercial use as provided under DGPIO Decree No. 127 of 2016 (on internet telephony services for public utilization). Telkomsel is also licensed to provide public VoIP services based on DGPIO Decree No. 65 of 2015 (internet telephony services for public utilization). These licenses do not have set expiry dates, but they are evaluated every five years.\n\nISP\n\nWe are licensed as an ISP under MoCD Decree No. 2176 of 2016 (on internet access services). Telkomsel is also licensed to provide multimedia internet access services with nationwide coverage under DGPIO Decree No. 19 of 2016 (on internet access services). These licenses do not have set expiry dates, but they are evaluated every five years.\n\n​\n\n88\n\n[Table of Contents](#TOC)\n\nInternet Interconnection Service\n\nWe hold a license to provide internet interconnection services pursuant to MoCD Decree No. 1004 of 2018 on Internet Interconnection Service (Network Access Points). This license does not have a set expiry date, but it is evaluated every five years.\n\nData Communication System (“SISKOMDAT”)\n\nWe have a license to provide data communication system services pursuant to MoCD Decree No.046/KEP/M.KOMINFO/02/2020 (on data communication system services). This license does not have a set expiry date, but it is evaluated every five years.\n\nPayment Method Using E-Money\n\nFollowing the implementation of BI’s regulations applicable to APMK and E-Money businesses since 2009, BI confirmed our status as an issuer of E-Money in 2018. We operate our E-Money business under the brand name “t-money.” We, through Telkomsel, also operate our E-Money business under the brand name “LinkAja” (formerly known as “**T-Cash**”). With the issuance of BI Circular Letter No. 9/9/DASP, Telkomsel is also permitted to conduct APMK activities and offers *Tunai* prepaid cards. These permits do not have set expiry dates so long as: (i) we and Telkomsel continue to conduct the relevant businesses in compliance with applicable regulations, and (ii) the Government does not amend or revoke such permits. In addition, BI regulations governing E-Money companies in Indonesia have multiple requirements for BI license holders such as Telkomsel, including certain restrictions on shareholding and corporate governance as well as risk management and information system capability requirements.\n\nIn the midst of digital wallet business competition, LinkAja’s strategy is to serve consumers under the B2C business model and to provide business solution services under the B2B business model. LinkAja has extended its ecosystem into its shareholders’ and strategic partners’ digital platforms, such as MyTelkomsel and MyPertamina, acting as a digital financial enabler through services including account linking and the provision of digital products. In parallel, LinkAja has strengthened its presence in the advertising business by developing advertising solutions that support its shareholders’ ecosystem initiatives, including in-app campaigns and the optimization of its shareholders’ assets and inventory for advertising purposes.\n\nFor the B2C LinkAja application segment, LinkAja continues to target the unbanked population with technology literacy in the productive-age segment nationwide, while also emphasizing its role in supporting the broader BUMN ecosystem, including employees. LinkAja’s B2B business solution services provide various features such as fund disbursement, cash collection, digital payments through QRIS, merchant applications and other digital ecosystems, as well as advertising services. LinkAja targets MSMEs and corporations in various industries. Key B2B collaborations include: (i) Digipos Telkomsel, where LinkAja functions as the payment balance for merchants and supplies digital products such as prepaid electricity and e-wallet top-ups; (ii) Pertamina Single Settlement, where LinkAja serves as an intermediary connecting users, Pertamina, and other payment methods within the MyPertamina application; (iii) MyTelkomsel Linkage, a comprehensive integration between LinkAja and MyTelkomsel, enabling users to access LinkAja accounts and services directly within MyTelkomsel; and (iv) advertising solutions, connecting advertisers with businesses seeking advertising opportunities, thereby establishing a broader advertising network.\n\nLinkAja also develops Sharia-related initiatives, including: (i) digitalization of partnerships with Islamic organizations, communities, and MSMEs; (ii) strategic collaboration with philanthropic institutions to support digital donation initiatives; (iii) partnerships with Muslim-focused digital applications; and (iv) development of Sharia-compliant digital features to support subscription payments across Muslim-focused digital platforms (e.g., Muslim Pro and Qaara).\n\n​\n\n89\n\n[Table of Contents](#TOC)\n\nAdministration of Source of Fund and Remittance Services\n\nWe and Telkomsel have licenses to operate as money transfer service providers pursuant to BI License No. 23/587/DKSP/Srt/B. These permits do not have set expiry dates so long as: (i) we and Telkomsel continue to conduct the relevant businesses in compliance with applicable regulations, and (ii) the Government does not amend or revoke such permits. BI re-evaluates the license every three years from the date the license is issued, and BI also retains the authority to initiate an additional evaluation at any time if necessary, allowing for more frequent oversight to designed to establish our compliance with regulatory requirements.\n\nIPTV\n\nSince March 5, 2024, after effecting the transfer of the IndiHome business segment into Telkomsel, Telkom no longer holds an IPTV telecommunications service operation license as it is no longer listed in Telkom’s NIB.\n\nHowever, we are able to continue to provide IPTV services by reselling Telkomsel’s IPTV products, which Telkomsel offers through its IPTV telecommunications service operation license, obtained on May 27, 2023.\n\nConstruction Services Business\n\nCertain of our subsidiaries possess SBUJKs, thereby permitting us to provide national telecommunications-related construction services, which primarily consist of installing telecommunications equipment and wiring buildings.\n\nOn February 15, 2023, we obtained an SBUJK for the construction of central telecommunications infrastructure, such as stations for voice connection. While this license has no expiry date, Construction Services Development Institute (*Lembaga Pengembangan Jasa Konstruksi*) re-evaluates all such licenses every three years.\n\nContent Service Provider\n\nWe obtained a content service provider license in 2017 pursuant to MoCD Decree No. 1040 of 2017 on Content Service Providers dated May 16, 2017. While such license has no set expiry date, MoCD re-evaluates all content service provider licenses every five years.\n\n**Trademarks, Copyrights and Patents**\n\nWe seek to develop product and service innovations in line with a dynamic business portfolio. To provide both protection for and recognition of creativity and innovation, we have registered several intellectual property rights, including trademarks, copyrights, and patents with the Directorate General of Intellectual Property Rights at the MoL.\n\nThe intellectual property rights we have registered include: (i) trademarks for our products and services, corporate logo and name, (ii) copyrights for our corporate name and logo, product and service logos, computer programs, research, books and songs, and (iii) single patents (generally valid for 10 years from the date of receipt of the single patent submission) and patents (generally valid for 20 years from the date of receipt of the patent submission) on technological inventions in the form of telecommunications products, systems and methods.\n\n**Corporate and Social Responsibility and Human Capital Management**\n\nWe are dedicated to fostering a sustainable business and contributing to a sustainable society. Our efforts encompass enabling connections, generating employment, and driving digital innovation. Our sustainability strategy is grounded in our five pillars of ethics, growth, human capital, societal contribution, and environmental stewardship and is regularly reviewed to mitigate risks and capture new opportunities.