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UNITED STATES SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20549

Form 20-F

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Commission file number 1-14406

Perusahaan Perseroan (Persero)

PT Telekomunikasi Indonesia Tbk

(Exact name of Registrant as specified in its charter)

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Telecommunications Indonesia

(a state-owned public limited liability company)

(Translation of Registrant’s name into English)

Republic of Indonesia

(Jurisdiction of incorporation or organization)

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Jl. Japati No. 1, Bandung 40133, Indonesia 

(Address of principal executive offices)

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Investor Relations Unit

Telkom Landmark Tower, Jl. Jend. Gatot Subroto No. 52, 51^st Floor, Jakarta 12710, Indonesia

(62) (22) 452-7101

(62) (21) 521-5109

(Name, Telephone, E-mail and/or Facsimile number and Address of Company Contact Person) 

Securities registered or to be registered pursuant to Section 12(b) of the Act.

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Securities registered or to be registered pursuant to Section 12(g) of the Act.

None

Securities for which there is a reporting obligation pursuant to Section 15(d) of the Act.

None

Indicate the number of outstanding shares of each of the issuer’s classes of capital or common stock as of the close of the period covered by the Annual Report:

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Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act.

Yes ☑ No ☐

If this report is an annual or transition report, indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934.

Yes ☐ No ☑

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the Registrant was required to file such reports) and (2) has been subject to such filing requirements for the past 90 days.

Yes ☑  No ☐

Indicate by check mark whether the registrant has submitted electronically every Interactive Data File required to be submitted pursuant to Rule 405 of Regulation S-T during the preceding 12 months (or for such shorter period that the registrant was required to submit such files).

Yes ☑ No ☐

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, or a non-accelerated filer. See definition of “accelerated filer and large accelerated filer” in Rule 12b-2 of the Exchange Act.:

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If an emerging growth company that prepares its financial statements in accordance with U.S. GAAP, indicate by check mark if the registrant has elected not to the extended transition period for complying with any new or revised financial accounting standard provided pursuant to Section 13(a) of the Exchange Act. ☐

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The term "new or revised financial accounting standard" refers to any update issued by the Financial Accounting Standards Board to its Accounting Standards Codification after April 5, 2012

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Indicate by check mark whether the registrant has filed a report on and attestation to its management’s assessment of the effectiveness of its internal control over financial reporting under Section 404(b) of the Sarbanes-Oxley Act (15 U.S.C. 7262(b)) by the registered public accounting firm that prepared or issued its audit report. ☑

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If securities are registered pursuant to Section 12(b) of the Act, indicate by check mark whether the financial statements of the registrant included in the filing reflect the correction of an error to previously issued financial statements. ☐

Indicate by check mark whether any of those error corrections are restatements that required a recovery analysis of incentive-based compensation received by any of the registrant’s executive officers during the relevant recovery period pursuant to §240.10D-1(b). ¨

Indicate by checkmark which basis of accounting the registrant has used to prepare the financial statements included in this filing:

U.S. GAAP ¨ International Financial Reporting Standards as issued by the International Accounting Standards Board R   Other ¨

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If “Other” has been checked in response to the previous question, indicate by checkmark which financial statement item the registrant has elected to follow.

Item 17 ☐ Item 18 ☐

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If this is an Annual Report, indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Exchange Act).

Yes ☐ No ☑

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*The Series B Shares were registered in connection with the registration of American Depositary Shares (“ADSs”). The Series B Shares are not listed for trading on the New York Stock Exchange

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TABLE OF CONTENTS

PART I

PART II

PART III

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DEFINITIONS

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3G

The generic term for third generation mobile telecommunications technology. 3G offers high speed connections to cellular phones and other mobile devices, enabling video conference and other applications requiring broadband connectivity to the internet.

3.5G

A grouping of disparate mobile telephony and data technologies designed to provide better performance than 3G systems, as an interim step towards deployment of full 4G/LTE capability.

4G/LTE

A fourth-generation super-fast internet network technology based on IP that makes the process of data transfer much faster and more stable than 3.5G.

5G

A fifth-generation of cellular mobile communications which targets high data rate, reduced latency, energy saving, cost reduction, higher system capacity and massive device connectivity.

5G Fixed Wireless Access Technology Roadmap

The strategic plan that outlines the deployment of 5G networks to provide high-speed, reliable wireless internet connectivity directly to homes and businesses.

A2P SMS

Application-to-Person SMS messaging, a process by which an SMS message is produced from an application and is sent to a mobile subscriber. Businesses can use it for communicating with consumers, authenticating users of online services, and/or delivering time-sensitive alerts. Typical examples of A2P SMS messaging include marketing and promotional messages (e.g., loyalty programs and marketing notifications) and confirmations and alerts (e.g., banking notifications, critical alerts, SMS-based two factor authentication, automatic booking confirmations and reminders).

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ADRs

American depositary receipts which, if issued, represents our ADSs.

ADSs

Our American depositary shares, which are certificates traded on the New York Stock Exchange. Each of our ADSs represents 100 shares of common stock.

AI

Artificial intelligence, intelligence demonstrated by machines, as opposed to intelligence of humans and other animals.

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APMK

Alat Pembayaran Menggunakan Kartu or card-based payment instruments, a payment instrument in the form of credit cards, ATM and/or debit cards.

ARPU

Average Revenue per User, a measure used primarily by telecommunications and networking companies which states how much revenue is generated by users on average during the relevant measurement period. It is defined as the total revenue from specified services divided by the number of users of such services.

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ATM

Automated Teller Machine.

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B2B

Business-to-business, arrangements and transactions between businesses.

B2C

Business-to-consumers, arrangements and transactions between businesses and consumers.

Backbone

The main telecommunications network consisting of transmission and switching facilities connecting several network access nodes. The transmission links between nodes and switching facilities include microwaves, submarine cables, satellites, fiber optic and other transmission technology.

Bandwidth

The capacity of a communication link.

Bapepam-LK

Badan Pengawas Pasar Modal dan Lembaga Keuangan, or the Indonesian Capital Market and Financial Institution Supervisory Agency, the predecessor to the OJK.

BI

Bank Indonesia, the central bank of the Republic of Indonesia.

Bitstream

A continuous sequence of binary digits, consisting of 1s and 0s, that represents a flow of data being transmitted or stored.

Broadband

A signaling method that includes or handles a relatively wide range (or band) of frequencies.

BRTI

The Badan Regulasi Telekomunikasi Indonesia, or Indonesian Telecommunications Regulatory Authority, a Government body in charge of regulating Indonesia’s telecommunications sector.

BTS

Base Transceiver Station, equipment that transmits and receives radio telephony signals to and from other telecommunications systems.

Business Competition Law

Law No. 5 of 1999 on Prohibition of Monopolistic Practice and Unfair Business Competition, as amended by the Job Creation Law 2023.

CDN

Content Delivery Network, a geographically distributed network of proxy servers and their data centers, which provides high availability and performance by distributing the service spatially relative to end-users.

CFU

Customer Facing Unit, an organizational unit similar to a strategic business unit that interacts with specific customer segments, has responsibility for their respective profit and loss, and which regroups subsidiaries and business portfolios relevant to the specific customer segments it is in charge of interacting with.

CLS

Cable Landing Station, a facility where submarine telecommunications cables land, connecting the underwater network infrastructure to the terrestrial networks, enabling data transmission between continents and countries.

Common stock

Our Series B Shares having a par value of Rp50 per share.

COVID-19

The global 2019 novel coronavirus and its variants.

Constitutional Court

Mahkamah Konstitusi or the Constitutional Court, the state institutions in Indonesia that exercises judicial power and has the primary role of reviewing the constitutionality of Laws.

CPaaS

Communications Platform-as-a-Service, a cloud-based platform that provides the ability to customers to add real-time communication features to their business applications. SMS, voice, or other messaging capabilities are features that can be added to such business applications.

CPE

Customer Premises Equipment, any handset, receiver, set-top box, or other equipment used by the consumer of wireless, fixed line or broadband services, which is the property of the network operator and located on the customer’s premises.

DCS

Digital Communication System, a cellular system using GSM technology operating in the 1.8 GHz frequency.

DBPP

Defined Benefit Pension Plan, a type of pension plan in which an employer promises a specified monthly benefit on retirement that is predetermined by a formula based on the employee’s earnings history, tenure of service and age,

rather than depending on investment returns. It is considered ‘defined’ in the sense that the formula for computing the retirement benefits is known in advance.

DCPP

Defined Contribution Pension Plan, a type of retirement plan in which the amount of the employer’s annual contribution is specified. Individual accounts are set up for participants and benefits are based on the amounts credited to these accounts (through the employer’s contributions and, if applicable, the employee’s contributions) plus any investment earnings on the money in the account. Only the employer’s contributions to the account, and not future benefits, are guaranteed. In defined contribution plans, future benefits fluctuate on the basis of investment earnings.

Deposit Agreement

The deposit agreement entered by and among our Company, the Depositary for our ADSs and all owners and beneficial owners, from time to time, of ADRs issued under that agreement, dated November 21, 1995, as amended and supplemented, from time to time.

Depositary

Bank of New York Mellon Corporation, which serves as the depositary for our ADSs under the terms of the Deposit Agreement.

DGPIO

The Director General of Post and Informatics Operations of the Republic of Indonesia, an official in MoCD who is responsible for overseeing and certifying the operations of postal services and information technology within Indonesia.

DGT

Directorate General of Taxes, a Government body under the Ministry of Finance of Indonesia that is responsible for developing taxation-related policies.

DTH

Direct-to-Home satellite broadcasting, the distribution of television signals from high-powered geostationary satellites to small dish antennas and satellite receivers in homes across the country.

Dwiwarna Share

The Series A Dwiwarna Share having a par value of Rp50 per share, which is held by the Government and provides special voting rights and veto rights over certain matters related to our corporate governance. For more information, see “Item 7. Major Shareholders and Related Party Transactions — Major Shareholders — Relationship with the Government and Government Agencies.”

E-Commerce

Electronic commerce, the buying and selling of products or services over electronic systems such as the internet and other computer networks.

E-Money

Electronic money, money or script that is only exchanged electronically.

E-KYC

Electronic Know your Client, a process by which a customer’s identity and address are verified electronically.

EDGE

Enhanced Data rates for GSM Evolution, a digital mobile phone technology that allows improved data transmission rates as a backward-compatible extension of GSM.

ESG

Environmental, Social and Governance.

EU

The European Union.

FANS

Fixed Access Network Sharing, a framework where multiple service providers share the same fixed network infrastructure to provide telecommunications services to end-users.

Fiber Optic

Cables using optical fiber and laser technology through which modulating light beams representing data are transmitted through thin filaments of glass, silica, or plastic.

Fintech

Products, services, and companies that employ or relate to digital and online technologies in the banking and financial services industries.

Fixed Line

Fixed wireline and fixed wireless.

Fixed Wireless

A local wireless transmission link using a cellular, microwave, or radio technology to connect customers at a fixed location to the local telephone exchange.

FLOU Cloud

Our cloud service, which is designed to support the digitalization of Indonesian startups, SMEs, enterprises, and government agencies.

FMC

Fixed-Mobile Convergence, a move in the telecommunications industry towards providing seamless connectivity by integrating fixed and wireless networks to deliver unified services to users.

FTTx

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Fiber To The x, a collective term used in telecommunications to describe various network architectures that use fiber optic cables to deliver high-speed internet and communication services to end-users. The “x” in FTTx represents the point at which the fiber optic connection ends in the network relative to the end-user. Common FTTx configurations include Fiber to the Home (“FTTH”) and Fiber to the Building/Business (“FTTB”).

Future State Architecture

A conceptual blueprint that represents an organization’s direction for technological development and transformation, planning the evolution of its systems to achieve strategic goals.

Gateway

A peripheral that bridges a packet-based network (IP) and a circuit-based network (PSTN).

Gb

Gigabit, a unit of information used, for example, to quantify computer memory or storage capacity.

Gbps

Gigabits per second, a measure of speed for digital signal transmission expressed in billions of bits per second passing between equipment in a data transmission system.

GHG

Greenhouse gases.

GHz

Gigahertz, a unit of measure of frequency equal to one billion cycles per second. The hertz (symbol Hz) is the international standard unit of frequency defined as the number of cycles per second of a periodic phenomenon.

GMS

General Meeting of Shareholders, which may be an annual general meeting of shareholders (“AGMS”) or an extraordinary general meeting of shareholders (“EGMS”).

GPON

Gigabyte-Passive Optical Network, the most widely deployed type of passive optical network system that brings fiber optic cabling and signals all or most of the way to end-users.

GPRS

General Packet Radio Service, a data packet switching technology that allows information to be sent and received across a mobile network and only utilizes the network when there is data to be sent.

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GraPARI

Telkomsel’s customer service centers in Indonesia.

GSM

Global System for Mobile Telecommunications, a European standard for digital cellular telephone.

HAP

High Altitude Platform, a system comprising various aerial vehicles, such as balloons or drones, situated in the stratosphere and used for communication and observation purposes.

ICT

Information and communications technology, an area concerned with information technology, telecommunications networking and services and other aspects of managing and processing information.

IDD

International Direct Dialing, a service that allows a subscriber to make an international call without the assistance or intervention of an operator from any telephone terminal.

IFRS

International Financial Reporting Standards, as issued by the International Accounting Standards Board (“IASB”).

IGG

Indonesia Global Gateway, a submarine fiber optic cable system covering several cities in Indonesia.

IMS

IP multimedia subsystem, a service which combines wireless and fixed line technologies for voice and data communications.

Indonesia Broadband Plan

A strategic initiative aimed at expanding and enhancing internet connectivity across Indonesia to foster economic growth and improve access to information.

Indonesia Cyber Core

The strategic framework and capabilities developed by the Government to safeguard Indonesia’s cyber space, aligning with national interests and political strategies.

Industry 4.0

The transformative phase in manufacturing that emphasizes automation, real-time data, interconnectivity, machine learning, and cyber-physical systems to create smart, interconnected production facilities.

Interconnection

The physical linking of a carrier’s network with equipment or facilities not belonging to that network.

IODN

Intelligent Optical Distribution Network, a pioneering technology that augments FTTH networks’ efficiency by integrating smart components such as eIDs and tools for the advanced management and operation of fiber optics, streamlining service provisioning and reducing manual errors.

IoT

The Internet of Things, infrastructure which interconnects physical and virtual things using interoperable information and communication technologies.

IP

The Internet Protocol, a set of communications protocols for exchanging data over the internet.

IP Core

A block of logic data that is used in making a field-programmable gate array or application-specific integrated circuit for a product.

IPTV

Internet Protocol Television, a system through which television services are delivered using the Internet Protocol suite over a packet-switched network such as the internet, instead of being delivered through traditional terrestrial, satellite signal, and cable television formats.

ISO

International Organization for Standardization, an independent, non-governmental international organization with a membership of 168 national standards bodies.

ISP

Internet Services Provider, an organization that provides access to the internet.

IT

Information Technology.

JATS

Jakarta Automated Trading System, an electronic system used by the Jakarta Stock Exchange to facilitate automated order matching for securities trading.

Job Creation Law 2023

Government Regulation in Lieu of Law of the Republic of Indonesia No. 2 of 2022 on Job Creation which (i) has been enacted into law on March 31, 2023 under Law of the Republic of Indonesia No. 6 of 2023, and (ii) revokes and replaces Law of the Republic of Indonesia No.11 of 2020 on Job Creation (the “Job Creation Law 2020”).

KPPU

Komisi Pengawasan Persaingan Usaha or Commission for the Supervision of Business Competition of the Republic of Indonesia.

KSO
 Kerja Sama Operasi or Joint Operations.

KSU
Koperasi Serba Usaha or Multi-Purpose Cooperative.

LAN

Local Area Network, a computer network that interconnects computers within a limited area such as a home, school, computer laboratory, office building, or closely positioned group of buildings.

Leased

A dedicated telecommunications transmissions line linking one fixed point to another, rented from an operator for exclusive use.

LoRa

From “long range,” a physical proprietary radio communication technique that is based on spread spectrum modulation techniques derived from chirp spread spectrum (CSS) technology.

LPWAN

Low-Power Wide-Area Network, a wireless telecommunications network technology designed for long-range communications at a low bit rate, optimally powering large-scale IoT deployments.

Mbps

Megabits per second, a measure of speed for digital signal transmission expressed in millions of bits per second passing between equipment in a data transmission system.

MEC

Multi-access Edge Computing, a network architecture that enhances cloud computing by bringing computational power, data storage, and services closer to the user right at the edge of the network.

Metro Ethernet

Bridge or relationship between locations that are apart geographically. This network connects LAN customers at several different locations.

MHz

Megahertz, a unit of measure of frequency equal to one million cycles per second. The hertz (symbol Hz) is the international standard unit of frequency defined as the number of cycles per second of a periodic phenomenon.

ML

Machine Learning, the technology that enables computers to learn and improve from data and experiences without being directly programmed to do so.

MMS

Multimedia Messaging Service, a standard way to send messages that include multimedia content, such as images, audio, video, and rich text, to and from mobile phones over a cellular network.

MNO

Mobile network operator, sometimes also known as a carrier service provider, mobile phone operator or mobile network carrier, which provides telecommunications services such as wireless voice and data communication to subscribed mobile users.

Mobile Broadband

The marketing term for wireless internet access through a portable modem, mobile phone, USB Wireless Modem, or other mobile devices.

MoCD

Kementerian Komunikasi dan Digital or the Ministry of Communication and Digital of the Republic of Indonesia (formerly known as the “Ministry of Communication and Informatics or “MoCI,”). effective as of October 2024). In this Form 20-F, any reference to MoCD refers to the same institution previously known as MoCI prior to the name change and encompasses the roles, functions, and authorities formerly held by MoCI.

MoF

The Ministry of Finance of the Republic of Indonesia.

MoL

Kementerian Hukum or the Ministry of Law of the Republic of Indonesia (formerly known as the Ministry of Law and Human Rights or “MoLHR”).

MOU

Memorandum of Understanding.

MSAN

Multi-Service Access Node, a network device typically installed in a telephone exchange that connects customers’ telephone lines to the core network, providing multiple services including telephone, ISDN, and broadband such as DSL all from a single platform, serving as the boundary between customer interfaces and the transport network.

MSME

Micro, Small and Medium Enterprise.

MSOE

Kementerian Badan Usaha Milik Negara or the Ministry of State-Owned Enterprises of the Republic of Indonesia.

