A. [RESERVED] ​ 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. ​ 22 Table of Contents Summary of Risk Factors: Risks Related to Our Business Operational Risks · The telecommunications industry is characterized by intense competition and rapid technological change, and our ability to compete effectively depends on significant capital investment, access to sufficient spectrum, and successful adaptation to new technologies and market entrants. · Our business is highly dependent on the uninterrupted operation of our complex network infrastructure and information systems, which are vulnerable to disruption from operational failures, physical and cybersecurity threats, and other events beyond our control. · Damage to our reputation could negatively impact our business, financial condition, and results of operations. · 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. · 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. · Expected benefits from investment in new networks and technologies may not be realized. · We rely on third parties to supply and maintain our network infrastructure, and they may be difficult to replace. ● 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. ● Actual or perceived health risks or other problems relating to radio emissions could lead to litigation or decreased mobile communications usage. ● 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. Risks Related to our Fixed and Cellular Telecommunications Business · 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. · 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. Risks Related to the Development of New Businesses and Acquisitions ● We may not succeed in our efforts to develop new businesses. ● Expected benefits from partnerships with global technology companies may not be achieved. 23 Table of Contents ● 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. ● If we are unable to manage our growth effectively, our business and financial results may be adversely affected. ● Our acquisition activities expose us to various risks. 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. · Deterioration of the financial condition of our customers could adversely affect our operating results. · We are exposed to interest rate risk in relation to our bank borrowings. · We may be unable to fund the capital expenditures needed for us to remain competitive in the telecommunications industry in Indonesia. 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. · 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. 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. ● 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. · Applicable regulations on tariffs and their implementation as supervised by MoCD may affect our revenues and earnings. · 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. · We may experience local community opposition to some of our tower sites. · Our electronic money business is highly regulated. 24 Table of Contents · 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. Risks Related to our Corporate Structure and Governance ● 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. ● We may experience further changes in governance as an SOE. ● We are dependent on our subsidiary, PT Telekomunikasi Selular ("Telkomsel"), a cellular telecommunications services and cellular telecommunications networks company. ● Our efforts to streamline our corporate structure may not create expected synergies and efficiency in a timely fashion or at all. ● Our Articles of Association contain certain anti-takeover provisions that could adversely affect the rights of holders of our ordinary shares and ADSs. Risks Related to Indonesia Political and Social Risks · Current political and social events in Indonesia may adversely affect our business. · 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. · 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. Macroeconomic Risks · Negative changes in global, regional or Indonesian economic activity could materially and adversely affect our business. · Fluctuations in the value of the Indonesian Rupiah may materially and adversely affect us. · 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. · Downgrades of credit ratings of the Government or Indonesian companies could materially and adversely affect our business. · Uncertainty in respect of manpower legislation in Indonesia could materially and adversely affect our business. Risks related 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. 25 Table of Contents · We are exposed to the potential for financial loss and further non-financial detriments arising from climate change and society’s response to it. Risks related to our ADSs · The trading price of our ADSs may be volatile, which could result in substantial losses to you. · 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 different characteristics of the capital markets in Indonesia and the U.S. may negatively affect the trading prices of our ADSs and shares. · Our financial results are reported to the OJK in conformity with IFAS, which differs in certain respects from IFRS, and we distribute dividends based on profit for the year attributable to owners of the parent company and net income per share determined in reliance on IFAS. · As a foreign private issuer in the U.S., we are permitted to, and we have relied on and will rely on exemptions from certain NYSE corporate governance standards applicable to domestic U.S. issuers. This may afford less protection to holders of our ADSs. · 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. · The voting rights of holders of our ADSs are limited by the terms of the Deposit Agreement. · Holders of our ADSs may be subject to limitations on transfer of their ADSs. · 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. · Holders of our ADSs may experience dilution of their holdings due to their inability to participate in rights offerings. · 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. · 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. ​ 26 Table of Contents Risks Related to Our Business Operational Risks The telecommunications industry is characterized by intense competition and rapid technological change, and our ability to compete effectively depends on significant capital investment, access to sufficient spectrum, and successful adaptation to new technologies and market entrants. The Indonesian telecommunications market is highly competitive and dynamic. We face significant and evolving pressure from multiple sources, which could adversely affect our market share, revenue, and profitability. Market Competition and Saturation Our cellular and data services face intense competition from other operators who continue to make long-term investments in network quality and expand their service offerings. In recent