\n\n90\n\n[Table of Contents](#TOC)\n\nOur governance framework demonstrates our ambition to become a partner of choice for customers, suppliers, and communities, backed by a firm commitment to ethical practices. All employees are required to uphold our ethical standards in their daily work, and we provide regular training and information to foster a culture of integrity. We are also committed to upholding fair competition, data privacy, and transparent, inclusive procurement practices. We believe that our recognition for excellence in corporate governance and security reflects our progress in these areas.\n\nIn 2025, we received numerous awards and acknowledgments in human capital management, including in the areas of employer branding, corporate social responsibility, women's empowerment, and diversity, equity, and inclusion. The following is a list of our awards in human capital:\n\n•Forbes World's Best Employers 2025 for the fifth consecutive year, ranking 345th globally and first in Indonesia;\n\n•LinkedIn Top Companies Indonesia for four consecutive years;\n\n•Best Practices of Sustainable Development Goal 14 in the United Nations Sustainable Development Goals (“**SDGs”**) National Voluntary Review by the United Nations, through the Indonesia National SDGs Secretariat, Ministry of National Development Planning (“**BAPPENAS”**);\n\n•Silver Winner in ESG Asia Positive Impact by Asia Positive Impact ASEAN and EY SEA Region, recognizing our commitment to local community relations through the DigiUp Program;\n\n•International certification as a Great Place to Work for three consecutive years by the Great Place to Work Institute;\n\n•Bronze Medal in the SDGs Impact Award by BAPPENAS, recognizing excellence in SDGs practices among large companies;\n\n•Gold Winner for Community Involvement Development and Best Social and Environmental Responsibility (“**TJSL**”) Agent of the Year in the Indonesia Corporate Communication and Sustainability Summit 2025 by the State-Owned Enterprise Communication Forum (BP BUMN);\n\n•Best Practices for Community Development – Health Category in the IDX Channel Award by the IDX through our Stunting Action Hub program;\n\n•Silver Medal for CSR Strategy in the Indonesia Corporate Sustainability Award 2025 by Olahkarsa in collaboration with the Association of Carbon Emission Experts Indonesia (ACEXI);\n\n•Gold Winner in the Lestari Awards by KG Media, recognizing our commitment to local community relations through the DigiUp Program;\n\n•Best Practices for Digital Inclusion Pioneer in the Republika Awards by Republika through our Stunting Action Hub Program; and\n\n•Top 10 Most Compliant State-Owned Enterprises in the Satya JKN Award 2025 by the Government and the Social Health Insurance Administration Body (BPJS *Kesehatan*).\n\nWe rely on our growth pillar to enhance and modernize our business through innovation and digitalization. By digitizing and streamlining our operations, we intend to maintain and improve our operational and financial health. We believe that high-quality products and services are central to achieving this goal, as they underpin customer satisfaction and business continuity. In our telecommunications business, we prioritize connectivity, platforms, and services, constantly improving our network and IT systems to mitigate cybersecurity risks and maintain our infrastructure's integrity.\n\n91\n\n[Table of Contents](#TOC)\n\nCollaborative initiatives with law enforcement agencies enhance security, and we incorporate customer feedback to refine our offerings.\n\nWe prioritize managing human capital because we believe that our employees, managers, and skilled personnel are key to becoming and remaining a leading digital telecommunications company. Our human capital management practices focus on equitable recruitment, diversity, positive labor relations, and personal growth. We foster an inclusive culture, offering equal training and advancement opportunities to attract and retain top talent. This approach is informed by international norms on human rights and gender equality. As of December 31, 2025, women held approximately 35.05% of managerial roles, comprised 45.44% of our workforce and represented 64.7% of our 2025 new hires. Our efforts to support gender equality include flexible work schedules, harassment-free policies, and adjustments for working mothers, such as remote work options and on-site childcare. We also support the Indonesian Ministry of Manpower's and the International Labor Organization's initiatives toward a child-labor-free Indonesia. We aim to enhance productivity by ensuring a modern, digital, and secure workspace that accommodates flexible work arrangements and health, safety, and environmental standards. We believe that our recognition as a Great Place to Work for three consecutive years by the Great Place to Work Institute aligns with these values. For more details on our human capital strategy, please see *“Item 6. Directors, Senior Management and Employees — D. Employees.”*\n\nIn 2025, we implemented our Social and Environmental Responsibility (“**TJSL**”) programs as an integral component of our sustainability strategy and long-term value creation framework. The TJSL framework is designed to deliver measurable outcomes across environmental stewardship, inclusive social empowerment, MSME digital capacity building, and effective governance, while remaining aligned with internationally recognized ESG standards. The TJSL framework has been integrated with the Indonesia SDGs Action Plan, coordinated by the Ministry of National Development Planning.\n\nDuring 2025, we allocated approximately Rp169.3 billion to TJSL initiatives across Indonesia. Funding priorities focused on programs that strengthen digital inclusion, enhance social resilience, and support sustainable economic growth. Under the social pillar, we expanded inclusive digital education through our Digital Learning School, teacher certification programs, vocational digital skills development, and digital literacy programs targeting women and persons with disabilities. These initiatives were complemented by community-based programs addressing food security, stunting prevention, and the development of digitally enabled assisted villages (*desa binaan*), supporting more equitable access to essential services and socioeconomic opportunities.\n\nTo support inclusive economic growth, we strengthened MSME digital capacity through structured entrepreneurship training, digital onboarding, and market access facilitation aligned with the MSME growth journey—from initial capability development to scaling and international market exposure. These programs are designed to integrate MSMEs into our digital ecosystem, enhancing productivity, competitiveness, and long-term business sustainability.\n\nEnvironmental initiatives in 2025 focused on supporting our decarbonization objectives through carbon offset and climate action programs, including green and blue carbon conservation, waste management, water provision, and community-based climate adaptation initiatives supported by green applications. In parallel, we continued to invest in sustainable infrastructure, including renewable energy-powered public street lighting and biogas projects, rural connectivity expansion, elderly housing development, and suspension bridge construction to improve accessibility in underserved areas. Certain environmental initiatives also contribute to operational risk mitigation, including mangrove restoration activities that support the resilience of coastal areas surrounding our subsea cable landing points.\n\nSee *“Business Overview — Strategy — Environmental, Social and Governance (“ESG”) matters”* above for more information on our ESG strategies.