Multi-Service Aggregation Networks

A network architecture that consolidates various network services, such as voice, data, and video, onto a single, scalable platform to optimize resource utilization and enhance service delivery.

MVA

Megavolt-amperes, the unit used to measure the apparent power in an electrical circuit.

MVNO

Mobile virtual network operator, a provider of telecommunications services such as voice and data communication to subscribed mobile users that does not own the wireless network infrastructure over which it provides its services.

NAP

Network Access Point, a key interchange for ISPs to connect and exchange traffic in a high-connectivity facility, which may also serve as a juncture for multiple carriers and content providers.

Neutra DC

Neutral Data Center facilities, specifically under Telkom Group’s NeutraDC brand in Singapore, offering colocation and cloud services.

Next Generation Network

A packet-based network able to provide multiple services, including telecommunications services, and to make use of multiple broadband and quality-of-service-enabled technologies, in which service-related functions are independent from underlying transport-related technologies. Such a network is able to handle multiple types of traffic (such as voice, data, and multimedia) by encapsulating these into packets, similar to how packets are transmitted over the internet.

NFV

Network Function Virtualization, a technology that decouples network functions, such as routing, load balancing, and firewalls, from proprietary hardware appliances, instead running these functions as software on standardized computing hardware.

NGSO satellite

Non-Geostationary Orbit satellite, satellite orbits where satellites are not stationary relative to the Earth’s surface but move across the sky, such as Low Earth Orbit (LEO), Medium Earth Orbit (MEO), and Highly Elliptical Orbit (HEO) satellites.

NIB

Nomor Induk Berusaha or Business Identification Number, a unique identifier issued by the government to all businesses operating in Indonesia through the Online Single Submission (OSS) system. It is 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.

NYSE

The New York Stock Exchange.

Open Cable Technology

Submarine cable systems that provide the purchaser or Internet Content Provider (“ICP”) with the flexibility to select their own Submarine Line Terminating Equipment (“SLTE”), instead of being limited to pre-installed hardware, which allows for greater freedom in network design and operation.

ONT

Optical Network Terminal, a device that converts fiber-optic signals into usable data formats (e.g., Ethernet) at the customer’s premises in a fiber-to-the-home (“FTTH”) setup.

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OJK

Otoritas Jasa Keuangan, or the Indonesian Financial Services Authority, the successor of Bapepam-LK, an independent institution with authority to regulate and supervise financial services activities in the banking sector, capital market sector as well as non-bank financial industry sector.

OSS

The Online Single Submission system, an integrated Government service platform designed to streamline business licensing and improve efficiency in regulatory compliance for companies in Indonesia.

OTT

Over The Top, a generic term commonly used to refer to the delivery of audio, video, and other media over the internet without the involvement of a multiple-system operator in the control or distribution of the content.

Pajak Bumi dan Bangunan

Land tax in Indonesia, also known as Pajak Bumi dan Bangunan (PBB), which is levied on land ownership and is a key component of Indonesia’s taxation system.

Pay TV

Pay Television, premium television, or premium channels, subscription-based television services, usually provided by both analog and digital cable and satellite, but also increasingly via digital terrestrial and internet television.

Point of presence

An access point, location or facility that connects to and helps other devices establish a connection with the internet, which may consist of a router, switches, servers, and other data communication devices. We operate two layers of points of presence, namely main and primary points of presence. A “main point of presence” is the transport backbone that aggregates national traffic. A “primary point of presence” is the aggregate regional transport backbone which has the capability of creating services.

PSTN

Public Switched Telephone Network, a telephone network operated and maintained by us that provides infrastructure and services for public telecommunications. Originally only an analog system, the PSTN is now almost entirely digital, even though most subscribers are connected via analog circuits. It now includes mobile phones in addition to fixed-line phones.

Radio frequency spectrum

The part of the electromagnetic spectrum corresponding to radio frequencies, (i.e., frequencies lower than around 300 GHz, or equivalently, wavelengths longer than about 1 millimeter).

Regional Business Unit

Our Company’s organizational units in the form of divisions that are formed on a geographical basis, and each of them is differentiated based on the regional scope of its operations.

Rich Communication Services

A communication protocol designed to enhance messaging with features like high-resolution media sharing, read receipts, and typing indicators, seeking to supersede traditional SMS and MMS standards.

RIO

Reference Interconnection Offer, a regulatory term covering all facilities, including interconnection tariffs, technical facilities and administrative issues offered by one telecommunications operator to other telecommunications operator for interconnection access.

SBC

Session Border Controller, a specialized device that secures and regulates SIP-based VoIP communications at network borders, ensuring call quality, integrity, interoperability, and efficient traffic management.

SBUJK

Sertifikat Badan Usaha Jasa Konstruksi, the construction services business entity certificate issued by the Indonesian Construction Services Development Institute (Lembaga Pengembangan Jasa Konstruksi), which is legally required for construction service companies that wish to participate in construction projects within Indonesia.

SCCS

Submarine Communications Cable System, a cable laid on the seabed between land-based stations to carry telecommunications signals across the ocean.

SDAN

Software Defined Access Network, the application of SDN principles to the access network, which connects end-users’ premises to the central network infrastructure of a service provider.

SDN

Software-Defined Networking, an architecture that dynamically manages networks programmatically, enabling centralized, flexible, and efficient control through abstraction of lower-level functionality.

SD-WAN

Software-defined Wide Area Network, an approach that uses software to deploy, operate and manage WAN architectures more easily and with increased connectivity.

SEA-US

Our fiber-optic submarine cable network connecting Southeast Asia (Indonesia and the Philippines) to the United States.

SEA-ME-WE-5

Our submarine fiber-optic communication cable system connecting Singapore to France and Italy through 17 countries.

Service node technologies

Essential components within a communications network infrastructure designed to manage data delivery, integrating various functionalities, and ensuring optimal service quality and efficiency.

SFU

Single Family Unit, a fiber-optic network solution or device designed specifically to provide broadband services to individual, standalone residential homes.

SIM Card

Subscriber Identity Module card, a microchip in a mobile phone that connects it to a particular phone network.

SLA calculations

Service Level Agreement calculations, monitoring and analyzing traffic across all segments and routes to ensure that network performance meets the agreed-upon targets.

SME

Small and Medium Enterprise.

SMS

Short Messaging Service, a technology allowing the exchange of text messages between mobile phones and between fixed wireless phones.

SOE

State-Owned Enterprise, a Government-owned corporation, state-owned company, state-owned entity, state enterprise, publicly owned corporation, Government business enterprise, or parastatal, a legal entity created by a Government to undertake commercial activities on behalf of a Government owner.

Softswitch

A central device in a telephone network that connects calls from one phone line to another, entirely by means of software running on a computer system. This work was formerly carried out by hardware, with physical switchboards to route the calls.

Switch

A mechanical, electrical or electronic device that opens or closes circuits, completes or breaks an electrical path, or selects paths or circuits, used to route traffic in a telecommunications network.

TDM

Time Division Multiplexing, a method of transmitting and receiving independent signals over a common signal path by means of synchronized switches that allow multiple data streams to share a single communication channel sequentially.

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Telecommunications BHP

Biaya Hak Penggunaan or right of use fee, a fee that mobile operators pay to the Government in connection with their use of radio frequencies for their network.

TIMES

Telecommunication, Information, Media, Edutainment and Service.

TPE

A normalized way to refer to transponder bandwidth, which means how many transponders would be used if the same total bandwidths used only 36 MHz transponder (1 TPE = 36 MHz).

Transponder

Radio relay equipment embedded in a satellite that receives signals from Earth and amplifies and transmits the signal back to the Earth.

uCPE

Universal Customer Premises Equipment, a flexible, general-purpose hardware device that runs multiple virtualized network functions (VNFs) like routing, firewalls, and SD-WAN on a single platform, replacing the need for dedicated hardware for each function.

UI/UX

User experience design, the process of defining the experience a user would go through when interacting with a company, its services, and its products.

USO

Universal Service Obligation, the service obligation imposed by the Government on all telecommunications services providers for the purpose of providing public services in Indonesia.

Voice-hubbing

A service provided by telecommunications operators that allows for the centralization and management of international voice traffic, offering access to mobile destinations worldwide.

VoIP

Voice over Internet Protocol, a means of sending voice information using the IP.

vCDN

Virtualized Content Delivery Network, an evolution of traditional CDN technology, leveraging virtualization to make CDN platforms more scalable, flexible, and easier to deploy and manage.

vSTB

Virtual Set-Top Box, a software-based solution that emulates the functionality of a physical set-top box, allowing users to access and manage video content and services over the internet without the need for dedicated hardware.

VPN

Virtual Private Network, a secure private network connection, built on top of publicly accessible infrastructure, such as the internet or the public telephone network. VPNs typically employ some combination of encryption, digital certificates, strong user authentication and access control to secure the traffic they carry. VPNs provide connectivity to many machines behind a gateway or firewall.

WAN

Wide Area Network, a collection of local-area networks (LANs) or other networks that communicate with one another.

XBRL

eXtensible Business Reporting Language, a freely available and global framework for exchanging business information.

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CERTAIN DEFINITIONS, CONVENTIONS AND GENERAL INFORMATION

Unless the context otherwise requires, the terms “Company,” “Telkom,” “Group,” “Telkom Group,” “we,” “us,” and “our” refers to Perusahaan Perseroan (Persero) PT Telekomunikasi Indonesia Tbk and its subsidiaries. “Indonesia” refers to the Republic of Indonesia. “Government,” except if stated otherwise, refers to the Government of the Republic of Indonesia. “United States,” “U.S.” or “US” refers to the United States of America. “United Kingdom” or the “UK” refers to the United Kingdom of Great Britain and Northern Ireland. “HK$” refers to the Hong Kong Dollar, the lawful currency of Hong Kong. “MYR” refers to the Malaysian Ringgit, the lawful currency of Malaysia. “Rupiah,” “Indonesian Rupiah” or “Rp” refers to the lawful currency of Indonesia. “SG$” refers to the Singapore Dollar, the lawful currency of Singapore. “U.S. Dollar” or “US$” refers to the lawful currency of the United States.

Our audited consolidated financial statements as of and for the years ended December 31, 2023 and 2024 included in this Form 20-F (the “Consolidated Financial Statements”) have been prepared in accordance with International Financial Reporting Standards (“IFRS”) as issued by the International Accounting Standards Board (“IASB”).

Solely for the convenience of the reader, certain Indonesian Rupiah amounts have been converted into U.S. Dollars at the rate of Rp16,095.0 to US$1.00 for December 31, 2024 and Rp15,398.5 to US$1.00 for December 31, 2023 based on the middle exchange rate which is calculated based on the Reuters Refinitiv buying and selling rates. The Federal Reserve Bank of New York does not certify for customs purposes a noon buying rate for cable transfers in Indonesian Rupiah. No representation is made that the Indonesian Rupiah or U.S. Dollar amounts shown herein could have been or could be converted into U.S. Dollars or Indonesian Rupiah, as the case may be, at any particular rate or at all.

Certain numerical figures set out herein, including financial data, have been subject to rounding adjustments and, as a result, the totals of the data disclosed herein may vary slightly from the actual arithmetic totals of such information. Percentages and amounts reflecting changes over time periods relating to financial and other data under “Item 5. Operating and Financial Review and Prospects” are calculated using the rounded numerical data in the narrative description under “Item 5. Operating and Financial Review and Prospects” and not the numerical data in our Consolidated Financial Statements.

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FORWARD-LOOKING STATEMENTS

This Form 20-F contains “forward-looking statements” as defined in Section 27A of the U.S. Securities Act of 1933, as amended (the “Securities Act”) and Section 21E of the U.S. Securities Exchange Act of 1934, as amended (the “Exchange Act”), within the meaning of the Private Securities Litigation Reform Act of 1995, including statements regarding our current expectations and projections for our future operating performance, business prospects and events. The words “may,” “will,” “believe,” “expect,” “anticipate,” “aim,” “seek,” “intend,” “plan,” “likely to,” “potential,” “estimate,” “project,” “continue” and similar words or expressions identify forward-looking statements. We have based these forward-looking statements largely on our current expectations and projections of future events that we believe may affect our financial condition, results of operations, business strategy and financial needs.

These forward-looking statements include, but are not limited to, statements about:  

In addition, all statements other than statements of historical facts included in this Form 20-F that address activities, events, or developments which we expect or anticipate will or may occur in the future are hereby identified as forward-looking statements for the purpose of the safe harbor provided by Section 27A of the Securities Act and Section 21E of the Exchange Act. Although we believe that the expectations reflected in the forward-looking statements herein are reasonable, such expectations may prove to be incorrect. These forward-looking statements are subject to a number of risks and uncertainties, including changes in the economic, social, and political environments in Indonesia. This Form 20-F discloses, under “Item 3D — Risk Factors” and elsewhere, important factors that could cause actual results to differ materially from our expectations.

The forward-looking statements made in this Form 20-F relate only to events or information as of the date on which the statements are made herein. Except as required by law, we undertake no obligation to update or revise publicly any forward-looking statements, whether as a result of new information, future events or otherwise, after the date on which the statements are made or to reflect the occurrence of unanticipated events. You should read this Form 20-F and the documents that we refer to herein completely and with the understanding that our actual future results may be materially different from what we expect.

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PART I

ITEM 1.              IDENTITY OF DIRECTORS, SENIOR MANAGEMENT AND ADVISORS

Not applicable.

ITEM 2.              OFFER STATISTICS AND EXPECTED TIMETABLE

Not applicable.

ITEM 3.              KEY INFORMATION

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B.           CAPITALIZATION AND INDEBTEDNESS

Not applicable.

C.           REASON FOR THE OFFER AND USE OF PROCEEDS

Not applicable.

D.           RISK FACTORS

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.

Summary of Risk Factors:

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Risks Related to Our Business

Operational Risks

Risks Related to our Fixed and Cellular Telecommunications Business

Financial Risks

Legal and Compliance Risks

Regulatory Risks

Risks Related to the Development of New Businesses and Acquisitions

Risks Related to our Corporate Structure

Risks Related to Indonesia

Political and Social Risks

Macroeconomic Risks

Risks related to Natural Disasters and Climate Change

Risks related to our ADSs

Risks Related to Our Business

Operational Risks

A material failure in the continuing operations of our network, certain key systems, gateways to our network or the networks of other network operators could materially and adversely affect our business, financial condition, results of operations and prospects.

We 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 network and 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 an internet and broadband network and a cellular network, 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 also 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. We also depend on certain technologically sophisticated management information systems and other systems, such as our customer billing system, to enable us to conduct our operations.

Our network infrastructure and connected systems, including our information systems, IT and infrastructure and the networks of other operators with whom our subscribers are interconnected, 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. Past incidents have demonstrated our susceptibility to such damage or interruptions in operation. In 2022, we faced interruptions to some submarine cable communication systems as a result of damage from flood, earthquakes, a ship’s anchor and fishing equipment, among other things. As a result, services in east Indonesia were disrupted as we had to redirect affected traffic through satellites until the submarine cables could be restored. 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 provide continuous service but also strain our resources during recovery efforts.

More extensive infrastructure damage could severely hamper service provision across our operations, and our business continuity plan and disaster recovery plan may not fully protect us from damage or interruptions to our operations. Any failure that results in an interruption of our operations or of the provision of any service, whether from operational disruption, natural disaster or otherwise, could adversely and materially affect our business, financial condition, results of operations and prospects.

The rapid pace of technological change in the telecommunications industry may adversely affect our ability to remain competitive if we cannot successfully integrate new innovations.

We are selectively deploying 5G while considering ecosystem readiness, which includes spectrum availability—crucial for coverage and quality—5G handset penetration, and the development of 5G use cases. Our development of 5G services in 2024 included the expansion of the Hyper 5G network primarily in Bali and Greater Jakarta, along with the launch of 5G use cases. As of December 31, 2024 our 5G services covered 56 cities across Indonesia, with an additional 321 5G BTS, bringing the total to 975 5G BTS. However, emerging technologies such as 5G and future development or application of new or alternative technologies, services or standards could require substantial investments and significant changes to our business model in order for us to remain competitive, as new products and services may be expensive to develop and may result in the introduction of additional competitors into the marketplace. We cannot accurately predict how emerging and future technological changes will affect our operations or the competitiveness of our services. Furthermore, we may not succeed in effectively integrating new technologies into our existing business model. For instance, if our rollout of 5G may not meet expectations for customer adoption or return on investment in terms of magnitude and/or timeline, it may negatively impact our financial condition and results of operations.

One of the main challenges faced by the telecommunications industry in Indonesia is the increasing use of OTT services that have become substitutes for voice and SMS services, in line with the growing number of smartphone users. This has affected the contribution from cellular phone services to our consolidated revenues, which has continued to decline from 8.2% in 2022 to 5.5% in 2023 and 4.2% in 2024, computed as a percentage of our consolidated revenues for the fiscal years ended December 31, 2022, 2023, and 2024, respectively.

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Moreover, we face ongoing risks of losing market share to new market entrants such as operators and service providers (including non-telecommunications players and OTT players) who utilize newer or lower cost technologies. In particular, the rapid development of new technologies, services, products, and business models has reduced the distinctions in barriers to entry for the provision of local, long distance, wireless, cable and internet communication services and has attracted new competitors into the telecommunications market. For example, the planned entry of Starlink, with its ‘Direct to Cell’ service, could result in the adoption of competitive pricing strategies that could negatively impact our market share. Additionally, the increased availability of high-throughput satellite capacity in Indonesia has already intensified competition and placed downward pressure on pricing in our satellite operations. A loss of market share could have a material and adverse effect on our business, prospects, financial condition, and results of operations.

We may also be unable to sufficiently utilize big data and integrate this into our operations. Digital businesses especially benefit from significant data analyses, and we may not be able to innovate as fast as other competitors in this and other areas. As a result, we may fail to successfully transition our existing business models to take advantage of new technologies such as big data analytics and to develop new technologies and services that customers demand.

In addition, the rapid development and deployment of AI technologies have the potential to significantly alter traffic patterns within our networks in the future. While we are not currently experiencing such shifts, AI-driven applications and services may generate unprecedented increases in data transmission and utilization, requiring us to reengineer our network topology. Such modifications could necessitate substantial investments in our infrastructure and systems, subsequently increasing our operational costs. Moreover, these changes may not be accompanied by proportional revenue growth, as consumers and enterprises increasingly adopt AI innovations that rely on high-speed, low-latency networks but do not necessarily provide additional revenue streams for telecommunications operators. If we fail to

anticipate and effectively manage these potential impacts, AI-driven trends could materially and adversely affect our profit margins, financial condition, and overall market competitiveness.