years, competitors have used promotional strategies, such as offering bonus data packages, which have reduced profitability across the market. As major urban markets like those in Java become saturated, this competition has expanded to other regions, requiring us to focus on defending our market share. We also face increasing pressure from non-market leaders who target specific customer segments, such as gamers or entertainment users, with flanking strategies that may erode our market share in these niches. Industry consolidation further intensifies this competitive landscape. For a detailed discussion of the merger between PT XL Axiata Tbk and PT Smartfren Telecom Tbk in 2025, which has created a larger competitor. Technological Disruption and New Entrants The rapid pace of technological change continues to lower barriers to entry and introduce new forms of competition. For instance, the increasing number of smartphone users in Indonesia has fueled the growth of OTT services that substitute for our traditional voice and SMS services. This has directly affected the contribution of our legacy cellular phone services to our consolidated revenues, which has continued to decline from 5.5% in 2023 to 4.2% in 2024 and 3.0% in 2025. Moreover, we face new competition from satellite-based broadband services. Starlink officially began offering direct satellite broadband access to retail customers in Indonesia in April 2024, which may lead to heightened competition in the retail sector if such services develop more broadly in the future. While the effectiveness of satellite services can be limited in urban areas, Starlink’s “Direct-to-Cell” service, could in the future compete directly with traditional cellular networks, especially in rural or open areas. The development and application of new technologies require substantial investment and present both opportunities and risks. We are selectively deploying 5G while considering ecosystem readiness, including spectrum availability, handset penetration, and use case development. In 2025, our 5G services developed further with the expansion of the Hyper 5G network primarily in Greater Jakarta, Greater Bandung, Surabaya, Makassar, and Batam, along with the launch of 5G use cases, including the deployment of 5G Private Network Standalone aiming to enhance operational efficiency, productivity, and competitiveness for smart factories and manufacturing industry. As of December 31, 2025, our 5G services covered more than 80 cities with a total of 4,913 5G BTS. Our 5G rollout is being conducted in a focused and gradual manner, paced by ecosystem maturity and demand in both B2B and B2C segments, and is intended to support broader digital connectivity and future technology solutions. However, if our rollout does not meet expectations for customer adoption or return on investment, it may negatively impact our financial condition. The rapid development of AI may alter network traffic patterns, which may require substantial investments to reengineer our network topology without a proportional and concurrent increase in revenue. In 2025, we expanded the deployment of AI-related capabilities across our business, including Hitakari AI as our umbrella AI initiative, Veronika as an AI-enabled virtual assistant for customer service, TED as an AI-based virtual assistant for more complex and 27 Table of Contents enterprise-related interactions, Autonomous Network for AI-enabled network planning, optimization and real-time event handling, and AI functionality embedded in the MyTelkomsel super app and Moana, our employee experience platform. We also continued to invest in analytics, automation and data-driven capabilities across our operations. However, we may be unable to sufficiently utilize big data and integrate it into our operations in a timely manner, which could impair our ability to innovate and transition our business models effectively. Our failure to acquire or effectively integrate new technologies on commercially acceptable terms could lead to our existing technologies becoming obsolete, materially and adversely affecting our business, financial condition, and prospects. Spectrum Availability and Network Capacity Our ability to accommodate future traffic growth, support new technologies like 5G, and maintain service quality is critically dependent on acquiring sufficient spectrum and expanding our network capacity. Spectrum is a scarce resource, and we expect our needs to increase with the growth of data services. We must acquire additional spectrum through Government auctions, but we cannot be certain that we will secure the allocations necessary for our strategic objectives. The significant growth in data traffic, driven by smartphone applications, strains our existing network capacity. To manage this, we have been and may in the future be required to make significant capital expenditures to improve network coverage and secure additional spectrum. Limited or unavailable spectrum at suitable prices, or failure to win new allocations in Government auctions, would negatively impact our 5G deployment and overall growth strategy. If we are unable to obtain sufficient spectrum or fund the necessary capital expenditures to manage network congestion and deploy new technologies, our network performance could degrade, damaging our reputation and competitive position, which could have a material adverse effect on our results of operations and financial condition. Our business is highly dependent on the uninterrupted operation of our complex network infrastructure and information systems, which are vulnerable to disruption from operational failures, physical and cybersecurity threats, and other events beyond our control. 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 services and for the termination and origination of cellular telephone calls to and from fixed-line telephones, as a significant portion of our cellular and international long distance call traffic is routed through the PSTN. We also depend on access to internet, broadband, and cellular networks, as our integrated network infrastructure includes a copper access network, fiber optic access network, BTSs, switching equipment, optical and radio transmission equipment, an IP Core network, satellites, and application servers. In addition, we rely on interconnection to the networks of other telecommunications operators to carry calls and data from our subscribers to the subscribers of operators both within Indonesia and overseas, and on technologically sophisticated management information systems and other systems, such as our customer billing system, to conduct our operations. Our network infrastructure and connected systems are vulnerable to damage or interruption from a variety of sources, including: • Operational Failures and Natural Disasters. Our systems