MARCH 2014 LEGAL ALERT. banking

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1 LEGAL ALERT MARCH 2014 SSEK Legal Alert is a monthly publication of SSEK, Indonesian Legal Consultants. SSEK s lawyers, advisors and associates provide a wide range of legal services to Indonesian and multinational corporations, banks, joint ventures and other organisations. SSEK Legal Alert is a monthly survey designed to keep our clients up to date with the latest legal developments in Indonesia. To subscribe, visit our website: * * * banking Bank Indonesia Circular Letter No. 16/1/DKSP, dated January 10, 2014, regarding Report on the Implementation of On-Line Fund Transfer by Indonesian-incorporated Non- Bank Business Entities. This Circular Letter implements Bank Indonesia Regulation No. 14/23/PBI/2012 regarding Fund Transfer and Bank Indonesia Circular Letter No. 15/23/ DASP regarding Implementation of Fund Transfer. Under this Circular Letter, any domestic transfer or overseas transfer must be reported through an on-line system called the Non- Bank Fund Transfer Report System. This Circular Letter establishes the procedures for filing reports, including the timeline for such reports, and the form of such reports. This Circular Letter came into effect on the date of its Bank Indonesia Regulation No. 16/1/PBI/2014, dated January 21, 2014, regarding Consumer Protection for Payment Systems. This Regulation stipulates the obligations of banks/non-bank institutions in providing payment systems for customers. This Regulation requires banks/non-bank institutions to include standard clauses on certain types of agreements with customers. It also requires banks/non-bank institutions to put in place a customer complaint system. This Regulation came into effect on the date of its Certain obligations of payment system operators mandated by this Regulation will come into effect on July 1, Bank Indonesia Circular Letter No. 16/3/DPTP, dated March 3, 2014, regarding the Implementation of the Transfer of Management of Bank Indonesia Liquidity Credit in the Framework of Program Credit. This Circular Letter implements Bank Indonesia Regulation No. 5/20/PBI/2003 regarding the Transfer of Management of Bank Indonesia Liquidity Credit in the Framework of Program Credit, as amended by Bank Indonesia Regulation No. 14/10/PBI/2012. This Circular Letter governs the rights and obligations of appointed state-owned enterprises in managing Bank Indonesia liquidity credit. This Circular Letter further stipulates the procedures for the payment and acquittal of Bank Indonesia liquidity credit, as well as the implementation of sanctions for appointed state-owned enterprises in managing Bank Indonesia liquidity credit. This Circular Letter came into effect on the date of its Deposit Insurance Institution ( LPS ) Regulation No. 1/PLPS/2014, dated February 6, 2014, regarding the Sale of Salvageable Failing Bank Shares. Under this regulation, LPS must sell all salvageable failing bank shares. This Regulation sets forth the procedures for the sale of such shares by strategic sale or other methods that are in line with prevailing laws and regulations. This Regulation revokes LPS Regulation No. 2/ PLPS/2011 regarding the Procedures for the Sale of Salvageable Failing Bank Shares. This Regulation came into effect on the date of its SSEK legal alert 1

2 customs and excise Minister of Finance Regulation No. 11/PMK.011/2014, dated January 17, 2014, regarding the Import Duty Borne by the Government for Goods and Materials Imported to Produce Goods and/or Service for Public Interest and to Increase the Competitive Advantage of Certain Industrial Sectors for the 2014 Budgetary Year. Article 2 (2) provides that Import Duty Borne by the Government ( BM DTP ) is granted based to: (a) goods and/or services that are for the public interest, are consumed and/or used by the general public, and/or protect the interests of consumers; (b) goods and/or services that increase the competitive advantage of certain industrial sectors; (c) goods and/or services that help create jobs; and (d) goods and/or services that increase state revenue. This Regulation came into effect on the date of its Minister of Finance Regulation No. 59/PMK.04/2014, dated March 25, 2014, regarding Customs Registration. The Regulation aims to anticipate the development of information technology in the field of customs. It also implements Article 6A, paragraph (3) of Law No. 10 of 1995 regarding Customs, as amended by Law No. 17 of This regulation provides procedures for (i) filing registration applications with the Directorate of Customs and Excise; (ii) the examination and assessment of registration data; (iii) registration approval; (iv) changing registration data; (v) blocking and revoking a Custom Identity Number ( NIK ); and (vi) the special provision of free zones. This Regulation comes into effect on June 1, Director General of Customs and Excise Regulation No. PER-05/BC/2014, dated February 3, 2014, regarding the Amendment of Director General of Customs and Excise Regulation