\n\n**The Telecommunications Industry in Indonesia**\n\nIn 2025, Indonesia’s GDP grew by 5.11%, with further expansion expected in 2026, according to Government data. In its January World Economic Outlook Update, the IMF forecasts a 5.1% growth for the Indonesian economy in\n\n92\n\n[Table of Contents](#TOC)\n\n2026. The Indonesian telecommunications industry has seen significant advancements, with rising mobile and broadband subscriptions primarily as a result of greater affordability, service improvements, and higher smartphone penetration. The shift from traditional voice and SMS to data services is still ongoing, fueled by the affordability of smartphones and a sizeable youth demographic. OTT applications have supplanted legacy services, causing a notable decline in traditional telecommunications revenues.\n\nThe industry has also faced intense competition, with operators initiating promotional deals to attract customers sensitive to data pricing, leading to lower operator margins and intense price competition. The industry, however, saw a return to pricing and competition stability in late 2021, which continued through 2025, particularly following the price increases implemented by all major operators in late 2024, which have since been sustained into 2025. Operators have sustained healthier market conduct amidst rising demand for high-quality data services.\n\nAs of December 31, 2025, according to our internal estimates, Indonesia had approximately 322.8 million cellular subscribers, a 3.2% increase from 312.9 million in 2024, with Telkomsel holding a market share of approximately 48.0%. Following the IOH merger and the announcement of the XLSmart merger in 2024 has contributed to a more rational competitive environment and Telkomsel focused on initiatives to foster sustainable growth and profitability. Rising data consumption has required substantial investments in network improvements. In response, we have prioritized expanding coverage and enhancing network quality. This includes completing the 3G shutdown and migrating to 4G in 2023, which extended network coverage, supported the growth of digital businesses, and improved customer experience.\n\nWith the analogue TV bandwidth now available, mobile operators have the opportunity to strengthen their 4G LTE service offerings and explore 5G service offerings, providing enhanced coverage and speed. As data traffic remains a key revenue stream, telecommunications companies face the challenge of expanding their infrastructure to cater to the increasing data traffic, influenced by HD video streaming, gaming, and a surge in network-connected devices.\n\nFixed broadband penetration in Indonesia remains relatively low at less than 20%. However, demand for quality internet connectivity continues to increase, with the fixed broadband market still led by a few key players, including us and IconNet. However, high barriers to entry persist due to licensing and infrastructure requirements and limitations. Despite increasing competition and a slightly reduced market share, we continued to lead with approximately 10.3 million IndiHome B2C subscribers as of December 31, 2025.\n\nCompetition\n\nOur cellular services business, which we operate through our majority-owned subsidiary Telkomsel, faces competition primarily from IOH and XLSmart. The competitive environment in Indonesia continues to evolve as these competitors expand their service coverage into regions where Telkomsel has an established presence. In 2025, supply and demand conditions in the cellular services market began to stabilize, which we believe indicates a healthier competitive landscape. Industry competition has shown meaningful improvement compared with 2024, with signs of greater pricing discipline across operators and a shift toward healthier market conduct. In particular, starter pack oversupply has normalized, and operators have increasingly aligned supported by unified starter pack pricing, alongside broader product rationalization and simplification. As execution has progressed, the focus has increasingly shifted toward renewal package simplification.\n\nFollowing the initial announcement in late 2024, the merger between XL Axiata and Smartfren, which is part of the Sinar Mas Group, was completed in December 2025. Historically, mergers between larger and smaller operators in our market have contributed to a more balanced competitive landscape by reducing aggressive pricing practices. We expect that this consolidation will result in more rational pricing across the industry and support a more sustainable market structure.\n\nFor further information, see *“Item 3. Key Information—D. Risk Factors—Risks Related to Our Business— The telecommunications industry is characterized by intense competition and rapid technological change, and our ability to*\n\n93\n\n[Table of Contents](#TOC)\n\n*compete effectively depends on significant capital investment, access to sufficient spectrum, and successful adaptation to new technologies and market entrants.”*\n\n*Business Competition Law*\n\nThe Indonesian telecommunications sector is regulated by the Telecommunications Law, which took effect on September 8, 2000. The Telecommunications Law provides guidelines for industry reforms, including industry liberalization, to facilitate the entry of new operators as well as to increase transparency and competition. The Telecommunications Law eliminated the concept of “organizing entities” in the industry, which terminated the special status of Telkom and Indosat as the organizing bodies responsible for coordinating telecommunications services domestically and internationally. To increase competition, the Telecommunications Law prohibits monopolistic practices and unfair competition among telecommunications operators.\n\nThe Telecommunications Law, as amended by the Job Creation Law 2023, is implemented through various Government Regulations and Ministerial Regulations, including: (i) GR No. 52/2000, as amended, (ii) Government Regulation No. 46/2021, (iii) MoCD Regulation No. 01/PER/M.KOMINFO/01/2010 on Telecommunications Network Operations as last amended by MoCD Regulation No. 5/2021, (iv) MoCD Regulation No. 7 of 2018 on Electronic Integrated Business Licensing Services in the Sector of Communications and Informatics as last amended by MoCD Regulation No. 6 of 2021 on Broadcasting Operations (“**MoCD Regulation No. 7/2018, as amended**”), (v) Decree of the Ministry of Transportation No. KM33 of 2004 on Monitoring of Fair Competition of The Fixed Network and Basic Telephone Service Operations, and (vi) MoCD Regulation No. 14 of 2018 on Fundamental Technical Plan of National Telecommunications Plan.\n\nThe Government encourages healthy competition and transparency in the telecommunications sector, although the Government does not prevent operators from obtaining a dominant position or increasing their dominance in the market through specific regulations. Nevertheless, the Government prohibits market leading operators from abusing their dominant position.\n\nCompetition in the telecommunications sector, as with all Indonesian business sectors, is also governed more generally by the Business Competition Law, as amended by the Job Creation Law 2023. The Business Competition Law prohibits agreements and activities which constitute unfair business competition and an abuse of a dominant market position. Pursuant to the Business Competition Law, the KPPU was established as Indonesia’s antitrust regulator with the authority to enforce the provisions of the Business Competition Law.\n\nThe Business Competition Law is implemented by various regulations, including Government Regulation No. 57 of 2010 on Merger or Consolidation of Business Entities and Acquisition of Company Shares Which May Result In Monopolistic Practices and Unfair Business Competition (“**GR No. 57/2010**”). GR No. 57/2010 permits voluntary consultation with the KPPU prior to a merger or acquisition, which will result in the KPPU issuing a non-binding opinion. GR No. 57/2010 also requires that a mandatory report be made to the KPPU after a merger or acquisition is completed if the transaction exceeds certain asset or sales value thresholds. Further, on March 30, 2023, the KPPU issued Regulation No. 3 of 2023 on Assessment of Mergers, Acquisitions, or Stock Takeovers and/or Asset Acquisitions That May Result in Monopoly Practices and/or Unfair Business Competition (“**KPPU Regulation No. 3/2023**”). Under KPPU Regulation No. 3/2023, asset acquisitions which meet the set regulatory threshold must be reported to the KPPU.