Our technologies could become obsolete, or be subject to competition from new technologies in the future, and we may not be able to acquire new technologies necessary to maintain or increase our competitiveness on commercially acceptable terms, or in a timely fashion. Our failure to react to rapid technological changes could materially and adversely affect our business, financial condition, results of operations and prospects.

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.

Government regulations require telecommunications service providers with passive telecommunications infrastructure (e.g., ducts, towers, poles, or communication manholes, among other things) to give access to such passive telecommunications infrastructure to other telecommunications providers. These regulations require that use of passive telecommunications infrastructure must be based on cooperation and mutual agreements between telecommunications service providers in a fair, reasonable and non-discriminative manner. Further, a telecommunications service provider with active telecommunications and/or broadcasting infrastructure may be mandated to give access to such active infrastructure to other telecommunications providers as mutually agreed and in furtherance of fair business competition. This may involve the leasing of network capacity to other telecommunications providers.

It remains to be seen how these provisions will affect our business and our relations with other telecommunications players in Indonesia. It is possible for the Government to adopt more implementing terms in the future that we may not consider to be commercially reasonable. For example, subsequent or implementing regulations may not allow us to charge competitors who lease our network capacity fees at rates that we will consider to be commercially acceptable. If such regulations were to be implemented, being mandated to share infrastructure and lease capacity at such rates could have a material adverse effect on our revenue, financial condition, results of operations and prospects.

Revenue 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.

We 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 cell 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.

Expected benefits from partnerships with global technology companies may not be achieved.

We partner and collaborate with global technology companies such as Microsoft and Amazon Web Services 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.

However, 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.

As 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.

Delays 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.

Ultimately, 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.

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.

Our networks and equipment, particularly our wireline access network, face both potential physical and cybersecurity threats. Physical incidents or threats include 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.

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, corrupt our data or disrupt 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.

We 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 which 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.

A 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. For example, in August 2022, a hacker leaked what they claimed was personal data from millions of IndiHome users. While our subsequent internal investigation determined that this data was fabricated, we may face reputational damage even from false leaks. Further, since the COVID-19 pandemic we have experienced increased online and remote activities, including from our employees and service providers, which has increased our exposure to cybersecurity risk. In 2024, we detected 699.2 million cyber threats on our servers, showing an increase from 2023, where 65.9 million cyber threats were detected.

Although almost all of the cybersecurity threats were non-disruptive and none of them rose to the level of requiring us to specifically address them, techniques that computer hackers and others use to access or sabotage networks and computer systems constantly evolve and generally are 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, and 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.

Cybersecurity breaches could expose us to significant legal, financial, and reputational consequences. Due to applicable laws, regulations and contractual obligations, we may be held responsible for cybersecurity breaches, attacks or other similar incidents, and we may be subject to additional regulatory scrutiny and exposed to civil litigation, fines, damages and injunctions.

A successful cyber-attack 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, new cybersecurity due diligence procedures and training to prevent future similar attacks and lost revenues and litigation costs due to misused sensitive information, liabilities for information loss, breaches of confidentiality of private information, 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. Cyber-attacks may also cause equipment failures, loss of information, including sensitive information or information stored in our customers’ computer systems and mobile phone systems, 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, shareholders or law enforcement agencies following any such event, as well as disruption to our operations or our customers’ operations. Even a false claim that we were the victim of a cyber-attack may be detrimental to our reputation, and we may face attempts to blackmail us over allegedly or actually stolen data and through ransomware attacks.

Furthermore, 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 cybersecurity 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.

Damage to our network, equipment or data and the need to repair such damage resulting from a physical or cyber-attack may 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.

Damage to our reputation could negatively impact our business, financial condition and results of operations.

Our reputation is a critical factor in our relationships with customers, employees, the Government, other state-owned enterprises, suppliers and other stakeholders. Incidents involving any of the quality of our products and services, security, or safety issues, allegations of unethical behavior or misconduct or 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, the conduct of our partners or representatives, and other issues or incidents that, whether actual or perceived, may result in adverse publicity and be detrimental to our reputation. In addition, we are subject to corporate governance laws and regulations as well as corruption risks. We are committed to combating corruption such that our operations are conducted in accordance with applicable anti-corruption laws and record- keeping requirements, and to minimize the risk of potential violations, our management systems include a Corporate Code of Conduct, as well as other specific guidelines, policies and directives designed to minimize and detect potential violations of such laws and requirements in our operations in a timely manner. However, there is no assurance that all of our employees, consultants, agents or partners will follow at all times our Code of Conduct and such guidelines, policies and directives, or that our management systems can fully prevent violations of anti-corruption laws and record-

keeping requirements or will effectively detect any such violation in a timely manner. There is also an increased demand from external stakeholders, for example non-governmental organizations and investors, on transparency and corporate responsibility issues that may be difficult to fulfill.

We have received requests for information and documents from authorities in the United States and Indonesia regarding compliance with anti-corruption and accounting laws and regulations in these jurisdictions and we have engaged outside counsel to assist in responding to these requests.  While we are fully committed to cooperating with the U.S. and Indonesian authorities and continue to respond to their requests, we cannot predict the duration and outcome of those requests.

In addition, if we fail to respond quickly and effectively to address such incidents or requests, we may receive negative publicity, which could harm our reputation and subject us to enforcement actions and/or legal proceedings, sanctions, fines or penalties, compliance conditions or other restrictions. Moreover, we may incur substantial costs in connection with requests from authorities, regardless of the outcome of any on-going investigations. Damage to our reputation could harm customer relations, reduce demand for our services and products, reduce investor confidence in us, and may also damage our ability to compete for customers and highly skilled employees. Any of the foregoing risks and uncertainties could have material adverse effects on our business, operating results, financial condition, reputation, and brand.

We 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.

In addition to cybersecurity threats, since we provide connections to the internet and host websites for customers and develop internet content and applications, 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 2024, with instances of spam generation and subsequent blacklisting continuing to occur. Measures we have in place, such as administrative and technical preventative measures to identify and combat spam, may not always be effective and we could also be placed on certain IP blacklists again in the future.

In 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.

Expected benefits from investment in new networks and technologies may not be realized.

We may pursue new growth opportunities in the communications industry in the future, 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.

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.

Further, 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 “— Risks Related to Our Business — ­The rapid pace of technological change in the telecommunications industry may adversely affect our ability to remain competitive if we cannot successfully integrate new innovations” and “— Risks Related to Our Business — We may be unable to fund the capital expenditures needed for us to remain competitive in the telecommunications industry in Indonesia.”

Furthermore, 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.

We rely on third parties to supply and maintain our network infrastructure, and they may be difficult to replace.

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We 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. Our business could be materially impacted by disruptions to our key suppliers’ businesses or supply chains due to factors such as significant geopolitical events, changes in law or regulation, the introduction of restrictions to curb epidemics or pandemics, as seen during the COVID-19 pandemic, trade tensions and direct or indirect export and re-export restrictions. We may experience difficulty in replacing a number of our suppliers in the event that they fail to supply us with the components and/or equipment we require. Failure to obtain adequate supplies or services in a timely manner or on commercially acceptable terms or at all may result in significant increases to the cost of our supplies or services or in our inability to maintain and to expand our mobile network, any of which may have a material and adverse effect on our business, prospects, financial condition and results of operations.

Further, the ability of certain suppliers such as Huawei to ensure the supply of equipment or services provided to us or any entity in our supply chain may be impaired as a result of sanctions imposed on such manufacturers. For instance, the United States Department of Commerce added Huawei and certain of its affiliates to its “Entity List,” which prohibits companies globally from directly or indirectly exporting, re-exporting or transferring items subject to U.S. export control jurisdiction to Huawei without authorization and procuring items from Huawei when the companies know or have reason to know that the items were originally procured by Huawei in violation of U.S. export control regulations. If the supply of items we source from Huawei were disrupted by such restrictions, and if we were unable to source similar equipment from other suppliers in a timely fashion and at commercially acceptable conditions, it could negatively impact our operations and prospects. New sanctions, the concerns of customers and business partners, reputational and other reasons could require us to reevaluate our existing supply chains.

Additionally, global supply chain disruptions caused by geopolitical conflicts, such as the conflict in Ukraine, have impacted the supply of critical components, including semiconductors, which are essential for the equipment and devices required for our network infrastructure. The conflict has disrupted the supply of raw materials vital for semiconductor manufacturing, such as neon gas—of which Ukraine was a major global producer before the conflict—and palladium, of which Russia is a leading global supplier, thereby worsening the global chip supply crisis. This disruption has also affected semiconductor production capacity, resulting in the undersupply of chips. Consequently, these supply chain challenges have delayed the expansion of our data center capacity, including delays in the development of our Cikarang data center in 2023. Should these disruptions persist, they could continue to hinder our ability to acquire necessary components for maintaining and upgrading our network infrastructure, including the rollout of 5G technologies, potentially resulting in higher costs, extended project timelines, and possible service interruptions, which may negatively impact our operational performance, financial condition, and competitive position.

Difficulty in receiving equipment or services from existing suppliers could require us to find alternative suppliers, which may lead to an increase in our costs or otherwise affect or delay the development and maintenance of our increasingly advanced network infrastructure and negatively affect our operations and financial position.

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.

We 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.

We 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.

Actual or perceived health risks or other problems relating to radio emissions could lead to litigation or decreased mobile communications usage.

The 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.

The 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.

These factors could have a material adverse effect on our business, prospects, and financial condition.

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.

Health 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.

Governmental 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 duration 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.

Risks Related to our Fixed and Cellular Telecommunications Business

Competition from other cellular service providers may adversely affect our cellular services business.

The Indonesian cellular service business is highly competitive. Competitors continue to make long-term investments to improve network quality and coverage, expand services and enhance customer experience. In recent years, competitors have used promotional strategies such as offering bonus data packages, which have reduced profitability in the Indonesian market. In 2024, however, the cellular industry saw a trend of gradually raising prices after a period of declines during the COVID-19 pandemic. It is uncertain whether this trend of increasing prices will continue, however, as companies balance long-term profitability with competitive pricing pressures. Further, our ability to compete on price may be limited for certain services. The Job Creation Law 2023 allows the Government to determine upper and lower price limits based on public interest and fair business competition principles, and MoCD Regulation No. 5 of 2021 on Telecommunications Operation (“MoCD Regulation No. 5/2021”) also stipulates that implementation of the upper and/or lower limit tariff must be preceded by evaluation by MoCD of factors such as market conditions, cost analysis, public interest, financial performance of our Company, and the continuity of such services. Upper limits may be determined in areas where only one telecommunications operator operates, and lower limits may be determined based on the Government’s assessment of prevailing market conditions.

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Competition is growing, particularly from OTT providers, as more customers switch from legacy communications to data services. With major urban markets becoming saturated, several cellular companies have expanded coverage and product offerings outside Java, prompting Telkomsel to focus on defending its market share in such regions. Additionally, we are facing increased competition by non-market leader competitors who continue to target specific customer segments.

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In addition, we face competition from Starlink, a satellite-based broadband service from SpaceX (“Starlink”). Starlink has officially begun offering direct satellite broadband access to retail customers in Indonesia after receiving approval from MoCD in April 2024 to offer such services. This development may lead to heightened competition in the retail broadband sector moving forward. The limitations of satellite-based services, particularly their reduced effectiveness in urban areas due to signal obstructions, could impact Starlink’s competitiveness. Nonetheless, Starlink’s Direct-to-Cell service, which is in its trial phase as of the date hereof, poses a significant threat as it has the potential to compete directly with existing cellular services and could replace traditional cellular networks, especially in rural or open areas where direct satellite connectivity is more feasible.

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As Indonesia’s first 5G operator, Telkomsel anticipates increased competition in the rollout of 5G services, including bidding for spectrum allocation and investment in and deployment of 5G infrastructure. Our 5G strategy increasingly involves IoT solutions, which is mostly enabled by 5G technologies, but customer adoption may not meet expectations. Further, limited or unavailable spectrum at suitable prices would negatively impact our 5G deployment strategy and prospects, which could have a material and adverse effect on our business, results of operations and financial condition.

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Consolidation in our industry could negatively impact our competitive position and business. Competitors with wider spectrum access and integrated networks may expand coverage. For instance, in January 2022, CK Hutchison and Qatar’s Ooredoo merged their respective telecommunications businesses in Indonesia, PT Hutchison 3 Indonesia and PT Indosat Tbk. (“Indosat”), forming Indosat Ooredoo Hutchison (“IOH”). Furthermore, in 2024, merger plans were announced between PT XL Axiata Tbk and PT Smartfren Telecom Tbk. Such consolidations in the telecommunications industry align with the Government’s goal under the Job Creation Law 2023 of making this sector more efficient by

encouraging fewer, larger market players. As competition intensifies, further consolidation among cellular providers may occur, driven by competitive factors as well as efforts to reduce operating costs and obtain wider spectrum allocation to expand their integrated network coverage. Spectrum refarming has provided wider allocations, enabling competitors such as Indosat to improve service quality and network capacity. However, additional competitor consolidation may adversely affect our competitive position in the market and our business, results of operations, financial condition, and prospects.

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Furthermore, Government regulations have required cellular providers to share infrastructure and capacity with competitors. According to the Job Creation Law 2023, which is implemented by MoCD Regulation No. 5/2021, telecommunications operators are required to grant access for the utilization of passive infrastructure for telecommunications purposes to other telecommunications providers on a B2B basis. MoCD Regulation No. 5 of 2021 on Telecommunications Operators (“MoCD Regulation No. 5/2021”) prohibits owners of passive infrastructure from restricting access to its utilization (for example, by reserving the passive infrastructure for services of greater public interest). Additionally, MoCD Regulation No. 5/2021 establishes conditions for the imposition of tariffs for the utilization of passive infrastructure by owners of such infrastructure, and grants MoCD the authority to determine such tariffs if owners of passive infrastructure fail to meet the conditions for tariff imposition. See “— Risk Factors — Risks Related to Our Business — Operational Risks — 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.” As the operator with the most extensive infrastructure in Indonesia, mandated sharing not on commercial terms could allow competitors to take advantage of our existing infrastructure without significant capital expenditure, which would have a significant impact on our competitive position.

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Any of these developments combined with intensifying market competition and regulatory challenges,  may present challenges for Telkomsel in maintaining its market position and could materially and adversely affect our results of operations, financial condition and prospects.

Our data and internet services are facing increasing competition, and we may experience declining margins and/or market share from such services as such competition intensifies.

Our data and internet services are facing increasing competition from other data and internet operators, including mobile operators. The number of mobile broadband subscribers has increased with the increasing number of smartphones in Indonesia, which adversely affects our market share and revenues from our fixed wireline data and internet services. Certain geographical markets have become increasingly saturated, such as in major cities in Indonesia.

In addition, with the increasing number of smartphones in Indonesia, data and internet services have become an intense area of competition in our industry. Certain of our smaller competitors increasingly focus on specific market segments, such as the gamer segment or entertainment segment, and develop flanking marketing strategies that may erode our market share in specific market segments. Competition may further intensify in the future, which may affect our market share as well as the financial performance of our data and internet services and thus materially and adversely affect our results of operations, financial condition and prospects as a whole.

Cellular network congestion and limited spectrum availability could limit our cellular subscriber growth and cause reductions in our cellular service quality.

We expect our spectrum needs to continue to increase in the future in line with increased usage of our network, in particular with the increased use of data services as the internet becomes increasingly necessary for achieving productivity gains. As a result, we will need to acquire additional spectrum allocations through Government auctions to accommodate future traffic growth and support our business. The Government occasionally conducts auctions for unused spectrum allocation, such as the auction we won for 5 MHz spectrum in the 2.1 GHz frequency band in November 2022. We seek to obtain as much of the available spectrum as we expect to need for our operations. However, this is a scarce resource and allocations are subject to regulatory factors which may change over time (such as auction rules) and other considerations. As a result, we may not always be in a position to secure spectrum allocations that are consistent with our expectations or strategic objectives. If we are not able to obtain sufficient spectrum, we may be unable to maintain our ideal utilization level, may face network congestion, and may be unable to support the deployment of new technologies, all of which could affect our network performance and damage our reputation with our subscribers.

Moreover, the increase in the number and use of smartphone applications that rely on data services has resulted in the significant amount of data traffic and cellular network congestion. To support such additional demands on our network, we have been and may in the future be required to make significant capital expenditures to improve our network coverage, such as by investing in our BTS and securing additional spectrum. Such additional capital expenditures, together with the possible degradation of our cellular services due to potential network congestion and limited spectrum availability, could materially and adversely affect our competitive position, results of operations, financial condition and prospects.

Continuing 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.

Telecommunications 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.

If 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.

Our 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.

We regularly review our infrastructure network’s capabilities, advantages, and available capacity, and continue to make substantial investments in the development of our infrastructure network, including our 4G/LTE and 5G infrastructure, to carry increasing volumes of data traffic.

The COVID-19 pandemic had an impact on consumption habits with more people working and studying from home, which positively impacted data traffic and shifted traffic from business districts to residential areas. We 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.

As 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 construction of our infrastructure network, including our 4G/LTE infrastructure as well as 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.

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.

Government, through the MSOE, owns the Dwiwarna Share, which carries special rights to exercise certain reserved powers. In addition, as of March 31, 2025, our direct majority shareholder, PT Biro Klasifikasi Indonesia (Persero) (“BKI”) as a state-owned enterprise (“SOE”) wholly owned by the Republic of Indonesia that has been assigned to oversee operational activities of SOEs as well as other business activities (an “Operational Holding”), is directly controlled by the Daya Anagata Nusantara Investment Management Agency (Badan Pengelola Investasi Daya Anagata Nusantara or “BPI Danantara”) and indirectly by the Government through BPI Danantara. Consequently , the Government effectively controls the outcome of matters requiring the vote of our shareholders, including the composition of our boards of Directors and Commissioners, and determining the timing and amount of dividend payments. The Government has historically influenced, and is likely to continue to influence, our strategy and operations.In addition, the Government owns a Dwiwarna Share in our Company which gives the Government, represented by the MSOE, certain rights such as the right to veto with regards to the nomination, appointment and removal of our Directors and Commissioners, the issuance of new shares and any amendments to our articles of association (the “Articles of Association”). The rights of the Government attached to this Dwiwarna Share limit the ability of public shareholders to influence certain matters relating to our Company. Under our Articles of Association, the Government cannot transfer the Dwiwarna Share. The Government’s rights with respect to the Dwiwarna Share will not terminate unless our Articles of Association are amended, which would require the approval of the Government as holder of the Dwiwarna Share. See also “Item 7. Major Shareholders and Related Party Transactions — Relationship with the Government and Government Agencies — The Government as Shareholder.”