No. PER-15/BC/2012 regarding the Procedures for Refunding Import Duty that Has Been Paid for Goods and Materials Imported to Be Refined, Assembled, or Installed on other Goods for Export Purposes. This Regulation provides that a refund may be given to business entities that have obtained a Refund Company Identification Number ( Refund NIPER ). It also sets out detailed requirements and mechanisms to obtain such Refund NIPER. The appointed Regional Office Head or Customs Official will receive and examine such Refund NIPER application and the accompanying documents, and approve or reject such application. This regulation came into effect on February 4, energy and natural resources Minister of Energy and Mineral Resources Regulation No. 5 of 2014, dated February 4, 2014, regarding Procedures for the Accreditation and Certification of Electricity Businesses. This Regulation sets out accreditation procedures for professionals and firms in the electricity industry, more specifically, those that fall under the category of ancillary service providers. Ancillary service providers are f professionals or firms in the electricity industry that provide consultation, construction, inspection, operational, and maintenance services for electrical installations. This Regulation repeals and replaces Minister of Energy and Mineral Resources Decree No K/30/ MEM/2002 on the Electricity Competency Accreditation Commission, as lastly amended by Minister of Energy and Mineral Resources Regulation No. 20 of 2011, in its entirety and revokes several articles of Minister of Energy and Mineral Resources Decree No K/40/MEM/2001 on the Standardization of Electricity Technical Competency, as lastly amended by Minister of Energy and Mineral Resources Regulation No. 19 of 2011 and Minister of Energy and Mineral Resources Regulation No. 45 of 2005 on Electricity Installations, as amended by Minister of Energy and Mineral Resources Regulation No. 46 of This Regulation came into effect on the date of its SSEK legal alert 2

3 Minister of Energy and Mineral Resources Regulation No. 7 of 2014, dated February 28, 2014, regarding the Implementation of Reclamation and Post-Mining Activities at Mineral and Coal Mining Businesses. This Regulation implements Articles 9, 12, 15, 18, 28, 36, 43, 49 and 51 of Government Regulation No. 78 of 2010 regarding Reclamation and Post-Mining Activities. This Regulation applies to holders of exploration mining business permits ( Exploration IUP ), special exploration mining business permits ( Exploration IUPK ), operation production mining business permits ( Production Operation IUP ) and special operation production mining business permits ( Production Operation IUPK ). IUP holders must submit a Reclamation Plan and Post-Mining Plan. Failure to comply with this Regulation will result in administrative sanctions ranging from written warnings to permit revocation. This Regulation came into effect on the date of its environment Minister of Environment Regulation No. 2 of 2014, dated February 5, 2014, regarding Inclusion of the Eco-label Logo. An Eco-label Logo on a product proves that such product has complied with environmental requirements, including in the obtaining of raw materials, production process, distribution, utilization, and/or the disposal of product residuals. There are two types of Eco-label Logos: Indonesian Eco-label Logo (Logo Ekolabel Indonesia or LEI ) and Indonesian Self-Declaration Eco-label Logo (Logo Ekolabel Swadeklarasi Indonesia or LESI ). An LEI is included on products after obtaining a certificate from the Eco-label Certification Institution (Lembaga Sertifikasi Ekolabel or LSE ) and after obtaining approval for inclusion from the Minister of Environment. An LESI is included on products after obtaining a letter from the Eco-label Verification Institution (Lembaga Verifikasi Ekolabel or LVE ) and after obtaining approval for the inclusion from the Minister of Environment. This Regulation came into effect on the date of its Government Regulation No. 2 of 2014, dated January 16, 2014, regarding Nuclear Installation Licensing and Nuclear Material Utilization. This Regulation implements Article 17, paragraph (3) of Law No. 10 of 1997 regarding Nuclear Power. This Regulation sets forth comprehensive provisions concerning the licensing of nuclear reactors, the licensing of non-reactor nuclear installations and licensing for the use of nuclear materials. This Regulation revokes Government Regulation No. 43 of 2006 regarding Nuclear Reactor Licensing and Government Regulation No. 29 of 2008 regarding Licensing for the Use of Nuclear Materials to the extent that it concerns licensing for the use of nuclear materials. This Regulation came into effect on the date of its finance Financial Services Authority ( OJK ) Circular Letter No. 1/SEOJK.07/2014, dated February 14, 2014, regarding Implementation of Education to Improve the Financial Literacy of Consumers and/or the Public. This Circular Letter was issued to implement OJK Regulation No. 01/POJK.07/2013 regarding the Protection