\n\nIn addition, a new implementing regulation relating to the Business Competition Law, namely Government Regulation No. 44 of 2021 on The Implementation of Monopolistic Practices Prohibition and Unfair Business Competition (“**GR No. 44/2021**”) has been issued following the adoption of the Job Creation Law 2023.\n\nThe Job Creation Law 2023 amended the Business Competition Law in the following ways:\n\n·\n\nAssignment of the authority to examine objections to the KPPU’s decisions from the District Court to the Commercial Court;\n\n94\n\n[Table of Contents](#TOC)\n\n·\n\nElimination of the deadline for examining objections at the Commercial Court and cassation at the Supreme Court;\n\n·\n\nAdditional provisions on administrative actions and the elimination of maximum fines of Rp25 billion; and\n\n·\n\nElimination of principal and additional criminal provisions.\n\nThe Job Creation Law 2023, as implemented by GR No. 44/2021, regulates the authority of the KPPU, criteria for the imposition of sanctions and types of sanctions for violations of competition law, and the amount of fines as well as procedures for the evaluation of objections and appeals against KPPU decisions.\n\nFurthermore, on May 31, 2021, the KPPU issued KPPU Regulation No. 2 of 2021 on the Guidelines for the Imposition of Fines for the Violation of Monopolistic Practices and Unfair Business Competition (“**KPPU Regulation No. 2/2021**”) which provides provisions on the calculation of fines, bank guarantees, payment of fines and concessions for payment of fines. According to KPPU Regulation No. 2/2021, the KPPU may impose a fine of between a minimum of Rp1 billion and a maximum of either 50% of the net profit earned by the business in the relevant market or 10% of the total sales of the business in the relevant market during the period when the violation occurred. The fine amount is Rp1 billion plus a calculation based on: (a) the negative impact caused by the violation, (b) the duration of time the violation occurred, (c) mitigating factors, (d) aggravating factors, and/or (e) the ability of business actors to pay the fine.\n\nAdditionally, in 2022, the KPPU issued KPPU Regulation No. 1 of 2022 on the Business Competition Compliance Programs which aims to provide a general understanding of compliance for business actors in preventing violations of laws and encouraging the implementation of business activities in accordance with the principle of fair business competition. As an incentive for business actors to register their compliance programs, the KPPU will impose a lower fine if the business actors are later proven to have violated the Business Competition Law. To comply with the Business Competition Law, we obtained certification of our compliance program from the KPPU, as evidenced by the Statement of Compliance Program No. 04/KPPU-PKP/2023 issued by the KPPU.\n\nCellular\n\nWe operate our cellular service business through Telkomsel.\n\n*Market Position and Competition*\n\nAs of December 31, 2025, Telkomsel was the largest cellular provider in Indonesia, with approximately 156.1 million cellular subscribers, which represented an estimated market share of approximately 48.0%. Based on publicly available information, we believe the next largest providers as of such date were IOH and XL Smart, based on their respective number of subscribers.\n\nThe penetration of SIM cards in Indonesia is high, which makes continued growth in the total number of subscribers increasingly difficult. As of December 31, 2025, there were approximately 322.8 million cellular subscribers in Indonesia, as compared to approximately 312.9 million as of December 31, 2024. Despite a penetration rate that indicates market saturation, the total number of cellular subscribers has remained relatively stable, which suggests that a significant portion of the population continues to use multiple SIM cards.\n\n*Regulatory Environment*\n\nThe Government’s enforcement of its prepaid SIM card registration policy, which began in 2018, has resulted in a higher proportion of active subscribers and has contributed to a healthier competitive environment. We believe that this policy, assuming its continued implementation, will continue to have a positive long-term impact on the industry. Changes in regulations regarding SIM card registration, usage, or distribution could, however, impact the number of subscribers in the future.\n\n95\n\n[Table of Contents](#TOC)\n\n*Industry Trends*\n\nThe trend of customers shifting from legacy services, such as voice and SMS, to data services continues, driven by the increased availability of lower-priced smartphones and a growing youth customer segment. Data traffic has grown significantly, while voice and SMS service traffic has decreased over the past five fiscal years. This trend is attributable to the substitution of traditional voice and SMS services with over-the-top, or OTT, based calling and messaging services as smartphone penetration in Indonesia has risen. We expect this trend to continue for the foreseeable future.\n\nDespite these challenges, our Digital Business segment continues to grow. We remain focused on encouraging customers to adopt more productive digital habits as internet connectivity becomes increasingly essential.\n\nThe following table sets out information as of December 31, 2025, for Telkomsel:\n\n​\n\n​\n\n​\n\n​\n\n​\n\n​\n\n​\n\n  ​ ​ ​\n\n**Unit**\n\n​\n\n**Telkomsel**\n\n  ​ ​ ​\n\nLaunch date\n\n \n\nyear\n\n​\n\n1995\n\n \n\nNeutral - 2G, 3G and/or 4G spectrum allocation (GSM 900 MHz)\n\n \n\nMHz\n\n​\n\n15\n\n \n\nNeutral - 2G, 3G and/or 4G spectrum allocation (GSM 1.8 GHz)\n\n \n\nMHz\n\n​\n\n22.5\n\n \n\nNeutral - 2G, 3G and/or 4G spectrum allocation (2.1 GHz)\n\n \n\nMHz\n\n​\n\n20\n\n \n\nTime Division Duplex (TDD) technology (2.3 GHz)\n\n​\n\nMHz\n\n​\n\n50\n\n1)​\n\nSubscribers\n\n \n\nmillion\n\n​\n\n156.1\n\n \n\nNote:\n\n(1)\n\nComprises additional spectrum in the 2.3 GHz frequency band that Telkomsel won following an auction process in 2021.\n\nFixed Broadband Services\n\nWe face competition in the fixed broadband market from major providers such as IconNet, MyRepublic, XL Home, and Biznet, with IconNet in second place behind us in terms of customer base. The industry is witnessing strategic acquisitions targeting subscriber growth, including IOH’s acquisition of MNC Play and XL Axiata’s purchase of PT Link Net Tbk, as operators strive for service convergence and new growth engines. Despite increased competition since 2019 and the market entry of PT Perusahaan Listrik Negara’s subsidiary, IconNet, which leverages wide coverage beyond Java, Telkomsel aims to accelerate fixed broadband penetration by targeting various market segments with targeted pricing strategies. This includes offering competitive pricing to address affordability concerns in the mass-market segment while encouraging higher-end IndiHome customers to upgrade to premium packages and bundled content, all while maintaining high-quality broadband services. In addition, our fixed broadband strategy focuses on sustainable, quality-led growth, including retention, disciplined acquisition, and initiatives to enhance customer value and experience through segmented offers and value-added services, while leveraging FMC to deepen household engagement.\n\nData Centers\n\nCompanies such as Equinix/NTT Communication, EDGE Connex, Biznet, DCI Indonesia, Elitery, Nex-center/CBN Nusantara, Pure DC, BDx/IOH provide data center solutions in Indonesia and compete with us. In the Asia Pacific region, our subsidiary, Telin, competes with other major data center providers in Hong Kong and Timor Leste. We are dedicated to providing the highest quality of data center solutions to our customers in Indonesia and Asia Pacific. Supported by our proprietary self-owned submarine cable network, our comprehensive co-location services are designed to be flexible, modular, seamless, and scalable in order to meet our customers’ business needs.