The Government may not always exercise its control and influence to our benefit and its interests may not necessarily be aligned with those of our other shareholders. For example, the Government may request us to enter into transactions which are not in our best interests. In addition, we may never become independent of our Government shareholder or even if we do become independent, we may not be able to exercise such independence effectively in making decisions concerning our business and prospects, including decisions concerning compensation from the Government when we act in the public interest. If we agree to act in the public interest and are not adequately compensated by the Government, our business, prospects, financial condition, liquidity and results of operations may be materially and adversely affected, which would limit our ability to compete effectively and expand 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.

During the course of documenting and testing our internal controls and procedures, we may identify deficiencies and material weaknesses in our internal control over financial reporting. A material weakness in internal control over financial reporting is a deficiency, or a combination of deficiencies, in internal control over financial reporting, such that there is a reasonable possibility that a material misstatement of our annual or interim financial statements will not be prevented or detected on a timely basis by our internal controls. We regularly implement additional procedures and controls designed to strengthen our internal control systems and/or remedy deficiencies, including enhanced control over procurement, contract and project management, additional internal approval requirements before selecting or transacting with new partners, customers and suppliers, and improved segregation of duties and functions, but if we are unable to achieve and maintain an effective internal control environment, we could suffer material misstatements in our financial statements and fail to meet our reporting obligations, which would likely cause investors to lose confidence in our reported financial information. This could in turn limit our access to capital markets, harm our results of operations, and lead to a decline in the trading price of our securities. Additionally, ineffective internal control over financial reporting could expose us to increased risk of fraud or misuse of corporate assets and subject us to potential delisting from the stock exchanges on which we list, regulatory investigations and civil or criminal sanctions.

Moreover, even if our management concludes that our internal control over financial reporting is effective, our independent registered public accounting firm, after conducting its own independent testing, may issue a report that is qualified 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.

Deterioration of the financial condition of our customers could adversely affect our operating results.

Deterioration of the financial condition of our enterprise customers and/or of our subscribers has and may continue to adversely impact our collection of accounts receivable and may also result in fewer purchases or delays in purchases of our products and services. Challenging 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.

For the years ended December 31, 2023 and 2024, our total trade and other receivables, net of allowance for expected credit losses were Rp10,948 billion and Rp12,829 billion, 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 Rp6,064 billion as of December 31, 2024, representing an increase by approximately 8.5% compared to our allowance for expected credit losses as of December 31, 2023. Otherwise, the written-off uncollectible accounts in 2024 decreased by 30.3%, from Rp575 billion in 2023 to Rp401 billion in 2024. We believe that the allowance for expected credit losses of trade receivables is adequate to cover losses on uncollectible accounts. If our uncollectible accounts, however, were to exceed our current or future allowance for credit losses, our operating results would be negatively impacted.

Further, 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 adversely affect our financial condition and operating results.

We are exposed to interest rate risk in relation to our bank borrowings.

Our 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, 2024, approximately 37.4% (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.

Worldwide 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 economy, Bank Indonesia (“BI”) has adjusted interest rates several times in recent years. In February 2021, the BI benchmark seven-day (reverse) repo rate hit a historic low of 3.50% annually. As of March 6, 2025, this rate stood at 3.75%. More recently, inflation has eased and interest rates have decreased in certain economies, such as in the United States and in the European Union. Despite expectations of further decreases in interest rates, the pace of such decreases and their magnitude could be lower than anticipated. Lower than anticipated interest rate decreases, or new interest rate hikes may keep financial expenses at higher level than we anticipate or escalate financial expenses linked to floating rate loans, potentially adversely affecting our financial performance.

We may be unable to fund the capital expenditures needed for us to remain competitive in the telecommunications industry in Indonesia.

The 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, 2022, 2023 and 2024, our consolidated capital expenditures totaled Rp34,146 billion, Rp32,858 billion and Rp24,436 billion (US$1,519 million), respectively. Our capital expenditure in 2024 was driven by the expansion of our subsidiaries’ business operations. Key initiatives undertaken in 2024 included network quality improvements, expansions of network coverage and FMC integration by Telkomsel, the launch of Telkom Merah Putih-2, a high-throughput satellite at the 113 East orbital slot by Telkomsat to promote the availability of connectivity and network reliability throughout the terrestrial and marine areas of Indonesia, the development of an international submarine cable system by Telin, and the establishment of HyperScale data centers in Batam and Cikarang by PT Telkom Data Ekosistem (“TDE”).

Our 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.

Accordingly, 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.

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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.

We are subject to numerous risks relating to legal and regulatory proceedings and government investigations in which we are currently a party, or which could develop in the future. We cannot provide any assurance about the outcome of any such legal or regulatory proceedings, which may have a material adverse effect on our reputation, business, results of operations or financial condition.

In October 2023, the Company received a document request from the U.S. Securities and Exchange Commission (“SEC”) as it relates to Telkom Infra’s involvement in a project with the Indonesian Information and Telecommunication Accessibility Agency of the Ministry of Communication and Information (“BAKTI Kominfo”) regarding the provision of 4G Base Transceiver Station (“BTS”) infrastructure. The SEC has since expanded its investigation to include accounting and disclosures issues relating to our revenue recognition and financial reporting practices and internal control over financial reporting, 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, the Company also received additional requests for information from the U.S. Department of Justice (“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. The Company is cooperating with the U.S. authorities and has retained outside counsel to conduct an internal investigation into these issues. The Company cannot predict the duration, outcome or impact of these investigations on our business or whether they will have a material impact on the Company's audited consolidated financial statements. Furthermore, in 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 the DOJ’s enforcement of the FCPA for 180 days (which period can be renewed an additional 180 days) until the U.S. Attorney General issues revised FCPA enforcement guidance. Due to the changing nature of and uncertainties related to the regulatory environment, we cannot be certain if or how the DOJ’s enforcement of the FCPA will change or its impact on the outcome of the DOJ’s investigations on our business. It is additionally uncertain whether our Company, affiliates, employees, agents, or contractors would meet the requirements of any individualized exception to the FCPA enforcement moratorium. Furthermore, while an investigation or inquiry by the SEC or DOJ should not be construed as an indication by the SEC or the DOJ that any violation of law has occurred, nor as a reflection upon any person, entity or security, publicity surrounding the foregoing, any SEC or DOJ enforcement action or settlement as a result of these investigations, even if ultimately resolved favorably for us, could have an adverse impact on our reputation, business, prospects, financial condition, and results of operations. See "Item 8. Financial Information – A. Consolidated Statements And Other Financial Information – Legal Proceedings."

We are also cooperating with and have in certain instances self-reported various matters involving alleged or potential violations of Indonesian laws and regulations by our business units and subsidiaries and affiliates, including anti-corruption, alleged fraud, embezzlement and issues associated with accounts receivable, some of which are related to the

above-described matters investigated by the SEC and the DOJ, to government authorities in Indonesia, including the Indonesian National Police, Public Prosecution Service and Corruption Eradication Commission. The length, scope or results of these self-disclosures and proceedings, or their impact on our results of operations, business or financial condition remain uncertain.

Any actual or perceived outcomes of these matters that are adverse to us could result in negative publicity, legal proceedings and/or regulatory actions that could damage our reputation, discourage current or potential business partners and customers from doing business with us, and subject us to claims, fines, damages and lawsuits, any of which could have material and adverse effects on our business, results of operations and financial condition.

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If 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.

We 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.

In 2016, our Company, Telkomsel, and five other local operators were found to have violated the Business Competition Law for price-fixing practices related to SMS services. We and Telkomsel paid penalties to the treasury fund in the amount of Rp18 billion and Rp25 billion, respectively.

In 2017, allegations surfaced asserting that we had breached the Business Competition Law by offering bundled services of broadband internet, fixed wireline, and IPTV services through our “IndiHome” retail brand. Similarly, in 2021, allegations surfaced against our Company and Telkomsel for purportedly discriminating against Netflix in providing internet access services. In both instances, however, the KPPU concluded that no violation of the Business Competition Law had occurred. These incidents underscored potential challenges from customers or regulators to our business strategy.

We 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.

Regulatory Risks

Changes 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.

Since 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 telecommunications 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.

The 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.

Furthermore, 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.

Additionally, 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.

In 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 takes full effect on October 17, 2024, requiring us, as personal data controllers, to adapt our

business practices to ensure 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 2023, we appointed a DPO, who reports to our Vice President of IT Strategy, Technology, and Architecture. In addition, in 2024, Telkom 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.

As of the date hereof, the Government, through MoCD, is drafting detailed implementing regulations to clarify the PDP Law’s requirements. These regulations are expected to provide operational guidance on key provisions, including mandatory record-keeping of data processing activities, such as identifying data sources, purposes, types, security protocols, transfers, and related security measures. The Inter-Ministerial Committee (Panitia Antar Kementerian) has completed discussions on a draft Government regulation to supplement the PDP Law and establish clear standards for data controllers and processors. We have already begun adapting to these anticipated requirements; however, full compliance may require additional resources and investments, possibly delaying specific projects. 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.

As of the date hereof, MoCD is in the process of developing a new regulation on Artificial Intelligence (“AI”) ethics, which may be issued as a Ministerial regulation or another regulatory instrument. According to MoCD’s Press Release No. 628/HM/KOMINFO/10/2024, dated October 2, 2024, Nezar Patria, the Vice Minister of MoCD, stated that the regulation is still under discussion and was expected to be finalized by the end of 2024. 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.

The 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. This includes setting age restrictions, verifying user identities, and establishing reporting channels to defend children’s rights online. 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.

Cybersecurity 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 regulatory 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.”

The 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.

Moreover, 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.

Applicable regulations on tariffs and their implementation as supervised by the MoCD may affect our revenues and earnings.

MoCD 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.

Under 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.

Changes 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. We expect the full implementation of IP-based interconnection to commence on January 1, 2025. However, our network still operates partially on legacy systems, meaning the transition to full IP-based interconnection has not yet been completed. 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.

Regulated 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.

MoCD 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 protect the public interest, the MoCD may have the authority to set upper and lower limits on the tariffs we charge.

Regulations 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.

In 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.

In 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 network 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.

In 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.

We may experience local community opposition to some of our tower sites.

We 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, vandalism could result in damaged equipment. In the year ended December 31, 2024, we were involved in 78 community disputes.

Opposition 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.

We 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.

We 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.

According 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.

Our electronic money business is highly regulated.

We 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, and e-wallet business).

Any 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 has obtained an E-Money license from BI which also covers remittance services held by Finarya, an associate of Telkomsel. 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 Telkomsel, 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.

BI 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, fail to comply with any of these obligations, we will be subject to administrative sanctions. Any sanction imposed on Telkomsel could materially and adversely affect our business, financial condition, results of operations and prospects.

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We may experience changes in governance as an SOE.

On February 24, 2025, the Government officially enacted Law No. 1 of 2025 on the Third Amendment to Law No. 19 of 2003 on State-Owned Enterprises (the “New SOE Law”). The enactment of the New SOE Law coincided with the launch of BPI Danantara; an institution granted certain governance powers previously held by the MSOE. Notably, BPI Danantara’s key governance responsibilities include overseeing dividend management, approving capital increases or decreases in SOEs sourced from dividend management, and writing off SOE assets.

The New SOE Law introduces, among other things, two new categories of SOEs: (i) operational holding, an SOE assigned to oversee the operational activities of SOEs as well as other business activities (“Operational Holding”); and (ii) investment holding, designated to manage dividends and/or the utilization of SOE assets (“Investment Holding”). Both Operational Holding and Investment Holding are wholly managed by BPI Danantara, which holds majority share ownership and exercises oversight through these holding entities. While BPI Danantara plays a central role in management, the Government ultimately retains control over both the Operational and Investment Holding entities through its ownership of the Dwiwarna Share. Operational Holding is responsible for directly managing SOEs within their respective sectors and is empowered to issue debt, obtain and extend loans, and provide guarantees to SOEs or their subsidiaries. On the other hand, Investment Holdings focus on dividend management and may also extend loans or guarantees to SOEs or subsidiaries.

As part of implementing the New SOE Law, the Government issued Government Regulation No. 15 of 2025 on the Additional State Capital Participation of the Republic of Indonesia into the Share Capital of BKI for the Establishment of an Operational Holding (“GR 15/2025”), which includes the additional state capital participation in BKI through an in-kind contribution (inbreng) of the Government’s Series B shares in various SOEs, including the Series B shares in our Company. As a result, as of March 22, 2025, BKI has become our majority shareholder and serves as an Operational Holding, acting as an extension of BPI Danantara in overseeing our operational activities. Despite this transfer of Series B shares in our Company, the Government remains our ultimate controlling party by retaining the Dwiwarna Share, which grants special rights including determining strategic policy, appointing directors and commissioners, and accessing key company information.

Additionally, pursuant to Government Regulation No. 16 of 2025 on State Capital Participation of the Republic of Indonesia in BPI Danantara (“GR 16/2025”), as of March 22, 2025, all Series B shares in BKI were transferred to BPI Danantara, formally establishing BKI as an Operational Holding under the management and majority control of BPI Danantara. As of the date hereof, the Government retains the Series A Dwiwarna share in BKI, ensuring continued ultimate control of BKI and of our Company.

The transfer of the Government’s Series B shares in our Company to BKI and retention of the Dwiwarna Share, such that ultimate control remains with the Government, establishes a dual oversight structure. BKI, as an extension of BPI Danantara, is mandated to manage our operational strategies, while the Government, through its special rights as the holder of the Dwiwarna Share, maintains overarching decision-making authority over our Company. This structure may create overlapping functions and mandates between BKI and the Government, particularly concerning strategic direction and corporate control. Clear delineation of roles and strong coordination mechanisms will therefore be essential to avoid conflicting mandates and ensure effective corporate governance within the SOE framework.

While we do not anticipate any material impact on our governance or business operations from this restructuring, given that ultimate control remains with the Government, we continue to closely monitor the Government’s issuance of implementing regulations under the New SOE Law. These upcoming regulations may introduce further governance adjustments, and we will assess any potential implications to maintain our adaptability and strategic alignment within the evolving regulatory landscape.

Risks Related to the Development of New Businesses and Acquisitions

We may not succeed in our efforts to develop new businesses.

We 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 acquire 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.

Focusing 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.

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.

Our strategic focus in 2024 was on achieving better FMC performance, optimizing fiber asset utilization through PT Telkom Infrastruktur Indonesia, consolidating and expanding our data center business segment, developing our offering of B2B services (such as for cybersecurity and cloud and data center services), accompanying and fostering the digitalization of Indonesian businesses and Governmental agencies. We 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. As 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 effort 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.

If we are unable to manage our growth effectively, our business and financial results may be adversely affected.

To continue to grow sustainably, we must continue to expand our operational, research, sales and marketing efforts, accounting and financial systems, procedures, controls and other internal management systems. 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.

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Our acquisition activities expose us to various risks.

We have in the past pursued, and may continue to pursue, acquisitions of complementary assets and businesses. In 2022, Mitratel acquired an additional 6,000 telecommunications towers from Telkomsel. 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.

The 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.

Even 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 expect. 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.

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Risks Related to our Corporate Structure

We are dependent on our subsidiary, Telkomsel, a cellular telecommunications services and cellular telecommunications networks company.

We derived 58.0%, 57.2% and 55.6% of our revenue in 2022, 2023 and 2024, 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 was an increase in the contribution from Telkomsel to our consolidated revenue. See "Item 5A—Operating Results."

Singtel, 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, strategy, 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.

Our effort to streamline our corporate structure may not create expected synergies and efficiency in a timely fashion or at all.

To 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.

As 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. For instance, we are consolidating our data center assets under our subsidiary TDE, and our infrastructure assets under a proposed InfraCo. 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.

These streamlining efforts, however, have been delayed, and we may experience further delays. 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.

Our controlling shareholder’s interests may differ from those of our other shareholders.

As of March 31, 2025, the Government, through the MSOE, holds our one Dwiwarna Share, which has special voting rights and veto rights over certain matters, including the election and removal of our Directors and Commissioners. The Government may also use its powers under the Dwiwarna Share to cause us to issue new shares, amend our Articles of Association or bring about actions to merge or dissolve us, increase or decrease our authorized capital or reduce our issued capital, or veto any of these actions. One or more of these may result in the delisting of our securities from certain exchanges. In addition, the Government regulates the Indonesian telecommunications industry through MoCD.

As of December 31, 2024, the Government, through PT Perusahaan Pengelola Aset (Persero), held a 9.63% equity interest in IOH, which competes with us in cellular services, data center services, IT solutions, system integration services, and fixed IDD telecommunications services. The Government’s equity interest in IOH also includes a Dwiwarna Share which has special voting rights and veto rights over certain strategic matters under IOH’s articles of association, including decisions on dissolution, liquidation, and bankruptcy, and also permits the Government to nominate one director to its board of directors and one commissioner to its board of commissioners. As a result, there may be instances where the Government’s interests will conflict with ours. The Government may direct opportunities to IOH or favor IOH or any other telecommunications operator when exercising regulatory powers over the Indonesian telecommunications industry. If the Government were to give priority to the business of IOH or any other telecommunications operator over ours, or to expand its equity interest in IOH or acquire an equity interest in any other telecommunications operator, our business, financial condition, and results of operations and prospects could be materially and adversely affected.

Our Articles of Association contain certain anti-takeover provisions that could adversely affect the rights of holders of our ordinary shares and ADSs.

Our 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.

Risks Related to Indonesia

Political and Social Risks

Current political and social events in Indonesia may adversely affect our business.  

Indonesia 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 2000, 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.