of Financial Services Sector Consumers. This Circular Letter requires financial service businesses to educate customers and the public on financial literacy, which comprises the knowledge and skills to manage funds. Each financial service business must prepare a financial literacy education plan and include the same in its annual report to the OJK. This Circular Letter comes into effect on August 6, OJK Circular Letter No. 2/SEOJK.07/2014, dated February 14, 2014, regarding the Service and Settlement of Consumer Complaints against Financial Service Businesses. This Circular Letter stipulates the mechanisms for receiving and settling complaints, with such settlement to be in the form of a written apology or remedy. This Circular Letter also SSEK legal alert 3

4 obligates financial service businesses to establish a working unit or appoint officials to implement the servicing and settlement of consumer complaints. This Circular Letter will come into effect on August 6, Head of Financial Transaction Report and Analysis Center ( PPATK ) Regulation No. PER-02/1.02/PPATK/02/2014, dated February 27, 2014, regarding Integrated User Information System. This Regulation implements Article 12, paragraph (4) and Article 12, paragraph (2)g of Presidential Regulation No. 50 of 2011 regarding the Implementation of the Authorities of the PPATK. Under this Regulation, financial service providers are required to provide information regarding customers to the PPATK. Such information to the PPATK is intended to combat money laundering and/or other crimes related to money laundering. This Regulation came into effect on the date of its forestry Minister of Forestry Regulation No. P.8/Menhut-II/2014, dated January 17, 2014, regarding Land Area Limitations Under Business License for Wood Forest Product Utilization for Natural Forests ( IUPHHK-HA ), Business License for Wood Forest Product Utilization for Industrial Plants ( IUPHHK-HTI ) and Business License for Wood Forest Product Utilization for Ecosystem Restoration ( IUPHHK-RE ) in Production Forests. This Regulation implements Article 31 of Law No. 41 of 1999 regarding Forestry. An IUPHHK- HA, IUPHHK-RE, or IUPHHK-HTI may be granted for a maximum of 50,000 hectares, with a maximum of two licenses for one company or for one parent company. There is an exception in the Regulation for Papua and West Papua, where an IUPHHK-HA, IUPHHK-RE, or IUPHHK-HTI may be granted for a maximum of 100,000 hectares, with a maximum of two licenses for one company or for one parent company. This Regulation came into effect on the date of its Minister of Forestry Regulation No. P.16/Menhut-II/2014, dated March 13, 2014, regarding Guidelines for the Borrow and Use of Forest Areas. This Regulation revokes Minister of Forestry Regulation No. P.18/Menhut-II/2011 regarding Guidelines for the Borrow and Use of Forest Areas and its amendments. This Regulation was issued to increase the management, control, and utilization of forest areas, including the acceleration of borrow and use services. This Regulation sets out detailed requirements, restrictions, and licensing for a number of business sectors to utilize forest areas for development and construction purposes. This Regulation came into effect on the date of its industry Minister of Industry Regulation No. 67/M-IND/PER/12/2013, dated December 12, 2013, regarding the Enforcement of Mandatory Indonesian National Standards for Aluminum Sulfate. This Regulation stipulates a mandatory Indonesian National Standard ( SNI ) for aluminum sulfate. Any company that produces aluminum must implement the SNI and obtain a Certificate for Product Utilizing SNI. This Regulation comes into effect six months after its enactment, i.e., on June 12, Minister of Industry Regulation No. 87/M-IND/PER/12/2013, dated December 27, 2013, regarding the Enforcement of Mandatory Indonesian National Standard for Palm Oil. This Regulation stipulates a mandatory Indonesian National Standard ( SNI ) for palm oil. Any company that produces or imports palm oil must implement the SNI and obtain a Certificate for Product Utilizing SNI. This Regulation comes into effect 15 months after its enactment, i.e., on March 27, SSEK legal alert 4

5 Minister of Industry Regulation No. 04/M-IND/PER/1/2014 of 2014, dated January 23, 2014, regarding the Granting of Recommendation to Companies in Bonded Zones to Sell Products Produced in Bonded Zones to Other Places in the Customs Area. This Regulation allows a company in a bonded zone to sell its products within the customs area in the amount of no more than 50% of the accumulated realization value of the previous year, as stipulated by the Government. The realization value includes the export value, production selling value to other bonded zones, production selling value to free trade areas, and production selling value to other economic areas determined by the Government of Indonesia. Such selling must be approved by the Director General of Customs and Excise, with a recommendation from the Ministry of Industry. This Regulation