\n\nInternational Direct Dialing (IDD)\n\nWe compete in traditional IDD services (non-VoIP) in Indonesia, primarily with IOH. However, due to the development of digital technology, our IDD services also face competition from VoIP and other OTT voice services such as Telegram, FaceTime (iPhone), and WhatsApp. The presence of these OTT services has affected the use of legacy services, which has resulted in decreasing traffic in recent years.\n\n96\n\n[Table of Contents](#TOC)\n\nVoice over Internet Protocol (VoIP)\n\nWe have operated our voice service through VoIP technology since 2002. VoIP uses data communications to transfer voice traffic over the internet, which usually provides substantial cost savings to subscribers. Several other companies, including XL Axiata, IOH, PT Atlasat Solusindo, PT Gaharu Sejahtera, PT Telindo Nusantara, PT Quiros Networks, PT Aktif Tengah Malam, PT Jasnita Telkomindo, and PT IP Telecom Multimedia Indonesia also provide licensed VoIP services in Indonesia.\n\nSatellite\n\nThe Asia Pacific region, particularly Southeast Asia, requires satellites on an ongoing basis for telecommunications and broadcasting infrastructure due to the region’s archipelagic nature. The technological capabilities provided by satellites include cellular backhaul, broadband backhaul, enterprise network, military network, Government network, video distribution, video contribution, DTH TV, communication on aviation, maritime, mining, plantation, and for disaster recovery scenario, as well as other satellite-based services.\n\nWe compete with several other satellite operators with satellites covering Southeast Asia and South Asia, and several operators are in the process of developing satellites with coverage over these regions.\n\nTower\n\nWithin Indonesia’s tower industry, we operate in a competitive landscape alongside PT Tower Bersama Infrastructure Tbk, PT Profesional Telekomunikasi Indonesia Tbk., PT Centratama Telekomunikasi Indonesia Tbk. and PT Solusi Tunas Pratama Tbk.\n\nFrom 2018 to 2023, industry demand moderated following mobile sector consolidation and spectrum reallocation. While this period limited near-term growth, it also encouraged greater capital discipline, network optimization, and more sustainable industry structures. In 2024, industry activity began to stabilize, supported by continued mergers and acquisitions and selective tower divestments by mobile network operators. These transactions were primarily driven by operators’ need to optimize capital allocation while maintaining network quality and preparing for incremental 5G deployment.\n\nDuring 2023–2025, MNO mergers and strategic alliances further reshaped the competitive landscape, prompting continued divestment of tower assets as operators rebalanced capital toward core network expansion and service quality enhancements.\n\nIn 2025, despite the ongoing effects of MNO consolidation, the tower sector has demonstrated resilience. Stable long-term contracts, predictable recurring revenues, and continued demand for broader coverage and fiber backhaul have underpinned occupancy levels. Growth remains measured, driven by selective densification in urban and peri-urban areas, fiber-to-the-tower integration, and demand for reliable infrastructure to support evolving data traffic and service quality expectations. The sector continues to benefit from long-term contracts, predictable cash flows, and its role as essential infrastructure underpinning Indonesia’s digital connectivity agenda.\n\nThe requirement for new tower infrastructure persists, underpinned by continued profitability among mobile operators and the need to extend coverage, particularly outside of Java where market opportunity is substantial. Additionally, investments in complementary services such as fiber connectivity for improved mobile services have spurred tower market growth.\n\nIn addition to our 5G deployment and the adoption of newer network technologies in anticipation of future demand for services, we are transitioning our tower business towards fiber optic solutions, aligning with global shifts of tower companies evolving into comprehensive infrastructure providers. We have already initiated this transformation and aim to reinforce our tower operations to support Indonesia’s 5G infrastructure development.\n\n97\n\n[Table of Contents](#TOC)\n\nAs of December 31, 2025, we had approximately 44,702 towers, including approximately 40,230 towers owned by Mitratel and approximately 4,472 towers owned by Telkomsel.\n\nLegal Basis and Regulation\n\nThe regulatory framework for the Indonesian telecommunications industry comprises specific laws, Government Regulations, Ministerial Regulations, and Ministerial Decrees enacted and issued from time to time.\n\nTelecommunications Law\n\nThe Indonesian telecommunications sector is primarily governed by the Telecommunications Law, which became effective on September 8, 2000. This law established guidelines for industry reforms, encompassing industry liberalization, the facilitation of new entrants, and enhanced transparency and competition across various business activities.\n\nThe Telecommunications Law eliminated the concept of “organizing entities” thereby ending our and Indosat’s responsibility for coordinating domestic and international telecommunications services, respectively. To enhance competition, the Telecommunications Law prohibits monopolistic practices and unfair competition among telecommunications operators, aiming to pave the way for market liberalization.\n\nThe Telecommunications Law was implemented through several Government Regulations, Ministerial Regulations, and Ministerial Decrees. Key regulations include:\n\n·\n\nLaw No. 36 of 1999 on Telecommunications, as partially amended by the Job Creation Law 2023;\n\n·\n\nLaw No. 27 of 2022 on Personal Data Protection;\n\n·\n\nGovernment Regulation No. 52 of 2000 on Telecommunication Operations, as partially revoked by Government Regulation No. 46 of 2021 on Post, Telecommunications and Broadcasting;\n\n●Government Regulation No. 53 of 2000 on the Use of Radio Frequency Spectrum and Satellite Orbit, as partially revoked by Government Regulation No. 46 of 2021 on Post, Telecommunications and Broadcasting;\n\n●Government Regulation No. 46 of 2021 on Post, Telecommunications and Broadcasting;\n\n●Government Regulation No. 43 of 2023 on Types and Tariffs for Non-tax Revenue Implemented by MoCD;\n\n·\n\nMoCD Regulation No. 01/PER/M.KOMINFO/01/2010 on Telecommunications Network Operations as partially revoked by MoCD Regulation No. 5 of 2021 on Telecommunications Operation;\n\n·\n\nMoCD Regulation No. 20 of 2016 on Data Protection on Electronic System;\n\n·\n\nMoCD Regulation No. 13 of 2019 on Telecommunications Services Operation, as last amended by MoCD Regulation No. 14 of 2021 on the Third Amendment to MoCD Regulation No. 13 of 2019 on Telecommunications Services Operation;\n\n●MoCD Regulation No. 5 of 2021 on Telecommunications Operation;\n\n​\n\n·\n\nMoCD Regulation No. 14 of 2018 on the Fundamental Technical Plan of National Telecommunications;\n\n●MoCD Regulation No. 2 of 2025 on the Amendment to Regulation of the MoCD Regulation No. 2 of 2023 on the Use of Radio Frequency Spectrum Based on Class Permit;\n\n98\n\n[Table of Contents](#TOC)\n\n·\n\nMoCD Regulation No. 11 of 2022 on Governance of Implementation of Electronic Certification; and\n\n·\n\nMoCD Regulation No. 3 of 2024 on Certification of Telecommunication Equipment and/or Telecommunication Devices.\n\nTelecommunications Industry Regulators\n\nThe authority to regulate the telecommunications industry is vested in MoCD. Pursuant to authorities assigned to it under the Telecommunications Law, MoCD establishes policies, regulates, supervises, and controls the telecommunications industry in Indonesia. MoCD comprises several directorate generals, each authorized to set policies, supervise, evaluate, and report on various derivative aspects of telecommunications industry in Indonesia. Specifically, the DGPIO oversees the postal and telecommunications sectors in Indonesia, including with respect to licensing, numbering, interconnection, USO, and business competition. Additionally, the Directorate General of Post and Informatics Resources and Equipment of MoCD is responsible for regulating matters related to radio frequency spectrum and standardization of telecommunications equipment in Indonesia.