The demonstrations focused on social and civil responses to specific issues, such as regional election laws, civil rights, democratic processes, election integrity, and Job Creation Law 2023. Although these demonstrations have generally been peaceful, some have escalated into violence. The most recent demonstration took place on August 22, 2024, in response to amendments to regional election laws. Joko Widodo, who has since completed his term as the seventh President of Indonesia, faced criticism for allegedly attempting to consolidate power ahead of his departure on October 20, 2024. Despite the national Parliament’s decision not to reverse the Constitutional Court’s ruling that lowered the thresholds for regional election nominations, public discontent remains. The political environment is still tense, with various groups voicing concerns over potential government overreach and its impact on democratic processes and civil rights as the transition of power approaches.

Earlier, on February 16, 2024, around a thousand protesters gathered outside the General Election Commission (Komisi Pemilihan Umum) office in Jakarta, calling for the commission to prevent Prabowo Subianto and Gibran Rakabuming Raka from assuming office as president and vice president, citing widespread allegations of electoral fraud. These claims led to a lawsuit challenging the 2024 Presidential Election results, which was filed with the Constitutional Court by rival presidential candidates. On April 22, 2024, the Constitutional Court rejected all petitions contesting the election outcome and affirmed Prabowo Subianto and Gibran Rakabuming Raka’s victory. This decision highlighted the contentious nature of Indonesia’s political landscape, marked by public skepticism regarding election integrity and ongoing debates about democratic principles.

In addition to the evolving political dynamics, Indonesia has been grappling with social and civil unrest driven by separatist movements and clashes between religious and ethnic groups. Significant conflicts have arisen, particularly involving separatist rebels in West Papua, leading to violent incidents, including those in January 2023. These tensions reflect ongoing confrontations between separatist supporters and the Indonesian military. Additionally, inter-ethnic conflicts in Kalimantan and religious tensions in Maluku and Poso further complicate the nation’s social landscape. These issues underscore the challenges Indonesia faces in maintaining stability and unity amidst diverse cultural and regional interests.

Given 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.

Terrorist 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.

There 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.

Although 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.

We 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.

Since 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.

For 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.

Macroeconomic Risks

Negative changes in global, regional or Indonesian economic activity could materially and adversely affect our business.

Our 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. Although the Indonesian economy has recovered modestly from COVID-19, the economic situation in Indonesia may nonetheless deteriorate, which could have an adverse effect on our business, financial condition, results of operations and prospects.

Downside 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.

For instance, ongoing trade disputes between major economies, particularly the United States and China, continue to create uncertainty and volatility in global financial markets. In 2025, these tensions have intensified, with the United States imposing additional tariffs on Chinese goods and China implementing retaliatory measures, including increased tariffs and export restrictions. This escalation may further reduce capital inflows and investment in emerging markets such as Indonesia, exerting downward pressure on currencies and increasing external financing costs for businesses.

Further, the U.S. Federal Reserve’s monetary policy decisions continue to impact global markets. In 2025, the U.S. Federal Reserve has balanced inflation concerns and slower economic growth by signaling a pause in rate hikes but maintaining higher interest rates than pre-2022 levels. This has continued to cause 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.

In addition, China’s economic slowdown has persisted into 2025, 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.

The 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, leading to elevated oil prices and intermittent supply disruptions. These geopolitical tensions increase uncertainty in global markets, contributing to inflationary pressures and reducing global business and consumer confidence. 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.

Following 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.

These adverse economic conditions and geopolitical developments 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 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.

Fluctuations in the value of the Indonesian Rupiah may materially and adversely affect us.

Our 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 in 2022 to a low of Rp16,095 to US$1.00 on December 31, 2024, (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.

In 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.

Rapid and excessive increases in levels of inflation and interest rates in Indonesia could materially and adversely affect our financial condition and results of operations.

Interest 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 2.61% and 1.57% in the years ended December 31, 2023 and 2024, 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.

Even if we have not yet experienced any such impact on our revenues in 2024, 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.

Downgrades of credit ratings of the Government or Indonesian companies could materially and adversely affect our business.

As of the date of this annual report on Form 20-F, Indonesia’s sovereign foreign currency long-term debt was rated “Baa2” with stable outlook by Moody’s, “BBB” with stable outlook by Standard & Poor’s and “BBB” with stable outlook by Fitch.

These 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.

Uncertainty in respect of manpower legislation in Indonesia could materially and adversely affect our business.

The 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 been 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.

In 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.

On 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 ensure 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.

The evolving regulatory landscape creates significant uncertainties in Government oversight and compliance standards, which could affect our strategic and financial planning. The requirement to implement a standalone manpower law by 2026 further complicates the regulatory framework. 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.

Risks relating to Natural Disasters and Climate Change

Indonesia is vulnerable to natural disasters and events beyond our control, which could materially and adversely affect our business and operating results.

Many 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. 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 disrupted, and may in the future, disrupt our business activities, cause damage to equipment, and adversely affect our financial performance and profit.

For 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.

To 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.

Future 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.

We are exposed to the potential for financial loss and further non-financial detriments arising from climate change and society’s response to it.

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This 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.”

Climate Risk continues to be a core focus of regulatory policymaking across all jurisdictions in which we operate, including as a result of recent COP26-related initiatives. 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.

If 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.

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In 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 continuance of any of the abovementioned risks could have a material adverse effect on our financial condition, results of operations and, if severe or prolonged, our prospects.

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Risks Related to our ADSs

The trading price of our ADSs may be volatile, which could result in substantial losses to you.

The 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:

Any of these factors may result in large and sudden changes in the volume and price at which our ADSs or ordinary shares will trade.

If 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.

The trading market for our ADSs will 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.

The different characteristics of the capital markets in Indonesia and the U.S. may negatively affect the trading prices of our ADSs and shares.

As 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 shares may not be the same, even allowing for currency differences. Fluctuations 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 having 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.

Our 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.  

In 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, 2024, on April 17, 2025. We furnished such financial results to the SEC on Form 6-K dated April 17, 2025, which contains our Consolidated Financial Statements as of and for the year ended December 31, 2024, 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.

Based on IFAS financial statements, our profit for the year attributable to owners of the parent company were Rp20,753 billion in 2022, Rp24,560 billion in 2023, and Rp23,649 billion in 2024. Our net income per share was Rp209.5 in 2022, Rp247.9 in 2023, and Rp238.7 in 2024. For the fiscal year ended December 31, 2022, dividends declared per share were Rp167.6 and dividends declared per ADS were Rp16,759. For the fiscal year ended December 31, 2023, dividends declared per share were Rp178.5 and dividends declared per ADS were Rp17,850. The dividends for the fiscal year ended December 31, 2024 will be decided at the 2025 AGMS, scheduled for May 27, 2025.

As 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.

We 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.

We 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.

As 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.

As 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.

The voting rights of holders of our ADSs are limited by the terms of the Deposit Agreement.

Holders 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 permit them 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. 

Holders of our ADSs may be subject to limitations on transfer of their ADSs.

ADSs 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.

Holders 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.

The 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 have 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.

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Holders of our ADSs may experience dilution of their holdings due to their inability to participate in rights offerings.

We 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.

The 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.

There 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.

We 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.

We 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.

We 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.

Furthermore, 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 judgement 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.

This 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.

As 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.

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ITEM 4.              INFORMATION ON THE COMPANY

A.           HISTORY AND DEVELOPMENT OF THE COMPANY

Profile of Telkom

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Telkom is the largest telecommunications company in Indonesia, in terms of revenue and number of subscribers, as of December 31, 2024. 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.

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In order to achieve our vision and missions, we continue to work to transform key aspects of our business: technology, organization, operations, people, and culture.

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We 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.

Telkom’s Milestones

In 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.

In 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.

In 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.

In 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.

In 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.

In 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.

In 2004, we launched an international direct dialing service for fixed lines with the access code of 007.

In 2005, we launched the Telkom-2 satellite. This satellite was retired in 2021 when it reached the end of its operational life.

In 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.”

In 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.

In 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.

In 2014, we became the first cellular operator in Indonesia to commercially launch 4G/LTE service.

In 2015, we launched the retail brand “IndiHome,” under which we market fixed voice, fixed broadband, IPTV, and consumer digital services in a bundled package.

In 2017, we launched the Telkom-3S satellite and commenced operations on schedule.

In 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.”

In 2019, we reconfigured our business portfolio from TIMES to a five-segment portfolio of mobile, consumer, enterprise, wholesale, international business, and other.

In 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.

In 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. As of the date hereof, our second HyperScale data center in Batam is still under construction. We also established strategic partnerships with several global technology companies such as Microsoft.

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 business segment to Telkomsel. See also “Item 10C. — Material Contracts.”

In 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 cable 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.

In February 2024, we launched our Merah Putih-2 satellite. In December 2024, Mitratel acquired 100% 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.

For the years ended December 31, 2022, 2023, and 2024, our consolidated capital expenditures totalled Rp34,146 billion, Rp32,858 billion and Rp24,436 billion (US$1,519 million), respectively. The capital expenditures were primarily used for purchases of property under construction, cable network and equipment. 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, 2024.  

Information about the legislation under which we operate and a description, to the extent applicable, of our divestitures (including interests in other companies), since the beginning of our last three financial years, is contained elsewhere in this Form 20-F. 

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Strategy

As the largest telecommunications company in Indonesia in terms of revenue and number of subscribers, we aim to become the preferred digital telecommunications company in Indonesia while also contributing to national development and delivering 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 partnerships. We expect these efforts to promote the wider adoption of digital technologies across different sectors. In addition, we seek to improve customer experiences by building a comprehensive digital ecosystem. This includes offering services such as gaming and IPTV and collaborating with strategic partners to deliver innovative solutions.

Strategic Focus 2024

Our long-term strategy focuses on achieving excellence in three key digital business domains: digital connectivity, digital platforms, and digital services. At the same time, we aim to optimize current operations to maintain our market position. These efforts are designed to drive sustainable growth, unlock stakeholder value, and foster inclusive digitalization across Indonesia. Our core programs for implementing our strategy are as follows:

The Five Bold Moves

To achieve our strategic objectives, we are implementing five key initiatives, collectively referred to as the “Five Bold Moves.” These initiatives are expected to strengthen competitiveness across digital connectivity, platforms, and services while supporting our vision to become a world-class digital telecommunications company. We aim to optimize operations, enhance capabilities, improve efficiency, and deepen our relationships with our customers, investors, and partners. The Five Bold Moves are as follows:

Further Development of 5G Services

In 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 (particularly in the manufacturing, infrastructure, and education sectors) and the availability of additional 5G spectrum through anticipated Government auctions.

Our 5G development aims to support Indonesia’s broader digital ecosystem goals by integrating emerging technologies and scalable infrastructure to drive adoption across sectors. 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 with high-speed, low-latency connectivity.

We are expanding our 5G network through the Hyper 5G initiative in a focused and gradual manner to enhance digital connectivity and support the growth of Indonesia’s digital ecosystem and economy. Since its commercial launch in 2021, Telkomsel’s Hyper 5G network has been expanding, with approximately 1,000 BTS covering 56 cities and regencies, supporting national digital transformation efforts. As an initial step, as of the date hereof, Telkomsel now provides 5G services in Denpasar City and Badung Regency, Bali Province.

In December 2024, Telkomsel completed the expansion of its Hyper 5G network in the Greater Jakarta area, which covers strategic routes such as the route from the Soekarno-Hatta Airport to the Halim Perdanakusuma Airport, the planned areas of Pantai Indah Kapuk 1 and 2, and business districts and Government centers from Pondok Indah to the National Monument.In the near future, Telkomsel plans to further extend its 5G network to other key locations across Indonesia in a gradual and strategic manner. As the customer base grows and 5G device adoption increases, Telkomsel is offering various products and deals to enhance the benefits of Hyper 5G connectivity, aiming to provide faster and more affordable services in the Greater Jakarta area.

Additionally, we will continue to explore partnerships with technology providers to scale emerging technologies such as Network Functions Virtualization (“NFV”) and Software-Defined Networking (“SDN.”) driving Indonesia’s 5G Fixed Wireless Access Technology Roadmap. Alongside network expansion, we will continue to strengthen Group-wide cybersecurity measures to support secure and reliable connectivity.

Our focus remains on delivering superior customer experiences while supporting Indonesia’s transition to a digitally connected future through innovative 5G infrastructure, applications, and solutions.  

Strategic Partnerships

In 2024, we expanded digital service offerings through strategic partnerships and collaborations. We formed alliances with global technology companies in cloud computing to strengthen TDE’s data center business, leveraging these collaborations to drive innovations and enhance competitiveness in Indonesia and the region.

We reinforced our digital services ecosystem through investments such as Telkomsel’s US$450.0 million (Rp6.4 trillion) investment in PT GoTo Gojek Tokopedia Tbk (“GoTo”) from 2020 to 2022. This partnership, which saw Telkom gradually invest in GoTo from 2020 to 2022, has consistently generated synergistic value through enhanced connectivity, digital platforms, and services. In 2024, we continued to work with GoTo to expand services in the GoTo ecosystem. Future collaborations with GoTo will focus on connectivity, data services, and integrating offerings with GoTo’s platforms to strengthen the digital ecosystem. See “–  Business Portfolios – Mobile Segment.”

Telkomsat has collaborated with SpaceX’s Starlink since 2022 to provide backhaul services in remote Indonesian regions, supporting digital inclusion by extending connectivity to underserved areas. In May 2024, Telkomsat leveraged its partnership with Starlink by becoming the first authorized Starlink re-seller in Indonesia.

In November 2023, we partnered with KT Corp, a South Korean telecommunications company, to develop a sustainable smart city model for Nusantara, Indonesia’s planned capital, focusing on infrastructure, connectivity, and digital ecosystem development.

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Enhancing our Assets through Acquisitions and Spin-offs

In April 2023, as part of the FMC initiative, we entered into an agreement with Telkomsel to integrate our fixed and mobile broadband businesses into a single entity by transferring IndiHome-related assets and liabilities (the “IndiHome Integration”). The IndiHome Integration aims to enhance customer engagement through cross-selling, integrated content delivery, and unified customer touchpoints, while driving operational and cost efficiencies, improve customer experience, and foster synergies to deliver more competitive product offerings. As at 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.

In our tower business portfolio, we remain focused on strengthening assets and digital capabilities through acquisitions, spin-offs, and strategic initiatives. In 2022 and 2023, Mitratel expanded its fiber optic and tower portfolio, acquiring 6,012 km of fiber optic assets from PT Sumber Cemerlang Kencana Permai and PT Trans Indonesia Superkoridor, 967 km from PT Power Telecom, 54 towers from PT XL Axiata Tbk (“XL Axiata.”) and 803 towers from PT Gametraco Tunggal. In 2024, Mitratel acquired a 100% equity stake in PT Ultra Mandiri Telekomunikasi from PT PP Infrastruktur, which increased the coverage of Mitratel’s fiber optic network. These acquisitions are expected to improve asset utilization and enhance Mitratel’s infrastructure portfolio value for both operational and investment purposes. See also “Item 3D — Risk Factors — Risks Related to Our Business — Risks Related to the Development of New Businesses and Acquisitions — Our acquisition activities expose us to various risks.”

While pursuing external growth through acquisitions, we also focus on enhancing governance and collaboration within Group entities to unlock synergies and promote efficient resource utilization.

Furthermore, Mitratel continues to explore strategic growth opportunities, focusing on optimizing asset utilization and expanding into adjacent tower-related businesses, including power-as-a-service and next-generation infrastructure such as High-Altitude Platform Stations (“HAPS”). These initiatives align with Mitratel’s long-term goals of sustainable growth and market position enhancement.

Environmental, Social, and Governance (“ESG”) Matters

In 2024, we updated our sustainability strategy under the GoZero% program, signifying our dedication to responsible business practices based on Environmental, Social, and Governance principles. Our sustainability strategy is composed of three pillars:

Our sustainability strategy seeks to mitigate the environmental impact of our operations and businesses. We are dedicated to building an eco-friendly culture and extending environmental management practices beyond our immediate operations. We aim to reduce the telecommunications industry's carbon footprint by reducing energy use, emissions, and managing electronic waste effectively.  

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We have implemented several practices: enhancing energy efficiency, promoting renewable energy adoption, responsible waste handling, careful water usage, and procuring energy-saving hardware. Oversight of environmental policies is centralized under the head of each business unit. Measures to decrease energy consumption include using LED lighting, installing reflective glass to reduce air conditioning use, managing cooling systems, and optimizing electricity usage with devices such as capacitor banks and timers. Plans to install rooftop solar panels are also being assessed as at the date hereof.  

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In 2024, we also began calculating Scope 3 GHG emissions across nine categories and completed an independent verification by TUV Rheinland of its first GHG emissions inventory. Additionally, we reduced total waste generation by 6,387 tons and diverted 176,046 kg of fiber optic cable waste. 

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Our network infrastructure improvements entail AC optimization and replacing old equipment with more energy-efficient alternatives, alongside expanding solar energy usage. Water-saving initiatives feature automatic taps and reusing AC condensation. Transportation has become more eco-friendly by encouraging cycling to work with bike parking facilities. Through digitalization, we are reducing paper trails by encouraging online communication and virtual meetings. Invoicing processes are now paperless, with digital channels in use for customer billings, such as apps (MyTelkomsel), email, outbound calls, and text notifications on Pay TV services. Our corporate culture is focused on sustainability and responsible practices, integrating ESG principles into business decisions. We engage with communities and within our organization to foster a sense of environmental responsibility.

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We have also implemented initiatives focused on water management and biodiversity conservation. In addition to operating a Sewage Treatment Plant (STP), we have introduced a wastewater recycling system that utilizes condensation waste from the Air Handling Unit (AHU) for cooling and irrigation. To enhance land and marine ecosystems, we have conducted mangrove planting, revegetation, and coral reef transplantation. In 2024, we have planted 102,450 trees across 4.6 hectares in collaboration with local communities through the Hutan Binaan Digital Telkom. Additionally, 62,250 mangrove trees (Rhizophora mucronata) were planted, and 896 coral reef substrates (Acropora sp. and Porites sp.) were transplanted to support marine biodiversity. 

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Throughout 2024, we strengthened our dedication to diversity, digital innovation, and customer-centric service. Starting with our employees, women held 22% of managerial positions, supported by initiatives such as DayCare and Srikandi Telkom workshops, which foster gender equality in the workplace. This dedication is further reinforced through the Respectful Workplace Policy, a comprehensive framework that regulates the prevention, handling, and reporting of discrimination, violence, and harassment. In digital talent development, the Digital Talent program successfully trained 20.6% of our digital workforce through Telkom Athon and various upskilling programs. Workplace safety also remained a top priority, with zero work-related fatalities recorded throughout the year. 