came into effect on the date of its Minister of Industry Regulation No. 05/M-IND/PER/2/2014 of 2014, dated February 17, 2014, regarding Procedures for Granting a Business License for Industrial Area an Expansion License for Industrial Area. A Business License for Industrial Area and Expansion License for Industrial Area are granted by the local authority where the industrial area is located (Regent/Mayor, Governor, or Minister of Industry). The Minister of Industry will also grant the licenses for a foreign investment company or if the industrial area was established pursuant to an agreement between the Indonesian Government and a foreign government. The Minister delegates his authority to the Indonesian Capital Investment Coordinating Board (Badan Koordinasi Penanaman Modal or BKPM ) for the issuance of the licenses. The Business License for Industrial Area remains valid so long as the company is engaged in business activities in the industrial area. The Business License can only be granted to legal entities established based on Indonesian law and domiciled in Indonesia, which includes state-owned or regional-owned companies, cooperatives, and privately owned companies. The Principal License should be obtained before the Business License. At the latest of two years after obtaining the Principal License, all obligations thereof must be completed. The extension of Principal License can be granted only one time for a maximum period of two years. This Regulation came into effect on the date of its Minister of Industry Regulation No. 09/M-IND/PER/2/2014 of 2014, dated February 17, 2014, regarding Provisions for the Granting of Recommendation for the Importation of Used Capital Goods. This Regulation requires certain companies that will import used capital goods to first obtain a recommendation from the Ministry of Industry. This recommendation will be valid for six months from the date of its issuance. Further provisions on the granting of such recommendation will be governed in a Regulation from the Director General of High-Tech Prime Industries. There are five types of companies that must obtain a recommendation from the Ministry of Industry to import used capital goods: (a) Reconditioning Companies, (b) Remanufacturing Companies, (c) Direct User Companies that import goods with specific HS Codes, (d) Direct User Companies for specific purposes (i.e., export development and investment, industrial relocation, or infrastructures development), and (e) Reconditioning Companies importing used capital goods with specific tariff post codes. This Regulation came into effect on the date of its enactment will remain in force until December 31, Minister of Industry Regulation No. 15/M-IND/PER/3/2014, dated April 1, 2014, regarding the Granting of Recommendation to Registered Exporters of Mining Products as a Result of Processing and Refining. This Regulation provides that exports of mining products as a result of processing and refining can only be conducted by companies that have been acknowledged as Registered Exporters of Mining Products as a Result of Processing and/or Refining. The Minister of Industry, through the Director General of Manufacturing Industries, will grant a recommendation to conduct such export activities. This Regulation came into effect on the date of its SSEK legal alert 5

6 manpower and transmigration Presidential Regulation No. 108 of 2013, dated December 27, 2013, regarding Forms and Content of Management Reports on the Social Security Program. This Regulation implements Article 37 (7) of Law No. 24 of 2011 regarding Social Security Implementing Agency (Badan Penyelenggara Jaminan Sosial or BPJS ). Article 2 (2) of this Regulation provides that the obligation to submit a program management report is applicable for the Health BPJS and Manpower BPJS. Article 3 further states that the period covered by the program management report runs from January 1 to December 31. Under Article 4, such Regulation must be publicized in an executive summary through electronic mass media and at least two published mass media that have national circulation. This Regulation came into effect on the date of its Ministry of Manpower and Transmigration Regulation No. 4 of 2014, dated March 10, 2014, regarding Work Hours and Break Periods for Oil and Natural Gas Business Activities. The Regulation provides specific provisions on overtime and break periods for workers employed by upstream oil and gas companies and oil and gas support service companies. It also provides overtime arrangements, including the calculation of wages to be received by concerned employees. This Regulation came into effect on March 10, tax Government Regulation No. 22 of 2014, dated March 19, 2014, regarding the Amendment of Government Regulation No. 41 of 2013 regarding Luxurious Taxable Goods in the Form of Motor Vehicles Subject to Sales Tax for Luxury Goods. This Regulation amends paragraph 8 of Article 2 of Government Regulation No. 41 of This amended paragraph 8 of Article 2 classifies four specific types of luxurious