\n\nClassification and Licensing of Telecommunications Providers\n\nThe Telecommunications Law organized telecommunications services into following three categories: (i) provision of telecommunications networks, (ii) provision of telecommunications services, and (iii) provision of special telecommunications services.\n\nLicenses issued by MoCD are required for each category of telecommunications services. MoCD Regulation    No. 13 of 2019 on Telecommunications Services Operation, as last amended by MoCD Regulation No. 14 of 2021 on the Third Amendment to MoCD Regulation No. 13 of 2019 on Telecommunication Services Operations (“**MoCD Regulation No. 13/2019, as amended**”) regulates all telecommunications services and requires a permit issued by MoCD for the provision of such services by any person.\n\nSince 2018, MoCD has transferred a significant portion of its licensing responsibilities to the Online Single Submission (“**OSS**”) through the enactment of Government Regulation No. 24 of 2018 on Electronic Integrated Business Licensing Services (“**GR No. 24/2018**”). Consequently, the OSS oversees the administration and issuance processes for the majority of telecommunications business licenses. Designed as an online platform, OSS aims to expedite and simplify the acquisition of business licenses, making it accessible at any time, from any location, for businesses across Indonesia.\n\nGR No. 24/2018 also introduces a mandate for any existing or newly established business in Indonesia to obtain an NIB through OSS registration. This NIB serves as a substitute for various other licenses and permits, including customs duties access rights. The NIB is obligatory for businesses seeking to (i) apply for new business licenses and/or commercial or operational licenses, or (ii) extend or modify existing business licenses and/or commercial or operational licenses.\n\nTo support OSS registration, the Government established The Indonesian Standard Industrial Classification (KBLI) as the official standard for classifying economic activities in Indonesia into specific groups based on shared characteristics through the Central Statistics Agency (BPS) Regulation No. 7 of 2025 on The Indonesian Standard Industrial Classification (revoked BPS Regulation No. 2/2020). BPS Regulation No. 7/2025 has been adjusted to the International Standard Industrial Classification. MoCD requested that all telecommunication providers change their KBLI codes by the latest on June 17, 2026.\n\nCellular\n\nCellular telephone service is provided in Indonesia on radio frequency spectrum in the 1.8 GHz (neutral technology), 2.1 GHz (neutral technology), 900 MHz (neutral technology), and 2.3 GHz (neutral technology). The MoCD regulates the use and allocation of radio frequency spectrum for mobile cellular networks. Telkomsel has obtained\n\n99\n\n[Table of Contents](#TOC)\n\nfrequency allocation for cellular services in the 800 MHz, 900 MHz, 1.8 GHz, 2.1 GHz, and 2.3 GHz frequency bands. The allocation of frequency is regulated by:\n\n●MoCD Decree No. 620 of 2020 (on the Extension of the Stipulation on the 800 MHz, 900 MHz, and 1800 MHz Radio Frequency Bands by PT Telekomunikasi Selular);\n\n●MoCD Decree No. 480 of 2022 (on the Rearrangement of License Holders for the Use of Radio Frequency Spectrum in the 2.1 GHz Radio Frequency Band);\n\n●MoCD Decree No. 356 of 2018 (on the Stipulation of Radio Frequency Bands Resulting from the Refarming of 2.1 GHz Radio Frequency Bands for the Implementation of Cellular Mobile Networks);\n\n●MoCD Decree No. 1896 of 2017 (on the Establishment of PT Telekomunikasi Selular as the Winner of 2.3 GHz Radio Frequency Band User Selection in 2017 for the Implementation of Cellular Mobile Networks); and\n\n●MoCD Decree No. 188 of 2023 (on the Stipulation of the Radio Frequency Band Resulting from the Rearrangement and Approval of the Transfer of the Right to Use the Radio Frequency Spectrum in the 2.3 GHz Radio Frequency Band from PT Telekomunikasi Selular to PT Smart Telecom).\n\nInterconnection\n\nThe Telecommunications Law expressly prohibits monopolistic practices and mandates network providers to facilitate user access across networks on the basis of mutual interconnection agreements. In accordance with GR No. 52/2000, as amended, interconnection fees must be transparent, equitable, and based on mutual consent.\n\nOn March 31, 2021, MoCD released MoCD Regulation No. 5/2021 which requires that basic telephony service network operators provide interconnection transparently and without discrimination. This regulation enforces that agreements regarding service levels must uphold the quality standards for operation of telecommunications services established by the Director General of Telecommunications to promote healthy business competition, maintain service performance, and protect consumer interests. Such operators must also be ready to implement such IP-based interconnections following pursuant to mutual agreements without altering the existing fee determination process. Such implementation under mutual agreements may continue until the MoCD determines the technical provisions for full IP-based interconnections. Under this regulation, any adjustments to the Reference Interconnection Offer (“**RIO**”) must be submitted to MoCD.\n\nFurther, MoCD Regulation No. 5/2021 empowers the DGPIO to evaluate RIOs from operators with a dominant market position, defined as telecommunications network operators that control 50% or more of the total revenue of all telecommunications network operators of basic telephony services.\n\nMoCD Regulation No. 5/2021 also sets a transition timeline for interconnection services to move from TDM-based to IP-based interconnection services, between July 1, 2021, and December 31, 2024, with the expectation that all interconnection services will utilize IP technology by January 1, 2025.\n\nVoIP\n\nIn January 2007, the Government implemented interconnection regulations and a five-digit access code system for VoIP services pursuant to MoCD Decree No. 06/P/M.KOMINFO/5/2005 (“**MoCD Decree No. 6/2005**”). Under MoCD Decree No. 6/2005, the prefix for VoIP, which was originally 01X, was changed to 010XY. On April 27, 2011, MoCD issued Regulation No. 14/PER/M.KOMINFO/04/2011, as partially revoked by MoCD Regulation No. 11/2014 and MoCD Regulation No. 7/2018, as amended, which imposed quality control standards in relation to VoIP services on VoIP providers and this became effective three months thereafter, to which we and other operators must adhere.\n\n100\n\n[Table of Contents](#TOC)\n\nIPTV\n\nIn Indonesia, the IPTV business is regulated by MoCD Regulation No. 13/2019, as amended. GR No. 46/2021, as amended, provides that subscription-based broadcasting can be conducted using satellites, cables, and terrestrial transmitters. Broadcasting using satellite can have a nationwide range, while cables and terrestrial transmitters can only cover a particular region. As stipulated by MoCD Regulation No. 13/2019, IPTV services entail the delivery of television, video, audio, text, and data via an IP network, ensuring quality, security, and reliability in facilitating interactive communication between the provider and users.\n\nSatellite\n\nIn Indonesia, the use of radio spectrum frequency for satellites is governed by MoCD Regulation No. 3 of 2025 on the use of Radio Frequency Spectrum for Satellite Service and Satellite Orbit (“**MoCD Regulation No. 3/2025**”). MoCD Regulation No. 3/2025 requires foreign satellite operators to obtain a landing right license to operate in Indonesia and coordinate with domestic satellite operators, including us, to prevent the operational disruption of Indonesian satellite and terrestrial systems. Additionally, as per GR No. 46/2021, subject to MoCD’s approval, spectrum allocations can be re-assigned to different telecommunications operators, outside of the occurrence of a merger or acquisition.