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We believe that strong governance enables us to elevate our business by enhancing competitiveness, strengthening stakeholder trust, and ensuring long-term sustainability. We believe that by upholding the principles of Transparency, Accountability, and Compliance, we not only meet regulatory requirements, but also foster an innovative and sustainable business ecosystem that will allow us to grow even further alongside our stakeholders. 

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We are dedicated to implementing ethical and responsible business practices, ensuring regulatory compliance, and strengthening data protection amid evolving cybersecurity threats. Throughout 2024, we aimed to adhere to all applicable legal and regulatory frameworks within jurisdictions in which we operate, maintaining a firm stance on enforcing compliance within the Telkom Group. We also strived to consistently take decisive action against legal violations, cooperate fully with legal processes, and implement preventative measures to comply with applicable regulatory requirements. 

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We have implemented the ISO 37001:2016 Anti-Bribery Management System since 2020, and in 2024, we continued to reinforce this standard across our operations, including our subsidiaries. This ongoing implementation strengthens our dedication in upholding integrity, preventing corruption, and ensuring ethical business conduct throughout the Telkom Group. In line with our dedication to transparency and accountability, all whistleblowing reports received through our system were thoroughly reviewed and addressed. We believe that this reflects our strong ethical culture and dedication to fostering a respectful work environment. 

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On data security, we aimed to maintain robust safeguards to ensure that no critical data breaches occurred, and all data processing activities were conducted securely. These achievements reinforce our dedication to governance excellence, fostering trust, driving innovation, and advancing Indonesia’s digital future sustainably.

Business Portfolios

Our business portfolios are organized by business lines that are categorized into Legacy, Digital Connectivity, Digital Platform, and Digital Services. Those businesses lines are operated under five customer base segments (i.e., CFUs):

Historically, digital connectivity has generated the largest share of our total revenue. Thus far, our business has not experienced significant seasonality.

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The following is a brief overview of our product portfolios:

1. Mobile Segment

Our mobile segment portfolio comprises legacy services such as voice and SMS, alongside digital products such as data and value-added services, executed through Telkomsel, our majority-owned subsidiary. In 2024, mobile services,  particularly digital business revenue, which amounted to 69.1% of Telkomsel’s total revenues remained the principal driver of our revenue.

Telkomsel’s prepaid mobile services, branded as “Telkomsel Prabayar” (introduced in 2021) and “by.U” (introduced in 2019), amounted to 95.0% of the total number of cellular subscribers as of December 31, 2024. Meanwhile, Telkomsel’s postpaid mobile services, branded as “Telkomsel Halo,” represented 5.0% of the total number of cellular subscribers as of the same date. The total number of cellular subscribers remained stable, with a marginal increase of 49,000 subscribers from 159.3 million (comprising 151.8 million prepaid and 7.5 million postpaid subscribers) to 159.4 million (comprising 151.4 million prepaid and 8.0 million postpaid subscribers) as of December 31, 2024.

The stability in our subscriber base is attributed to 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. However, Telkomsel’s annual ARPU decreased by 6.6% from 2023 to 2024 reflects the challenges it faces, including the downward trend in legacy services and macroeconomic pressures due to weakened consumer purchasing power. To maintain ARPU stability and growth amid challenging macroeconomic conditions and market competition, Telkomsel continues to expand its digital product portfolio, optimize CVM initiatives, and leverage FMC offerings to enhance customer productivity and strengthen ARPU resilience in the long term.

Our mobile broadband services are supported by 5G/4G/2G technology. Despite macroeconomic challenges, we have observed positive indicators of productivity, driven by increased consumer consumption. This is reflected in a 13.9% year-on-year increase in data traffic, rising from 17,481 petabytes as of December 31, 2023, to 19,909 petabytes as of December 31, 2024. In 2024, Telkomsel continued to support and incentivize healthier market behavior aimed at strengthening business profitability and industry rationalization through several price adjustments. Major competitors also implemented price rationalization initiatives in 2024.

In addition to our digital connectivity business, we established several digital service offerings within our mobile segment with a specific focus on financial services, video on demand, music, gaming, advertising, and IoT. Our mobile segment comprises 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 PT Fintek Karya Nusantara (“Finarya”). As of the date hereof, Telkomsel owns a 24.83% equity interest in Finarya.

We also offer on-demand video content through the MAXstream application, a platform that collaborates with partners to co-produce content with studios. MAXstream produces programs in partnership with other creators, which are then distributed either through in-house channels or other OTT platforms. We provide music and gaming services that offer a mobile entertainment experience by targeting various consumer segments and leveraging Telkomsel’s billing system. We have applications for music (e.g., Langit Musik) and Dunia Games, which provides a comprehensive gaming ecosystem combining media content, distribution, payment facilities, e-sports, and gaming communities to enhance customer experience. With rapidly evolving customer needs and the transformation taking place in the society, we aim to enhance our product offerings and digital capabilities to go beyond connectivity while accelerating and expanding our current digital ecosystem, to continue to focus on customer needs and long-term growth supported by network quality.

Following Telkomsel’s investment in GoTo in November 2020 and May 2021, the two companies have strengthened their strategic partnership initiatives to provide users with new benefits and also help to accelerate the digitization of MSMEs.

GoTo has already developed a comprehensive and well-recognized digital ecosystem for users, drivers, and merchants. Our partnership with GoTo is multi-faceted. We have jointly promoted products and services such as connectivity promotions and advertising packages and conducted co-branding activities to better service our respective customers and expand our addressable markets. For instance, we have offered data packages and discounts designed for GoTo drivers. We are also collaborating with GoTo to better understand the consumption habits and behaviors of users and customers in order to improve our products and solutions offerings. These initiatives to increase the number of Telkomsel users within the GoTo ecosystem include creating easy onboarding capabilities for GoTo’s MSME partners to become Telkomsel reseller partners, integrating MyTelkomsel and GoPay, collaborating on loyalty programs, and providing GoTo with a number masking service. We expect additional digital initiatives in collaboration with GoTo in the future. See “– Strategy – Strategic Partnerships.”

The Job Creation Law 2023 aims, among other things, to support the acceleration of digitalization and accessibility of broadband services in Indonesia through various means. These include optimizing use of frequency spectrum, limiting passive infrastructure by imposing certain network sharing obligations on non-telecommunications companies and promoting a sustainable competitive environment through price regulation. To optimize spectrum use, the Government ordered a switch from analog to digital television broadcasting in 2022 (known as the analog switch-off) in the 700 MHz frequency band.

Telkomsel officially launched 5G services in May 2021, becoming the first cellular operator to offer 5G in Indonesia. As of 2024, Telkomsel has made 5G available by deploying 975 BTS towers at selected points in more than 56 cities 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 publicize 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. See “– Strategy – Further Development of 5G Services” and “Item 3D—Risk Factors—Risks Related to Our Business— Operational Risks— The rapid pace of technological change in the telecommunications industry may adversely affect our ability to remain competitive if we cannot successfully integrate new innovations.”

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2. Consumer Segment

Our consumer segment portfolio comprises fixed voice, fixed broadband, IPTV, and consumer digital services. We market these service offerings under the retail brand “IndiHome,” a product that allows customers to choose one or more of such services in a bundled package.

In 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. This new product aims to encourage equitable distribution of digital connectivity throughout the community through a wide selection of customer-centric packages and a multi-screen approach for content optimization.

Telkomsel is focused on maintaining the business continuity of IndiHome by optimizing synergies between fixed broadband and mobile broadband services, while pursuing revenue growth. The IndiHome Integration aims to enhance customer engagement through cross-selling, integrated content delivery, and unified customer touchpoints, while driving operational and cost efficiencies, improve customer experience, and foster 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.

Telkomsel aims to accelerate fixed broadband penetration by targeting diverse segments with with targeted pricing strategy. This includes the launch of EZnet in 2024, complementing existing offerings to maintain competitiveness, capture new opportunities, and address affordability in the mass market segments within targeted customers and areas. Concurrently, Telkomsel is enhancing our service offerings and maintaining high-quality standards to meet the demand for reliable high-speed broadband.  

In 2024, Telkomsel accelerated the acquisition of new IndiHome B2C customers adding approximately 918,000 new subscribers. However, this growth coincided with a natural decline in ARPU, which decreased by 6.0% from Rp252.7 thousand in 2023 to Rp237.6 thousand in 2024. See “– Business Portfolios – 1. Mobile Segment.”

Telkomsel 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 stands for Indonesia Wi-Fi, our wireless public internet network that provides public access to high-speed internet services and various other multimedia services.

3. Enterprise Segment

Our enterprise segment comprises mainly 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.

For enterprise connectivity, we offer fixed broadband, Wi-Fi, ethernet, and data communication services, including a SD-WAN ecosystem that enables higher performance of WANs, leased channels such as Metro Ethernet, VPN-IP, high-capacity data network solutions providing point-to-point connection with high-capacity bandwidth, and fixed voice services, among others. We also provide satellite services as part of our enterprise connectivity product offering in some segments, such as aviation, maritime, mining, and plantation, as well as other satellite-based services for domestic and international users while continuing our presence and support in cellular backhaul and government services.

In 2020, we launched FLOU Cloud to foster digital growth for Indonesian startups, 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 safety. We have also obtained the ISO 27000 certification in recognition of our dedication to data safety. In addition, we have implemented Cloud Security Alliance Security, Trust, and Assurance Registry (STAR) measures. In partnership

with leading cloud service providers, we primarily target Indonesian customers in sectors we expect to grow, such as customers in the finance, manufacturing, Government, and communications sectors, to whom we offer professional cloud management and consultancy services.

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Our 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 facilitate innovation by providing state-of-the-art solutions for our customers' applications, digital marketing, finance, e-health, and entertainment, among others. For instance, we offer payment services and big data analytics that provide information used by our customers to design more effective marketing initiatives. We assist our customers with customer relationship management and IoT deployments, including to set up smart building, 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 instance by simplifying healthcare claims processing. In 2024, we focused on our ICT business, delivering specialized solutions for the Government and the logistics, healthcare, education, financial, insurance, agriculture, and mining industries.

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4. Wholesale and International Segment

Our wholesale and international business segment includes domestic and international wholesale traffic, wholesale network, wholesale digital platform and services, data centers, telecommunications tower business, and infrastructure services business.

The domestic and international wholesale traffic, wholesale network and wholesale digital platform and services that we offer comprise network services, data, and internet, as well as interconnection services, value-added services, voice-hubbing, A2P SMS, platforms, and solutions.

We earn revenue principally from interconnection services that we provide 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 a call from our customers. Interconnection services that we provide to other telecommunications operators comprise domestic and international interconnection services. With regards to our telecommunications tower business, we lease out space to other operators to place their telecommunications equipment on these towers, for which we receive a fee. As of December 31, 2024, we had approximately 43,825 towers, comprising approximately 39,404 towers owned by Mitratel, who purchased 997 telecommunications towers from Indosat in February 2023 and 803 telecommunications towers from PT Gametraco Tunggal in November 2023, approximately 4,421 towers owned by Telkomsel. We aim to consistently expand our telecommunications tower business as we believe this is a strategic business in the telecommunications industry and intend to increase our tower rental revenues. We also seek to improve our operation and maintenance efficiency by digitalizing our internal business processes.

We provide managed infrastructure and network services by performing network construction and maintenance, including laying and maintaining submarine cable, 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 have developed energy management solutions. As such, we completed the delivery and installation of diesel power plants in the Kalimantan and Sulawesi regions in 2017. After completion of this project, we were engaged by an SOE into 2023 to manage the maintenance of some of the diesel engines we had delivered and installed. In 2017, construction was completed for the SEA-US submarine cable which connects California to Manado, Indonesia, and by extension to the IGG submarine cable, which connects major cities in Indonesia as well as the SEA-ME-WE 5 and SEA-US cable systems. In 2023, we completed construction of our PATARA-2 submarine cable system connecting multiple islands across Indonesia, which enhances 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.

Globally, telecommunications tower providers are optimizing value creation by embracing new growth opportunities. They are shifting from providing basic interconnection services to also providing a broad range of support including fiber optic services and mini data centers to customers. Increases in data usage and high bandwidth applications are making it necessary to compute and store data closer to customer premises, which tower providers are taking advantage

of by setting up edge computing on tower sites. Further, by deploying micro data centers close to the network edge, telecommunications tower providers may be able to enable ultra-reliable low latency communication in 5G services that could unlock new business opportunities. Demand for and reliance on edge computing technology is also expected to increase with the emergence and development of high-throughput and low-latency applications such as high-speed video services, augmented reality and virtual reality applications, autonomous driving and other communication applications. We expect the future deployment of 5G technology will also provide 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 leaders in the industry for carrying out such deployment in a cost-efficient and phased approach to offer 5G wholesale services in Indonesia.

In 2022, we continued to consolidate and expand our data center capabilities, including our cloud services and marketplace services. We began consolidating our data center business under our subsidiary, TDE, in 2021 by transferring our then under-construction Cikarang HyperScale data center. In 2022, we transferred our enterprise data center business in Sentul, Serpong and Surabaya from Telkom Sigma. TDE continues to expand the capacity of our HyperScale data center in Cikarang and has begun building a second HyperScale data center, in Batam. We plan to continue expanding our data center capabilities.

Our subsidiary, PT Telekomunikasi Indonesia International (“Telin”), continues to strengthen its international business. Telin has developed its NeuAPIX cloud-based CPaaS services to provide small, medium, and large companies and business owners with omni-channel communication features (bots and live chats, real-time voice capabilities, SMS, emails, video calls and messaging services). Telin also offers NeuTrafiX, a web-based public exchange platform for connecting buyers and sellers for wholesale trading of voice, SMS, and virtual numbers. Telin also manages data centers in Singapore (as reseller), Hong Kong, and Timor-Leste. In 2023, Telin unveiled TNeX, the Telin NeXt Gen Platform which enables businesses to connect their data centers across the globe by allowing customers to select, acquire and monitor provisioning statuses for a range of connectivity products while granting customers the ability to instantaneously fine-tune bandwidths according to their needs. In 2024, Telin launched WABA for Business in partnership with Meta, enhancing its existing NeuAPIX CPaaS solution. WABA for Business adds more comprehensive features and solutions for both the wholesale and enterprise segments.

We also have limited operations and/or interests in a number of jurisdictions outside Indonesia in telecommunications and data-related areas. Our subsidiary, Telin, manages our international operations in the following jurisdictions:

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We regularly assess these overseas operations, their profitability, prospects, and strategic positioning in order to optimize our portfolio structure. We may make further investments or divest existing investments from time to time based on such assessments. In Indonesia, we continue to monitor the potential for further consolidation in the telecommunications tower business.

5. Other Segments

Digital Services

Our digital services portfolio primarily comprises media and edutainment services targeted to digital consumers. Our diverse digital portfolio is clustered into a smart platform and gives access to digital content and E-Commerce. We also manage a venture capital fund through our subsidiary, PT Metra Digital Investama Ventura (also known as “MDI Ventures”) to invest in digital startups. Our smart platform business line consists of digital advertising, intelligent applications, big data, IoT, and financial services. Our financial services offering focuses on creating a digital financial ecosystem by offering digital payment solutions. For example, LinkAja (formerly known as T-Cash) is an E-Money service provided by Telkomsel that enables Telkomsel customers to perform banking activities such as paying bills, transferring funds, and making online and offline retail payments on customers’ smartphones and/or feature phones. The comprehensive financial services offered by LinkAja are expected to further accelerate financial inclusion and foster the development of a cashless society as envisioned by the Government in its Non-Cash National Movement Program. As of the date hereof, Telkomsel owns a 24.83% equity interest in Finarya, and we expect our strategic partnership with GoTo will allow us to expand our digital ecosystem, benefit from co-branding and joint promotional activities, and bring us closer to customers of digital services. See “- Business Portfolios - 1. Mobile Segment.”

Telkomsel established TED as a holding company to provide digital services in the edu-tech, health-tech, and gaming sectors. TED intends to collaborate with Indonesian startups, investors, and stakeholders in the digital industry. As an example, TED has partnered with Agate, one of the largest game developers in Indonesia, to expand access to locally made games and so open opportunities for local creators in Indonesia’s gaming ecosystem. In 2022, we introduced a new brand, Leap, as an umbrella brand for all of our digital transformation products and services. We seek to use Leap to help achieve Indonesia’s digital sovereignty by creating technological solutions through collaboration and innovation.

In 2023, our subsidiary, Metranet and Cakap have collaborated to provide digital educational content on the Metranet Platform, namely Cazbox Edu. The target market includes public and private schools from various levels across Indonesia.

Telkom is a company that operates in the telecommunication sector, but considering the current pace of changes, our company has to keep innovating, therefore we provides an End-to-End Big Data Platform called BIGBOX which is an analytical big data platform with end-to-end data management and Analytics, designed to help organizations manage and analyze large amounts of data in various environments and various data formats, to provide insights, problem solving, or create value for the business or organization. We have three segments, namely PRODUCTS (end-to-end Big Data Platform to generate insights that suit client’s operational and business needs), SOLUTIONS (Helping clients turn complex data into actionable insights across various use cases in various Industries), and SERVICES & SUPPORT (Helping clients build data-driven organizations with expert support, training and consulting services).

These three segments are divided into vertical products and horizontal products, where the vertical products consist of BigOne (One Data Platform to help the government to unite scattered data into one data management), BigMarket (E-commerce Analytical Platform for analyzing e-commerce products), BigSosial (Social Media Analytics Platform to help monitor and analyze trends, brands, social, political & economic issues on social media), BigView (Smart Government Dashboard that provides integrated services from various vertical applications to view regional information, regional potential, vision and mission to the regions), BigLegal (Legal Analytic to collect all systematic legal regulations that are accurate, valid and up-to-date), and BigVision (Video Analytics and eKYC to help provide API services related to Video Analytics and eKYC) and supported by seven horizontal products consisting of BigAction, BigSpider, BigLake, BigSearch, BigQuery, BigBuilder, and BigEnvelope.

Our digital content portfolio comprises music and gaming. We manage our digital content portfolio across the Group and also manage the relevant value chains which mainly consist of sourcing content, providing the content platform, dealing with payments, and marketing. Our digital content portfolio focuses on providing consumers with a mobile entertainment experience. It targets different consumer segments and leverages Telkomsel’s trusted billing system to facilitate transactions. It offers applications for music (e.g., Langit Musik for music streaming and an application for ringtones called Nada Sambung Pribadi) and games (e.g., Upoint.id and Dunia Games, which combines game content data for several games with game vouchers). We have been developing our gaming portfolio, our E-Commerce business with a specific focus on B2B E-Commerce opportunities, Xooply, a B2B marketplace for our customers, and investing in B2B IT digital services.