taxable goods in the form of motor vehicles that are subject to Sales Tax for Luxury Goods with a tax rate of 125%. This Regulation came into effect on 30 days after its enactment, i.e., April 18, Director General of Taxation Regulation No. 05/PJ/2014, dated February 18, 2014, regarding the Form and Contents of the Annual Income Tax Notification Letter for Upstream Oil and Natural Gas Taxpayers. This Regulation implements Article 31, paragraph (4) of Government Regulation No. 79 of 2010 regarding Refundable Operational Costs and Treatment of Income Tax in the Field of Oil and Natural Gas, and intends to provide legal certainty and improve tax services for and supervision of taxpayers in the upstream oil and gas industry. This Regulation revokes Director General of Taxation Regulation No. PER-28/PJ/2011 regarding the Form and Contents of the Annual Income Tax Notification Letter for Upstream Oil and Natural Gas Taxpayers. It came into effect on the date of its telecommunications Government Regulation No. 5 of 2014, dated February 4, 2014, regarding Licensing Requirements and Procedures to Produce, Distribute, and Use Pornographic Products. This Regulation implements Article 14 of Law No. 44 of 2008 regarding Pornography. It sets out the licensing requirements and procedures for educational and health institutions to produce and distribute pornographic materials, as well as measures on how to treat such materials. This Regulation also regulates the production, distribution, and use of pornographic materials for purposes outside the scope of education and health. It requires that a license be obtained for the production, distribution and use of pornographic products that are used in an appropriate context. This Regulation came into effect on the date of its SSEK legal alert 6

7 Minister of Communications and Informatics Regulation No. 11 of 2014, dated February 14, 2014, regarding Procedures to Impose Administrative Sanctions or Fines on Telecommunications Providers. This Regulation implements Government Regulation No. 7 of 2009 regarding Types of Non-Tax State Revenue Applicable at the Department of Communications and Informatics, as amended by Government Regulation No. 76 of This Regulation sets out the types of fines and the procedures for the Directorate General of Post and Telecommunications to impose such fines on telecommunications providers that fail to fulfill their obligations related to infrastructure development, service quality standards, service area coverage, interconnectivity, domestic product utilization, and others. This Regulation is applicable to telecommunications network providers and telecommunications service providers. It came into effect on the date of its Governor of the Jakarta Special Capital Region Regulation No. 14 of 2014, dated February 11, 2014, regarding the Management of Telecommunications Towers. This Regulation amends certain provisions on telecommunications towers in Jakarta and covers: (a) the requirements to build new telecommunications towers; and (b) the types of licenses that must be secured by operators/owners of existing and new telecommunications towers, which include the Building Construction Permit for telecommunications tower (Izin Mendirikan Bangunan of IMB ), Telecommunications Equipment Placement Permit (Izin Penempatan Perangkat Telekomunikasi or IPPT ), Tower Zone Recommendation, and Tower Construction Feasibility Letter (Surat Kelayakan Konstruksi Menara or SKKM ). This regulation is aimed at owners, managers, and parties that utilize telecommunications towers, including broadcast companies (radio and television) and mobile network carriers that operate in Jakarta. This Regulation repeals and replaces previous regulations. It came into effect on the date of its trade Government Regulation No. 10 of 2014, dated February 12, 2014, regarding the Requirements and Procedures for the Establishment of Warehouse Receipt Guarantor Institutions. This Regulation implements Article 44A, paragraph 3 of Law No. 9 of 2006 regarding Warehouse Receipt System, as amended by Law No. 9 of The purpose of a Warehouse Receipt Guarantor is to secure the rights and obligations of warehouse receipt holders or recipients of security rights against negligence or incompetence by warehouse managers in goods management and delivery. This Regulation came into effect on the date of its Minister of Trade Regulation No. 10/M-DAG/PER/1/2014, dated January 30, 2014, regarding the Amendment of Minister of Trade Regulation No. 67/M-DAG/ PER/11/2013 regarding the Obligation to Affix Indonesian-Language Labels on Goods. This amendment is aimed at harmonizing the regulation on Indonesian-language labels with the Minister of Trade regulation concerning the import of several types of telecommunications products. This Regulation changes the HS number for several types of telecommunications products in Attachment V of Minister of Trade Regulation No. 67/M-DAG/PER/11/2013. This Regulation will come into effect on June 25, Head of Commodity Futures Trading Regulatory Agency ( Bappebti ) Regulation No. 109/BAPPEBTI/PER/01/2014, dated January 30, 2014, regarding Derivative Contracts Traded on the Alternative Trading System ( ATS ). This Regulation sets out provisions on the types of derivative contracts and requirements for those contracts to be traded on the Alternative Trading System. The Appendix of this Regulation provides a list of derivative contracts that can be traded using the ATS, covering stock indexes, foreign currencies and commodities. Each derivate contract must be assessed by the SSEK legal alert 7