\n\nConsumer Protection\n\nUnder the Telecommunications Law, each network provider is required to protect consumer rights in relation to, among other things, quality of services, tariffs, and compensation. Customers injured or damaged by negligent operations may file claims against negligent providers. Telecommunications consumer protection regulations provide service standards for telecommunications operators.\n\nUSO\n\nAll telecommunications operators, whether network or service providers, are required by USO regulation to provide a financial contribution which is used to provide facilities and infrastructure for telecommunications access to certain underserved and undeveloped regions and citizens in Indonesia. MoCD regulations require, among other things, that when selecting a provider of telecommunications access and services in rural areas (as part of the Government’s USO program), the selection process is conducted by the Rural Telecommunications and Informatics Center (*Balai Telekomunikasi dan Informatika Pedesaan* or “**BTIP**”). Subsequent regulations renamed BTIP as the Telecommunications and Information Accessibility Agency (*Badan Aksesibilitas Telekomunikasi dan Informasi* or “**BAKTI**”).\n\nUSO payment requirements are calculated as a percentage of our and Telkomsel’s unconsolidated gross revenues, net of bad debts, interconnection charges, and/or connection charges. The USO tariff rate as of the date hereof is 1.25% of gross revenues (excluding certain revenues), net of bad debts and/or interconnection charges and/or connection charges.\n\nRegulatory Charges\n\nThe Government collects several non-tax state revenues from telecommunications providers. For Government spectrum auctions, the Government collects both an upfront fee (equal to twice the offering price submitted by each of the winning bidders) as well as an annual license fee for telecommunications operations (equal to the lowest offering price submitted by all winning bidders). MoCD also collects regular payments from telecommunications operators, calculated based on gross revenues, while deducting both certain receivables that have been written off as well as interconnection fees.\n\nFurther, telecommunications equipment and devices are subject to a certification fee. Telecommunications equipment and devices that are used for research, development, and disaster response are exempted for an initial period and subsequently only subject to half the commercial certification fee. Telecommunications equipment and devices with local content in excess of 50% are also charged half the certification fee plus a testing fee.\n\n101\n\n[Table of Contents](#TOC)\n\nTelecommunications Towers\n\nOperating telecommunications towers involves a number of relevant Government bodies. On March 30, 2009, the Ministry of Home Affairs Regulation No. 18/2009, Ministry of Public Works Regulation No. 07/PRT/M/2009, MoCD Regulation No. 19/PER.M.KOMINFO/03/2009 and Head of the Investment Coordinating Board Regulation No. 3/P/2009 (on Guidelines For The Construction And Shared Use Of Telecommunications Towers) together, the (“**Tower Construction Joint Decree**”) were promulgated with the intention of creating a joint system of regulation of telecommunications towers to be implemented by various Government bodies.\n\nBased on the Tower Construction Joint Decree, the construction of telecommunications towers requires construction permits from the relevant Governmental authorities. The Tower Construction Joint Decree also stipulates that the construction of telecommunications towers must observe the zoning and spatial planning applicable in the relevant regions of Indonesia. The Tower Construction Joint Decree states that the license for telecommunications tower construction is to be issued by regents or mayors, and for Jakarta Province, its Governor. The Tower Construction Joint Decree also provides tower construction standards and requires that telecommunications towers be made generally available for shared use by telecommunications service providers. The owner of a telecommunications tower is allowed to collect a fee, which is determined by reference to investment and operational costs, return on investment and profits earned. Monopolistic practices in the ownership and management of telecommunications towers are prohibited. The Tower Construction Joint Decree stipulates that telecommunications providers that own telecommunications towers and other tower owners are obligated to allow other telecommunications operators to utilize their telecommunications towers without discrimination, with due regards to the technical capacity of the respective tower.\n\nUnder GR No. 46/2021, a telecommunications service provider who owns passive telecommunications infrastructure (including telecommunications towers) has to grant access to such infrastructure to other telecommunications providers. GR No. 46/2021 states that such use of passive telecommunications infrastructure must be based on cooperation and mutual agreement between the parties involved in a fair, reasonable, and non-discriminative manner. The terms and conditions of any such cooperation agreement to be entered into by telecommunications operators still remain to be seen, pending the issuance of further guidelines by MoCD (if any).\n\nThe Ministry of Internal Affairs Regulation No. 19 of 2016 on the Guidelines for the Management of Regional Assets, as last amended by the Ministry of Internal Affairs Regulation No. 7 of 2024 (“**MoIA 19/2016**”), outlines the factors to be considered when adjusting lease rates for Regional Assets (*Barang Milik Daerah* or “**BMD**”) in the form of land used for various types of infrastructure, including telecommunications and informatics infrastructure. Specifically, for the lease of land for telecommunications infrastructure, if the leased land does not include integrated utility network facilities or pathways, the lease rate is set at 0% of the base lease rate. As a result, the BMD lease rate is determined solely by the base lease rate, without any additional adjustment factors applied for telecommunications and informatics infrastructure.\n\nContent Provider Services\n\nContent provider service is regulated by MoCD in accordance with MoCD Regulation No. 13/2019, as amended.\n\n**C.          ORGANIZATIONAL STRUCTURE**\n\nWe employ a strategic control framework for the management of our Group, which we believe provides our subsidiaries with operational flexibility tailored to their business needs and characteristics. Our corporate office outlines the overall corporate strategy and then delegates its implementation to each Directorate and Regional Business Unit accordingly. This structure, centered around customer segmentation and geography, allows us to manage emerging business challenges while aligning our operations with our diverse business portfolios. We have eight directorates:\n\n102\n\n[Table of Contents](#TOC)\n\n●**The Enterprise and Business Service Directorate (“EBIS”)** is responsible for business strategy and architecture for our enterprise segment, with the objective of growing our enterprise business portfolio within our Group in accordance with applicable Company policies and regulations.\n\n●**The Wholesale and International Service Directorate (“WINS”)** is responsible for business strategy and architecture for our wholesale and international segment, with the objective of growing our wholesale and international business portfolio within our Group in accordance with applicable Company policies and regulations.\n\n●**The Strategic Business Development and Portfolio Directorate (“SBDP”)** is responsible for value creation and business development through end-to-end corporate strategy management, investments, partnerships, and the optimization of value in our subsidiaries and affiliates to meet our corporate strategic objectives.\n\n●**The Information Technology Directorate (“IT Directorate”)** is responsible for the end-to-end development and management of our IT and digital products, leveraging our core digital IT capabilities to generate value and ensure consistent management of IT and digital functions across our Group.