Property Management

Consistent with our strategy to accelerate digital ecosystem creation, we prioritize increasing network-related building and equipment asset utilization that expands 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. In addition, we seek efficient space allocation for our legacy network equipment and to provide an enjoyable office experience for our employees. We execute our leveraging initiatives and space reconditioning through our subsidiary, PT Graha Sarana Duta (“Telkom Property”), which offers services such as property development (planning, development, and construction of property area), property leasing (property rent and leasing), property facilities (business line engaged in retail and leasing, transportation management system) and property management (building management, mall, apartment, and security services). These services contribute to the increase in our property asset utilization and diversification of our digital ecosystem.

In 2024, we undertook Five Bold Moves to support Telkom’s transformation in property management. We intensified our efforts in constructing facilities designed to facilitate the growth of our data centers. This infrastructure expansion aligns with our mission to speed up the digitalization across high-traffic sectors, supporting smooth services and product delivery. Expanding on our insight we placed strategic emphasis on the external market, fostering collaborations and partnerships to broaden our impact. This outward focus allowed us to tap into new opportunities and markets, contributing to our sustained growth. Through our improvement projects to adapt to global challenges, we continue to develop our properties to support the digital business ecosystem by delivering E-Commerce co-warehousing and cold storage collaborations. Furthermore, in our dedication to environmental stewardship, we are making efforts to enhance our services and energy management program.

In addition to leveraging our idle properties through partnerships as described above, we incorporate our digital competence and product solutions into our offerings. For example, we provide network connectivity or internet access to

our tenants or their customers as additional amenities. These digital features contribute to the increased value of our asset offerings and help to diversify our digital ecosystem. We also create partnerships with digital workplace enterprises through a co-working space business initiative. In addition to generating income, our property business also serves internal customers as part of our “group synergy projects” by providing efficient space allocation for our network equipment and an enjoyable work environment for our employees, partners, and subsidiaries. Such property assets come in the form of buildings that function as our network nodes, sales points, customer service centers, headquarters and branch offices, other businesses, functions, and land banks. Our goal for these projects is to achieve cost efficiency through economies of scale.

Network Infrastructure and Development

In 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.

National Network

Throughout 2023 and 2024, we further developed our Group IT infrastructure, encouraged internal digitalization initiatives, and enhanced customer services while expanding our Next Generation Network capabilities. We sought to drive digital connectivity service innovation, fortify cybersecurity, enhance network quality, deploy Future State Architecture, optimize capital and operating expenditure, modernize our operating model, and improve talent management. We regularly conduct software and network vulnerability assessments, and we offer cybersecurity training to all employees. Our dedication to network development aligns with the Indonesia Broadband Plan, aiming to improve broadband access nationwide. We expedited our digitalization efforts, alongside the deployment of 5G technology to meet Indonesia’s demand for advanced telecommunications infrastructure.

Our digital business comprises digital connectivity, digital platforms, and digital services, focusing on innovations that cater to the changing requirements of technology and information services.  

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:

Cellular Network

As of December 31, 2024, our subsidiary Telkomsel had the widest cellular network coverage in Indonesia, operating across GSM/DCS, GPRS, EDGE, 4G/LTE, and 5G networks with a diverse spectrum allocation, supporting technologies from GSM to 5G. In 2024, Telkomsel added a total of 23,452 new 4G BTS, along with a total of 321 additional 5G BTS. As of December 31, 2024, the network encompassed 271,040 BTS, including 2G, 4G, and 5G.

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Our subsidiary Mitratel has acquired a significant number of telecommunications towers from Telkomsel and other companies, enhancing its infrastructure portfolio, supporting Telkomsel’s focus on digitalization, and improving the digital offering for its customers across Indonesia. 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.

Data and Internet Network

In 2024, we continued to improve the quality of our data network by installing additional capacity and expanding coverage. As of December 31, 2024, we provided broadband access through fiber optic cable to more than 39 million homes. As of December 31, 2024, our Metro Ethernet network had an aggregate installed capacity of 243,988 Gbps. We use our Metro Ethernet network both 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.

As of December 31, 2024, we have extended the capacity of our internet gateway to reach an aggregate installed capacity of 9,000 Gbps, in particular to cope with expected peak surges in traffic. In 2024, we operated CDNs with an aggregate content delivery capacity of 33,180 Gbps in collaboration with Google, Facebook, Akamai, EdgeCast, Level3, Yahoo, ChinaNet, VDMS, Conversant, Zenlayer, and OTT video content providers such as iFlix and Catchplay+.

As of December 31, 2024, we had 64 points of presence in 49 cities in Indonesia, including: 12 main points of presence 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), and 52 primary and secondary points of presence throughout Indonesia. We have also been developing two primary points of presence in Kendari, which are expected to commence operations in 2025.

In 2024, we consistently deployed additional access points across Indonesia to enhance our Wi-Fi coverage and business model, while also choosing to dismantle certain access points that provided Wi-Fi services in locations where there was low utilization. Moreover, we expanded our Wi-Fi business by offering Wi-Fi management services using ONT Premium, which allows SMEs to purchase Wi-Fi at various bandwidth levels and with various additional services. As of December 31, 2024, we had installed a total of 376,212 access points (consisting of 106,836 managed access points, 221,000 home spots, and 48,376 ONT Premium access points).

Data Centers

As of December 31, 2024, we operate 35 data centers both in Indonesia and overseas. Out of all data centers that we have, 5 of which are located overseas with a total capacity of 18 MW consisting of three in Singapore, one in Timor-Leste and one in Hong Kong. Our neuCentrIX data centers in Indonesia had an aggregate capacity of 2,420 racks. Aside from data centers in Singapore which has installed 17 MW capacity, NeutraDC in Indonesia also operates three enterprise data centers with a classification of tier 3 or tier 4 with a total IT load capacity of 16 MW and one Hyperscale Data Center with a classification of tier 3 or tier 4 (at Cikarang) with current IT load capacity of 4 MW out of 51 MW total IT Load capacity that will be built in stages.

In December 2022, TDE conducted the groundbreaking ceremony for our second HyperScale data center in Batam. PT Teknologi Data Infrastruktur (“NeutraDC Batam”) is developing a 51MW data center on a five-hectare site at Kabil Industrial Estate, Batam. In 2025, we signed a contract with PLN Batam to secure electrical support with a total capacity of 90MVA for the data center. We are also exploring renewable energy initiatives in collaboration with PLN Batam. Envisioned as a three-campus infrastructure and designed to emphasize efficiency and innovation, the first campus is expected to be operational by 2025. This development aims to support digital transformation and economic development in Indonesia, particularly in Batam and the surrounding region, addressing demand from Singapore.

In 2024, we further expanded our neuCentrIX data center capacity and services via the deployment of three new neuCentrIX data centers. As of the date hereof, we are building new neuCentrIX data centers in Indonesia that will provide carrier neutral connectivity and multiple custom-made services for enterprise clients throughout the Asia Pacific region.

In 2024, we successfully integrated our international data centers by transferring Telin Singapore’s data center business to NeutraDC Singapore, which is an important milestone in our journey to become a leading regional player in the data center industry. NeutraDC also continues to explore data center expansion options at the regional level. Through regional expansion, we aim to identify new opportunities and address market demand in the Asia Pacific region.

Transmission Network

In 2024, we focused on the reinforcement of our domestic backbone network reliability and continued developing our broadband network, which serves as the backbone for our entire network infrastructure. Our backbone telecommunications network consists of transmission networks, switching facilities and core routers, which connect multiple access nodes. The transmission links between nodes and switching facilities comprise a terrestrial transmission network, in particular fiber optic, microwave and submarine cable systems, as well as satellite transmission networks and other transmission technologies. We took preemptive steps to reinforce the reliability of our network and limit congestion issues, in particular in urban areas. We did so by increasing our network capacity, prioritizing sensitive areas to prevent service disruptions (e.g., certain key Government agencies or ministries and key backbone connection links within our network), allocating more resources to monitor our network, either from our integrated operation centers or by sending teams of technicians on the field for controlling the physical integrity of our systems and the existence of potential intrusions. We have benefited from the enhancements to our network infrastructure and we seek to maintain the reliability of our network.

Communications Cable System

As of December 31, 2024, our transmission network comprised 28 backbone rings in Indonesia with an aggregate installed capacity of 578,050 Gbps and our fiber optic backbone network totaled 112,743 km domestically (compared to 111,663 km as of December 31, 2023). Our domestic fiber optic backbone network is supplemented by an international fiber optic backbone network totaling 64,700 km.

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In 2019, we began deployment of several submarine cable systems in order to strengthen our fiber optic backbone. We continue to make progress on the deployment of our fiber optic backbone in eastern Indonesia. We completed the deployment of the 1,126 km long PATARA-2 submarine cable in 2022, connecting Sarmi and Waisei. When our JASUKA and IGG fiber optic cables were disconnected in the second quarter of 2022 due to an incident with an anchor, we prioritized the repair of these two cables so that we could provide sufficient network bandwidth. In October 2023, we completed the construction of our PATARA-2 submarine fiber optic cable system connecting across North Papua, Indonesia. In 2024, we also completed the construction of the Labuha Obi submarine cable, and as of the date hereof, we are in the process of obtaining the necessary permits to commence operations.

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We also intend to leverage Indonesia’s strategic geographic location and to provide an alternative direct broadband connection between Europe, Asia, and America. The 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.

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Satellites

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In 2024, we operated three satellites, Telkom-3S, Telkom Merah Putih, and the Telkom Merah Putih-2, which was successfully launched in February 2024. During 2024, we transitioned from using TPE to Gbps as the measurement metric for satellite capacity to reflect the different technological characteristics of our newest satellite. Details on our satellites are listed below:

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We 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.

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Additionally, we lease capacity of 34.66 TPE from the following satellites: Apstar-5C HTS (138 E) in the amount of 32.93 TPE, Apstar-9 (142 E) in the amount of 0.21 TPE, and JCSAT 4B (124 E) in the amount of 1.26 TPE.

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In 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.

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International Networks

Through Telin, we continue to develop our international network infrastructure in order to support our international expansion strategy and vision to be the “King of Digital in the Region”. We operate international gateways in Batam, Jakarta, and Surabaya to route outgoing and incoming calls on our IDD service (“007” and “01017”). We also operate voice gateways in Singapore and Hong Kong to offer voice services from or to any country. As of December 31, 2024, we owned and operated an international fiber optic backbone network totaling 64,700 km.

We are a member of multiple submarine cable consortiums, including Thailand-Indonesia-Singapore, two routes of Batam-Singapore, Dumai-Malacca, Asia-America Gateway, Southeast Asia-Japan, Southeast Asia-Middle East-Western Europe 5 (SEA-ME-WE 5), South East Asia-United States (SEA-US) and IGG, which connects major cities in Indonesia with Asia, Europe, and the US. IGG also provides an express connection between the SEA-ME-WE 5 and SEA-US cable systems.

Moreover, we also operate and have rights of use for fiber optic infrastructure totaling 134,040 km in the aggregate under a long-term telecommunications lease agreement with other global submarine cable operators/consortiums. This includes the following submarine cables: 9,620 km of the Unity/EAC-Pacific network, 11,629 km of the FASTER network, 2,700 km of the EAC-C2C network, 2,700 km of the APCN-2 network, 6,500 km of the Asia Pacific Gateway (APG) network, 7,000 km of the Asia Submarine-cable Express (ASE)/Cahaya Malaysia network, 2,700 km of the TGN-Intra Asia (TGN-IA) network, 20,000 km of the Southeast Asia-Middle East-Western Europe 4 (SEA-ME-WE-4) network, 20,000 km of the Asia Africa Europe-1 (AAE-1) network, 8,100 km of the Bay of Bengal Gateway (BBG) network, 12,091 km of the Imewe network, 15,000 km of the Europe India Gateway (“EIG”) network, and 6,000 km of the Hibernia Transatlantic network.

In 2020, Telin along with the Southeast Asia-Japan Cable 2 (SJC2) consortium initiated the deployment of 10,500 km of submarine cables laid in intra-Asia, connecting China, Japan, South Korea, Taiwan, Thailand, Vietnam, and Hong Kong SAR. As of the date hereof, these cables are expected to be ready for sale at the latest by the first quarter of 2025.

In 2021, Telin commenced construction of a 20,000 km of submarine cable with the Bifrost Cable System consortium which will connect Singapore, Indonesia, the Philippines, Guam, and the west coast of North America.

In 2022, Telin joined the SEA-ME-WE-6 cable consortium, which is constructing a cable to connect Southeast Asia, the Middle East and Europe. The SEA-ME-WE 6 cable will connect Singapore, Malaysia, Bangladesh, Sri Lanka, India, Pakistan, Djibouti, Saudi Arabia, Egypt, and France. This 19,200 km-long cable is expected to provide additional diversity and resilience for the significant amount of traffic between Asia and Europe. Compared with other options, the SEA-ME-WE 6 will offer one of the lowest latencies available between Southeast Asia, the Middle East and Western Europe and will have a capacity of more than 100 terabytes per second. As of the date hereof, this cable is expected to be completed in 2026.

To continue its expansion in 2023, Telin commenced construction of the Indonesia Cable Express initiative (“ICE”). The ICE initiative aims to develop seven innovative cable systems that will connect and provide low latency and direct data center-to-data center connectivity. Additionally, in 2024, Telin signed an MoU for the construction of the ICE Cable System.

To respond to high demand for connectivity services, especially between Singapore and Europe, Telin completed the acquisition of PEACE Cable Spectrum in 2024 to strengthen and diversify connectivity from Southeast Asia to Europe. Telin also acquired 1/4 fiber pairs of the Topaz Cable System, connecting Japan to the US, to meet market demand. The Topaz Cable System is expected to be ready for service by the first quarter of 2025.

Since the deployment of the SJC-2 Cable System in 2018, all submarine cables used by Telin are equipped with Open Cable Technology for efficient use of capacity. Telin maintains control over the fiber optic infrastructure, including the physical cables and the associated bandwidth, enabling it to provide guaranteed bandwidth for each member of the respective cable consortium. These submarine cables are monitored and supported 24/7 by the Telin World Hub Operation and Command Center (TOCC).

As of the date hereof, to support our international voice and data services, Telin operates 58 points of presence throughout the world, including 26 points of presence in Asia and the Middle East (11 in Indonesia which are used for supporting the international network, four in Singapore, four in Hong Kong, two in Kuala Lumpur, and one in each of Dili, Tokyo, Taipei, Yangon and Dubai), 19 points of presence in Europe (one in each of London, Amsterdam, Frankfurt, Warsaw, Vienna, St. Petersburg, Bucharest, Prague, Switzerland, Milan, Manchester, Luxemburg, Brussels, Sofia, Marseille, Paris, Moscow, Helsinki, and Madrid), 13 points of presence in the United States and Canada (one in each of Montreal and Toronto, two in Los Angeles and one in each of Palo Alto, Ashburn, San Jose, New York, Guam, Hawaii, Seattle, San Francisco and Atlanta).

Geographic Distribution of Revenues

International expansion has become 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. The following table sets forth the distribution of our revenues by geographic markets for the years indicated therein.

Revenue Controls

As 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.

Overview of Telecommunications Services Rates

Under 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.

a.           Telecommunications Services Tariffs

Under the MoCD Regulation No. 5/2021, telecommunications services tariff consist of basic telephony service tariffs, value-added telephony service tariffs, and multimedia service tariffs, as described below:

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All the aforementioned tariffs follow the below tariff structure:

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b.           Telecommunications Network Tariffs

Under the MoCD Regulation No. 5/2021, telecommunications network tariffs consist of basic interconnection tariffs, and network lease tariffs, as described below:

The 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.

MoCD 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 Service, and Provision Procedure of Network Lease Service Owned by Dominant Network Lease Service Providers in agreement with the Telkom proposal.

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c.           Tariffs for Other Services

The 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.

Marketing, Sales and Distribution

We have implemented a comprehensive marketing and promotional strategy to bolster our brand and to increase sales, including through digital marketing and the development of our product and service distribution channels. To increase sales, we also use above and below-the-line marketing channels to promote our services to certain parties and communities. We also continue to place advertisement in printed and electronic media and implement marketing methods such as point of sales broadcasting as well as promotion and sponsorship events.

The following provides a description of our marketing and promotional strategies by customer segment.

Mobile Customers

In 2024, Telkomsel continued to implement and incentivize healthier business practices in the industry through price adjustments after competing intensely on prices in the past. Major competitors also implemented price rationalization initiatives, suggesting that industry prices will remain at more sustainable levels than in recent years. Additionally, with the announcement in 2024 of industry consolidation in the form of a merger between PT XL Axiata Tbk and PT Smartfren Telecom Tbk, we expect a healthier industry environment to be fostered as such consolidation promotes market rationality and price stabilization.

In 2024, we also enhanced our digital lifestyle related video, games, and music content, including by increasing the market presence of MAXstream in the video streaming industry through expanded partnerships with major content partners and original MAXstream content. We also expanded our footprint in the mobile gaming industry through Dunia Games, and expanded our presence in music streaming with Langit Musik, all with the goal of enhancing the customer experience.

In 2024, we continued to develop Telkomsel Orbit, a home wireless internet service, as an effort to leverage our strong network capacity and to cater to demand in areas where fixed broadband cannot penetrate. As of December 31, 2024, we had 159.4 million cellular subscribers, comprising 151.4 million prepaid cellular subscribers and 8.0 million postpaid cellular subscribers.

We continuously implement personalized offerings for mobile customers through dynamic customer segmentation and customer value management, targeting specific groups. This approach allows us to conduct targeted marketing campaigns leveraging data analytics. At the same time, we address market demand, strengthen market presence, and address affordability concerns by delivering affordable customer service and products to capture new customers in the mass-market segment, through the launch of Telkomsel Lite in early 2024.

Our focus remains on maintaining a stable subscriber base and driving ARPU resilience to help establish a solid foundation of quality subscribers and market share. This includes encouraging upgrades to higher-tier packages and enhancing digital content to attract higher-value segments over time, thereby fostering growth in customer consumption and productivity. Other strategic initiatives include network optimization, cost optimization, and the strengthening of our core broadband services.