8 futures exchange and approved by the Head of Bappebti prior to trading on the ATS. This Regulation came into effect on the date of its enactment and all relevant parties must comply with this Regulation within six months of its enactment date. Head of Commodity Futures Trading Regulatory Agency ( Bappebti ) Regulation No. 111/BAPPEBTI/PER/01/2014 of 2014, dated January 30, 2014, regarding Association of Futures Trading Industry. This Regulation implements Article 44B, paragraph (1) of Law No. 32 of 1997 regarding Commodities Futures Trading, as amended by Law No. 10 of The purpose of the establishment of the Association of Futures Trading Industry is to support the development of commodities futures trading and to better coordinate the stakeholders in the industry. Under this Regulation, membership to the association is mandatory for anyone holding a license for commodities futures trading issued by Bappebti. This Regulation came into effect on the date of its Governor of the Jakarta Special Capital Region Regulation No. 158 of 2013, dated December 24, 2013, regarding the Procedures for Halal Certification for Restaurants and Non-Restaurants. Article 2 of this Regulation sets out that this Regulation is intended as a guideline for restaurant and/or non-restaurant entrepreneurs who serve food and beverages and who wish to obtain halal certification. Article 5 provides that the applicant must first obtain a Tourism Business Registration Certificate from the Tourism and Culture Service Office and a Hygiene Certificate from the Health Service Office or a Trade Business License from the Cooperative, Micro, Small and Medium-scale Business and Trade Service Office. The application will then be submitted to the Food, Drug and Cosmetic Review Institution of Majelis Ulama Indonesia ( MUI ). This Regulation came into effect on the date of its transportation Minister of Transportation Regulation No. PM 2 of 2014, dated February 12, 2014, regarding Additional Fees for Passengers on Domestic Scheduled Economy-Class Air Transportation. This Regulation implements Article, 126 paragraph (3) of Law No. 1 of 2009 regarding Aviation and Article 2, paragraph (5) of Minister of Transportation Regulation No. KM 26 of 2010 regarding the Calculation and Stipulation of Rates for Domestic Scheduled Economy-Class Air Transportation. Additional passenger fees on domestic scheduled economy-class air transportation are fees incurred by air transportation business entities outside the calculation of the distance tariff, with such fees to be borne by passengers. It is stipulated that such additional fees are temporary in nature. This Regulation came into effect 14 days after its enactment, i.e., on February 26, Minister of Transportation Regulation No. PM 6 of 2014, dated February 26, 2014, regarding Civil Aviation Safety Regulation Part 830 regarding Accident Notification and Reporting Serious Events Involving Civil Aircraft including Investigation Procedures for Accidents and Serious Events. This Regulation revokes Minister of Transportation Regulation No. KM 1 of It is intended to regulate occurrence reports (mandatory occurrence reports, voluntary occurrence reports, determination of occurrence reports and others), investigation procedures and the responsibilities and authority of the National Transportation Safety Committee. This Regulation came into effect on the date of its SSEK legal alert 8

9 miscellaneous Presidential Regulation No. 112 of 2013, dated December 27, 2013, regarding the Fourth Amendment of Presidential Regulation No. 26 of 2009 regarding the Implementation of Identification Card with the Basis of National Citizenship Number. Under this Regulation, Article 10 is amended so that a Non-electronic Identification Card is still applicable for citizens who have not obtained an electronic Identification Card until the latest December 31, This Regulation came into effect on the date of its * * * You can find our Legal Alert archive at blog.ssek.com. This publication is intended for informational purposes only and does not constitute legal advice. We have endeavored to update information where appropriate, but we are under no obligation to do so. Any reliance on the material contained herein is at the user s own risk. You should contact a lawyer in your jurisdiction if you require legal advice. All SSEK publications are copyrighted and may not be reproduced without the express written consent of SSEK. For more information, please contact ssek@ssek.com SSEK legal alert 9