\n\n●**The** **Network Directorate** is responsible for network strategy, technology, architecture, cybersecurity, and our digital connectivity and cybersecurity service roadmap. Its mandate is to enhance our capabilities, improve operational efficiency through the provision of infrastructure and services, and prioritize investment in future network infrastructure.\n\n●**The Finance and Risk Management Directorate (“KMR”)** is responsible for financial strategy, policies, and operations, as well as asset management, risk management, investor relations, and inorganic business development, in each case in accordance with applicable Company policies and regulations.\n\n●**The** **Human Capital Management Directorate (“HCM”)** serves as a strategic business partner to our business lines and oversees our human capital management functions. HCM supports our business units and subsidiaries through centers of excellence, provides guidance on human capital strategy and policy, and oversees talent management systems across our Group.\n\n●**The** **Legal and Compliance Directorate (“L&C”)** is responsible for the comprehensive management of our legal, governance, and compliance matters, providing strategic and operational legal support for our businesses within our Governance, Risk, and Compliance **(“GRC”**) framework.\n\nFor a list of our subsidiaries and their countries of incorporation, see Exhibit 8.1 to this Form 20-F. A complete list of our subsidiaries and investments in associated companies, and our ownership percentage of each entity, as of December 31, 2025, is disclosed in Notes 1d and 11 to our Consolidated Financial Statements.\n\n103\n\n[Table of Contents](#TOC)\n\nThe following diagram illustrates our corporate structure of our principal operating entities as of the date of this report:\n\n​\n\n**D.           PROPERTY, EQUIPMENT AND RIGHT OF USE ASSETS******\n\nOur property and equipment are primarily used for telecommunications operations, which mainly consist of  transmission and installation equipment, cable network and in turn consist of (i) switching equipment, (ii) telegraph, telex, and data communication equipment, (iii) transmission installation and equipment, (iv) satellite, earth station, and equipment, (v) cable network, (vi) power supply, (vii) data processing equipment, (viii) drop cable, and (ix) other telecommunication peripherals collectively grouped as ‘telecommunication infrastructure’. A description of these is contained in Note 12 to our Consolidated Financial Statements and *“— Business Overview — Network Infrastructure and Development.” See also “Item 5B — Liquidity and Capital Resources — Capital Expenditures”* for material plans to construct, expand or improve our property and equipment.\n\nExcept for ownership rights granted to individuals in Indonesia, reversionary rights to land rests with the Government, pursuant to Agrarian Law No. 5 of 1960. Land title is designated through land rights, including Right to Build (*Hak Guna Bangunan* or “**HGB**”) and Right of Use (*Hak Guna*). Both rights stipulate that title holders enjoy full use of the land for a specified period, subject to renewal and extensions. In most instances, land rights are part of right-of-use assets, freely tradable and may be placed as security under loan agreements.\n\nWe lease several parcels of land located throughout Indonesia together with rights to build and use such land for periods varying from 1-50 years, which will expire between 2026 and 2071. In 2025, there were deductions in Group leases, including expired leases and reclassifications related to land rights, buildings, transmission, installations, equipment, vehicles, and other assets used in operations, amounting to Rp910 billion. We hold registered rights to build and right to use for most of our properties. Pursuant to Government Regulation No. 18 of 2021 on Right to Manage, Land Right, Apartment Unit, and Land Registration, the maximum initial period for the right to build is 30 years and is extendable for up to an additional 20 years plus up to another additional period of 30 years.\n\n104\n\n[Table of Contents](#TOC)\n\nThe right to build can be further renewed for an additional period of 30 years. We are not aware of any environmental issues that could affect the utilization of our property and equipment and right-of-use assets. Please refer to Notes 12 and 13 to our Consolidated Financial Statements.\n\nAll assets owned by our Company have been pledged as collateral for bonds. Please refer to Note 12b to our Consolidated Financial Statements. Certain property and equipment of our subsidiaries with an aggregate gross carrying value amounting to Rp2,205 billion (US$137 million) as of December 31, 2025, have been placed as collateral for loan agreements. Please refer to Notes 12b(vii) to our Consolidated Financial Statements.\n\nIn 2025, we implemented a voluntary change in accounting policy concerning the componentization and determination of the unit of account for certain assets, namely drop cable assets. See *“Item 5. Operating and Financial Review and Prospects – Principal Factors Affecting our Financial Condition and Results of Operations – Voluntary Change in Accounting Policy”*for further information on this voluntary change of accounting policy. Following the identification of drop cable assets as a separate component, we determined that the useful life of these assets should be five years, reflecting their specific characteristics and pattern of economic benefits consumption.\n\n**Insurance**\n\nAs of December 31, 2025, our property and equipment (excluding land rights), with a net carrying amount of Rp160,374 billion was insured against fire, theft, earthquake and other specified risks, under blanket policies totaling Rp44,267 billion, HK$35 million, SG$197 million, and MYR46 million, and first loss basis amounted to Rp2,750 billion. We believe that the insurance coverage is adequate to cover potential losses from the insured risks.\n\n**Disclosure of Iranian Activities under Section 13(r) of the Exchange Act**\n\nSection 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 added Section 13(r) to the Exchange Act. Section 13(r) requires an issuer to disclose in its annual or quarterly reports, as applicable, whether it or any of its affiliates knowingly engaged in certain activities, transactions or dealings relating to Iran or with designated natural persons or entities involved in terrorism or the proliferation of weapons of mass destruction. Disclosure is required even where the activities, transactions or dealings are conducted outside the United States by non-United States affiliates in compliance with applicable law, and whether or not the activities are sanctionable under U.S. law.\n\nAs of the date of this report, we are not aware of any activity, transaction or dealing by us or any of our affiliates in 2025 that requires disclosure in this report under Section 13(r) of the Exchange Act, except as set forth below.\n\nTelkomsel, our subsidiary, is party to international roaming agreements with Mobile Telecommunication Company of Iran and Irancell Telecommunications Services Company, which are or may be Government-controlled entities. In 2025, we recorded gross revenues of US$4,304 from transactions under these agreements. The amount of our net profits earned under these agreements is not determinable, but it does not exceed our gross revenues from these agreements. The purpose of these agreements is to provide Telkomsel’s customers with coverage in areas where Telkomsel does not own networks, and for this reason Telkomsel intends to continue the activities covered by these agreements.\n\nWe also provide telecommunication services in the ordinary course of business to the Embassy of Iran in Jakarta, Indonesia. We recorded gross revenues of approximately Rp16.7 million from these services in 2025. The amount of our net profits earned under these services is not determinable, but it does not exceed our gross revenues from these services. As one of the primary providers of telecommunication services in Indonesia, we intend to continue providing such services, as we provide to the embassies of many other nations.\n\n​\n\n105\n\n[Table of Contents](#TOC)"}