See “– Business Portfolios – 1. Mobile Segment.”

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Consumer Customers

In 2024, IndiHome remained our flagship consumer product, with a strategy to accelerate fixed broadband penetration by addressing diverse segments with targeted pricing strategies. Telkomsel’s strategy to bridge the home and mobile connectivity experience sought to increase fixed broadband adoption, given the low penetration of fixed broadband services in Indonesia, against the backdrop of a nearly saturated cellular service market.

Despite growing competition, we strive to remain competitive through the launch of EZnet, which complements existing offerings to capture new opportunities and address affordability concerns of customers in the mass-market segments and of targeted customer groups and areas. 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 improved response times to customer complaints, particularly in the event of service disruptions and other technical issues.

We design our service offerings, which span from 10Mbps up to 300Mbps, to deliver on value, aiming to meet the needs of and aim to maintain affordability for our broadened segments of customers through a wide selection of customer-centric offerings which includes bundled contents. The IndiHome Integration has fostered a unified customer strategy, enhancing our ability to cross-sell and up-sell. We offer personalized services through advanced data analytics, which enable us to refine our customer segmentation by utilizing customer data profiles to tailor offerings and pricing strategies. Our problem resolution is supported by an end-to-end traceable customer relationship management process, allowing us to anticipate and address issues before they negatively impact our customers. While our strategy to accelerate our fixed broadband penetration has led to an increase in our customer base, we are also focusing on encouraging higher-end customers to upgrade to premium packages and bundled content, with the aim of enhancing ARPU resilience.

Our access points provide wide coverage, with the number of fixed broadband IndiHome B2C subscribers having increased by approximately 0.4 million from the integration of our IndiHome B2C business into Telkomsel on July 1, 2023 to December 31, 2023 amounting to us having 8.7 million IndiHome B2C subscribers at the end of 2023. As of December

31, 2024, we have a total of 10.8 million fixed broadband IndiHome subscribers, including 9.6 million IndiHome B2C subscribers.

Enterprise Customers

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In 2024, we refined our enterprise customers approach by targeting high-value enterprise customers through strategic account management. This involved offering tailored solutions to deepen customer relationships.

Our marketing strategy for enterprise customers aims to:

Our sales approach provides tailored support across various enterprise customers segments:

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Wholesale and International Business Customers

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Our wholesale and international business segment serves a mix of other domestic operators, service providers, digital entities, global wholesalers, carriers, and related enterprises, such as those utilizing overseas data centers and international connectivity. Additionally, through our Non Geostationary Orbit satellites, we cater to retail customers internationally.

Our marketing and sales strategy for wholesale and international business customers focuses on:

Digital Service Customers

For our digital service customers, our marketing strategy focuses on strengthening and improving digital innovation, including by:

We tailor our sales strategy to each particular digital business and our digital customers’ needs. We offer customer care and channel management, including through contact centers, dedicated account management for large enterprises, websites, and social media.

Our digital service customers program focuses on improving IndiHome services. For example, we promote the digital touchpoint for IndiHome’s customers, which also offers Disney+ Hotstar in a starter bundle package, Indibox as a source of value-added services (e.g., video content, games, and certain Google applications), GameQoo as a cloud gaming service and also IndiHome Smart as an IoT home service. Customers can enjoy these value-added services by subscribing and paying an additional price.

Distribution Channels

Our primary distribution channels for products and services in 2024 included:

Licensing

To provide national telecommunications services, we have product and service licenses that are consistent with applicable laws, regulations, and decrees.

Cellular

Telkomsel 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. 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.

Fixed Network and Basic Telephony Services

We have the following licenses to operate fixed local networks, fixed long-distance direct line networks, fixed international call networks and fixed closed networks:

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These licenses do not have set expiry dates, but they are evaluated every five years.

International Calls

We have a license to operate a fixed network to provide international call services pursuant to MoCD Decree No. 082/TEL.01.02/2021.

We 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.

According 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.  

DGPIO 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”).

The foregoing licenses do not have set expiry dates, but they are evaluated every five years.

IDD Services

We 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.

VoIP

We 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.

ISP

We 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.

Internet Interconnection Service

We 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.

Data Communication System (“SISKOMDAT”)

We 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.

Payment Method Using E-Money

Following 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.

In the midst of digital wallet business competition, LinkAja has a business strategy to not only serve consumers under the B2C business model, but also provide business solution services under the B2B business model. LinkAja’s business solution service provides various features such as fund disbursement, cash collection, digital payments through QRIS, merchant applications and others, digital ecosystems, and advertising services. LinkAja targets MSMEs and corporations in various industries. LinkAja also collaborates with Bank Syariah Indonesia to provide sharia-compliant digital transaction services. It also works with Islamic organizations, communities, and MSMEs to expand sharia-compliant digital partnerships. In addition, LinkAja partners with philanthropic institutions and develops digital features, including recurring payments and auto-debit solutions, to promote financial inclusion in Indonesia.

Administration of Source of Fund and Remittance Services

We 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.

IPTV

Since 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.

However, 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.

Construction Services Business

Certain 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.

On 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.

Content Service Provider

We 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.

Trademarks, Copyrights and Patents

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We 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.

The 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.

Corporate Social Responsibility and Human Capital Management

We are dedicated to fostering a sustainable business and society. Our efforts encompass enabling connections, generating employment, and driving digital innovation. Our sustainability strategy, grounded in our five pillars of ethics, growth, human capital, societal contribution, and environmental stewardship, is regularly refined to mitigate risks and grasp new opportunities.

Our governance framework demonstrates our ambition to become a partner of choice for customers, suppliers, and communities, backed by a firm dedication to ethical practices. All our employees are required to uphold our ethical standards in their daily work, and we provide by 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 accolades for excellence in corporate governance and security underscore our achievements in these areas.

In 2024, we achieved numerous awards and recognitions for our human capital management initiatives, which included leadership in employment branding, CSR, women empowerment, and diversity, equity and inclusion. Below is a summary of the awards received:

We rely on our performance growth pillar to enhance and modernize our business through innovation and digitalization, so that we may operate sustainably and adapt to changes. By digitizing and streamlining our operations, we intend to maintain and promote our business’s 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 preempt or mitigate cybersecurity risks and maintain our infrastructure’s integrity. Collaborative initiatives with law enforcement agencies enhance security, and we incorporate customer feedback to refine our offerings.

We prioritize managing human capital because we believe that our employees, managers, and talents are key to becoming and remaining a leading digital telecommunications player. Our human capital management practices focus on equitable recruitment, diversity, positive labor relations, and personal growth. We try and foster an inclusive culture, offering equal training and advancement opportunities to attract and retain top talents. This approach is informed by international norms on human rights and gender equality. As of December 31, 2024, women held approximately 35.2% of managerial roles, making up 45.2% of our workforce and 62.2% of the year’s 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 in 2022 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 — Employees.”

Our approach to social impact is proactive and multifaceted, encompassing philanthropy, community empowerment, and infrastructure investment. We aim to maintain rigorous quality standards for our products and contribute positively to the community through various initiatives. In 2024, we committed approximately Rp144.8 billion to CSR and environmental efforts throughout Indonesia. These efforts included contributions to digital education, improvements to access to food, water, and healthcare, and quality-of-life of enhancements for individuals with disabilities. We also supported MSMEs through training and entrepreneurship programs, while promoting rural digital integration through the Smart Village Nusantara project. Our infrastructure projects focused on sustainable development, including the installation of renewable energy street lighting and the expansion of internet connectivity to underserved regions. Additionally, we funded social initiatives such as elderly housing, construction of rural suspension bridges, and environmental conservation measures such as reforestation and marine ecosystem restoration. Infrastructure enhancements included renewable energy-powered public lighting and internet access expansion for remote areas, aligning with national development goals. We also invested in housing for the elderly, suspension bridge construction for rural access, and ecological efforts such as reforestation and coral reef rehabilitation.

Our sustainability strategy seeks to mitigate the environmental impact of our operations and businesses. We are committed to building an eco-friendly culture and extending environmental management practices beyond our immediate operations. We aim to lessen the telecommunications industry’s footprint by reducing energy use, emissions, and managing electronic waste effectively. We have implemented several practices: enhancing energy efficiency, promoting renewable energy adoption, responsible waste handling, careful water use, and procuring energy-saving hardware. Oversight of environmental policies is centralized under the head of each business unit. Measures to decrease energy consumption include using LED lighting, installing reflective glass to cut down on air conditioning use, managing cooling systems, and optimizing electricity use with devices such as capacitor banks and timers. Plans to install rooftop solar panels are also being assessed as of the date hereof. Our network infrastructure improvements entail AC optimization and replacing old equipment with more energy-efficient alternatives, alongside expanding solar energy usage. Water-saving initiatives feature automatic taps and reusing AC condensation. Transportation is made eco-friendlier by encouraging cycling to work with bike parking facilities. Through digitalization, we are reducing paper trails by encouraging online communication and virtual meetings. Invoicing processes are now paperless, with digital channels in use for customer billings, such as apps (MyTelkomsel), email, outbound calls, and text notifications on Pay TV services. Our corporate culture is focused on sustainability and responsible practices, integrating ESG principles into business decisions. We engage with communities and within our organization to foster a sense of environmental responsibility.

See “Business Overview — Strategy — Environmental, Social and Governance (“ESG”) matters” above for more information on our ESG strategies.

The Telecommunications Industry in Indonesia

In 2024, Indonesia’s GDP grew by 5.03%, with further expansion expected in 2025, according to Government data. In its January World Economic Outlook Update, the IMF forecasts a 5.1% growth for the Indonesian economy in 2025. 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 business.

The 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 until 2024, particularly with the recent price increases implemented by all major operators at the end of 2024. Operators have sustained healthier market conduct amidst rising demand for high-quality data services.

As of December 31, 2024, according to our internal estimates, Indonesia had approximately 312.9 million cellular subscribers, a 0.9% decrease from 315.6 million in 2023, with Telkomsel maintaining a market share of approximately 50.9%. Following the IOH merger and the announcement of the XLSmart merger in 2024, 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 the customer experience.

With 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.

Fixed broadband penetration in Indonesia remains 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 10.8 million IndiHome subscribers as of December 31, 2024.

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Competition

Our cellular services business, operated through our majority-owned subsidiary "Telkomsel," faces competition primarily from IOH and XL Axiata. The competitive environment in Indonesia is evolving as competitors expand service coverage into regions where Telkomsel has an established presence. Supply and demand conditions began to stabilize in 2024, indicating a healthier competitive landscape.

In late 2024, XL Axiata and Smartfren, part of the Sinar Mas Group, announced their merger. Historically, mergers between larger and smaller operators have helped create a more balanced competitive landscape by reducing aggressive pricing practices. This consolidation is expected to result in more rational pricing across the industry and support a more sustainable market structure. For further information, see “Item 3D—Risk Factors—Risks Related to Our Business—Risks Related to our Fixed and Cellular Telecommunications Business—Competition from existing cellular service providers may adversely affect our cellular services business.”

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Business Competition Law

The 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.

The 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.

The 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.

Competition 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.

The 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.

In 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.

The Job Creation Law 2023 amended the Business Competition Law in the following ways:

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The 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.

Furthermore, 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.

Additionally, 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.

Cellular

We operate our cellular service business through Telkomsel.

As of December 31, 2024, Telkomsel remained the largest cellular provider in Indonesia, with approximately 159.4 million cellular subscribers and a market share of approximately 50.9%, based on our internal estimates. According to publicly available data, the next largest providers were IOH and XL Axiata, based on number of subscribers as of December 31, 2024, and information publicly released by each of these companies. The penetration of SIM cards in the cellular industry in Indonesia is high, significantly over 120%, making continued growth in penetration increasingly difficult. There were approximately 312.9 million cellular subscribers in Indonesia as of December 31, 2024, compared to approximately 315.6 million as of December 31, 2023. Despite a penetration rate exceeding 120%, which indicates market saturation, the number of cellular subscribers has remained relatively stable. This suggests that a significant portion of the population continues to use multiple SIM cards. Further growth becomes increasingly difficult as there are fewer potential new subscribers. Additionally, changes in regulations or policies regarding SIM card registration, usage, or distribution could also impact the number of subscribers. The Government’s reinforcement of the prepaid SIM registration policy since 2018, as customers no longer have the freedom of accumulating several numbers provided by various operators, has resulted in a better-quality customer base with a higher proportion of active subscribers and more efficient SIM card production costs. Due to a reduction in the number of starter packs, operators can provide better quality services to customers. Additionally, operators now focus more on offering renewal promotions than on new starter pack promotions, as demonstrated by the supply and demand condition that began to stabilize by the end of 2024, indicating a healthier competitive environment. With the overall current competition landscape being stagnant and highly saturated in the Java region, other operators are adjusting their prices while also aggressively expanding their networks outside the Java region seeking a path towards profitability. We believe that the registration policy, assuming continued implementation, will also have positive long-term impact and support the emergence of healthier competition in the industry.

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The shifting trend from legacy services (such as voice and SMS) to data services continues to develop, driven by cheaper prices of smartphones as well as the rapidly growing youth customer segment. Data traffic has been growing significantly, while SMS service traffic has been decreasing in the last five fiscal years. Since 2017, Telkomsel has seen a steep decrease in voice usage. Minutes of usage per mobile subscriber also started to decrease in the second half of 2017. These trends persisted in 2024 and are likely to continue in the foreseeable future, as they are attributable to the substitution of traditional voice and SMS services to OTT based calling and messaging services as smartphone penetration in Indonesia has risen.

Despite these challenges, our efforts to promote customer productivity and encourage healthy usage behaviors have delivered positive results, particularly in our Digital Business segment, which continues to grow. Data traffic growth has been largely driven by content consumption, and we remain focused on supporting customers in adopting more productive digital habits as internet connectivity becomes increasingly essential.

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The following table sets out information as of December 31, 2024, for Telkomsel:

Note:

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Fixed Broadband Services

We face competition in the fixed broadband market from major providers such as XL Home, IconNet, Biznet Home, and MyRepublic, 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.

Data Centers

Companies 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.

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International Direct Dialing (IDD)

We 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.

Voice over Internet Protocol (VoIP)

We 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 Telekomindo and PT IP Telecom Multimedia Indonesia also provide licensed VoIP services in Indonesia.

Satellite

The 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.

We 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. Our Telkom-3S satellite began operating in April 2017 and our Telkom Merah Putih satellite began operating in September 2018. Our Telkom-3S satellite operates at orbital slot 118 E and our Telkom Merah Putih satellite operates at orbital slot 108 E. In February 2024, Telkomsat successfully launched Telkom Merah Putih-2 in orbital slot 113 E.

Tower

Within the tower market, we face competition from several other companies, including PT Tower Bersama Infrastructure Tbk, PT Profesional Telekomunikasi Indonesia, and PT Solusi Tunas Pratama Tbk.

From 2018 to 2023, the tower market in Indonesia experienced reduced demand due to industry consolidation and spectrum reallocation within the mobile sector. In 2024, the Indonesian mobile and tower sectors continued to see substantial activity, with mergers and acquisitions remaining a key focus. MNOs have increasingly divested tower assets to prioritize capital generation for expanding their networks and improving service quality, aligned with the rising demand for advanced connectivity infrastructure and 5G readiness.

The 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 like fiber connectivity for improved mobile services have spurred tower market growth.

In 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.

As of December 31, 2024, we had approximately 43,825 towers, including 39,404 towers owned by Mitratel, and approximately 4,421 towers owned by Telkomsel.

Legal Basis and Regulation

The regulatory framework for the Indonesian telecommunications industry comprises specific laws, Government regulations, ministerial regulations and ministerial decrees enacted and issued from time to time.

Telecommunications Law

The 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.

The 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.

The Telecommunications Law was implemented through several Government Regulations, Ministerial Regulations and Ministerial Decrees. Key regulations include:

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Telecommunications Industry Regulators

The 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.

Classification and Licensing of Telecommunications Providers

The 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.

Licenses 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.

Since 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.

GR 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.

Cellular

Cellular 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 frequency 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:

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Interconnection

The 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.

On 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 ensure 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.

Further, 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.

MoCD 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.

VoIP

In 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.

IPTV

In 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, and facilitating interactive communication between the provider and users.

Satellite

In 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.

Consumer Protection

Under 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.

USO

All 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”).

USO 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.

Regulatory Charges

The 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.

Further, telecommunications equipment and devices are subject to a certification fee. Telecommunications equipment and devices that are used for research, development, or 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.

Telecommunications Towers

Operating 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.

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Based 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 for 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.

Under 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).

The 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.

Content Provider Services

Content provider service is regulated by MoCD in accordance with MoCD Regulation No. 13/2019, as amended.

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C.          ORGANIZATIONAL STRUCTURE

We employ a strategic control framework for the management of our Group, which we believe grants productive flexibility to our subsidiaries based on their business needs and characteristics. Our corporate office outlines the overall corporate strategy, and then delegates the implementation of such strategy to each CFU 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 four CFUs, with each unit overseeing subsidiary operations within specific customer segments:

In addition, we have five functional units (“FUs”) which perform certain specified internal corporate functions. Our FUs are discussed in greater detail below:

Our mobile CFU has been integrated into the consumer CFU due to the IndiHome Integration. For more information, see “—Strategy—Enhancing our Assets through Acquisitions and Spin-offs.”

For 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, 2024, is contained in Notes 1d and 11 to our Consolidated Financial Statements included elsewhere in this report.

The following diagram illustrates our corporate structure of our principal operating entities as of the date of this report:

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D.           PROPERTY, EQUIPMENT AND RIGHT OF USE ASSETS

Our 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, and (viii) 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.

Except 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 use of assets, freely tradable and may be placed as security under loan agreements.

We 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 2025 and 2071. During 2024, there were deductions in Group leases, including expired leases and reclassifications related to land rights, buildings, transmission, installations, equipment, and other assets used in operations, amounting to Rp539 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. The right to build can further be 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 Note 12 and Note 13 to our Consolidated Financial Statements.

All 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 Rp2,190 billion as of December 31, 2024, have been placed as collateral for loan agreements. Please refer to Notes 19a and 20c to our Consolidated Financial Statements.

Insurance

As of December 31, 2024, our property and equipment (excluding land rights), with a net carrying amount of Rp 178,692 billion was insured against fire, theft, earthquake and other specified risks, under blanket policies totaling Rp44,143 billion, HK$10 million, and SG$219 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.