are vulnerable to damage or interruptions in operation due to a variety of causes such as earthquake, fire, flood, power loss, equipment failure, network software flaws, transmission cable disruption, or similar events. As a geographically dispersed network in a region prone to natural disasters, our infrastructure is also susceptible to damage from earthquakes, fires, floods, and other catastrophic events. Past incidents have demonstrated our susceptibility to such damage or interruptions. In 2024, we faced significant infrastructure impacts due to natural disasters and accidents, including earthquakes affecting STO Bawean and Kebalen on March 22, Witel West Sumatra on May 12, and Witel Mataram on May 14, as well as fires at STO Cirebon on July 21 and Site Bunyu on August 21. Such incidents not only disrupt our ability to 28 Table of Contents provide continuous service but also strain our resources during recovery efforts. In late November and December 2025, exceptionally heavy rain caused severe flooding and landslides across Aceh and other parts of Sumatra, majorly displacing thousands from their homes. Large areas of Aceh were flooded, forcing many communities to temporary shelters, which led to significant loss of life and injury. • Physical Security Threats. Our networks and equipment, particularly our wireline access network, face both potential physical and cybersecurity threats, including facility access issues, energy blackouts, fire, power loss, telecommunications failure, catastrophic events such as landslides and earthquakes, theft and vandalism of our equipment, and organized attacks against key infrastructure intended to disrupt operations. For example, our fiber optic cables were cut several times in 2023 and 2024 because of vandalism, which caused temporary interruptions to our traffic. • Cybersecurity Threats. In addition, telecommunications companies worldwide face increasing cybersecurity threats as businesses have become more dependent on telecommunications and computer networks, and have adopted or will adopt cloud technologies. Cybersecurity threats include gaining unauthorized access to our systems or inserting computer viruses, malicious and destructive codes, worms, malware, ransomware, or other malicious software in our systems; phishing, or spoofing to misappropriate consumer data and other sensitive information; or corrupting our data or disrupting our operations. Unauthorized access may also be gained through traditional means such as the theft of computers, portable data devices, or mobile phones, and intelligence gathering on employees with access to our systems. 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 with whom we do business could attempt to improperly use or access our computer systems and networks, or those of third-party service providers, to copy, obtain, and misappropriate our confidential information, including personal data. 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. In 2025, we detected 545.9 million cyber threats, 9,613 DDoS attacks, and 1,434 brute force attacks on our IT assets. Although most of the cybersecurity threats were non-disruptive and none of them rose to the level of requiring us to specifically address them, the techniques that computer hackers and others use to access or sabotage networks and computer systems constantly evolve and are generally not recognized until launched against a target. As a result, we and our service providers may be unable to anticipate, detect in a timely manner or at all, react to, counter or ameliorate all of these techniques or remediate any incident as a result therefrom. Our safety procedures and intrusion detection systems may not be fully effective in preventing unauthorized access to our internal data and databases, as well as data of customers, suppliers and other parties that we host on our systems. Therefore, such data could be misappropriated and illegally used, monitored, modified, or disseminated. More extensive infrastructure damage from any source could severely hamper service provision across our operations, and our business continuity and disaster recovery plans may not fully protect us from damage or interruptions to our operations. Any such failure or breach, whether from operational disruption, natural disaster, physical attack, or cybersecurity breach, could expose us to significant legal, financial, and reputational consequences. A successful attack or other material failure may lead us to incur substantial costs and devote increasing resources to repair damage or restore data, implement substantial organizational changes, new safeguards, system improvements, and training to prevent future similar attacks. 29 Table of Contents It could also result in lost revenues and litigation costs, and cause substantial reputational damage, loss of customer confidence in the adequacy of our threat mitigation and detection processes and procedures, and impact our competitive position. Such incidents may also cause equipment failures, loss of information, failure or perceived failure to comply with applicable privacy, security or data protection laws, or our failure to make adequate or timely disclosures to the public, regulators, or shareholders following any such event, as well as disruption to our operations or our customers’ operations. 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 these threats, the scope and impact of any future incident cannot be precisely predicted, and the physical and cybersecurity measures that we take to protect our network may not be successful. Any such event could divert our management attention and resources, expose us to liability and damages, negatively impact our operations, reputation, and competitive position, and materially and adversely affect our business, prospects, financial condition, and operating results. 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. Our reputation may be adversely affected by incidents or allegations involving, among other things, the quality of our products and services, security or safety issues, unethical behavior or misconduct, legal non-compliance, internal control failures, data or privacy breaches, workplace safety incidents, environmental incidents, the use of our communications systems for illegal or objectionable applications, negative media reports, and the conduct of our partners or representatives, whether actual or perceived. There is also increasing demand from external stakeholders, including non-governmental organizations and investors, for transparency and corporate responsibility, which may be difficult to satisfy fully. We are also subject to corporate governance laws and regulations and corruption risks. We are committed to conducting our operations in accordance with applicable anti-corruption laws and record-keeping requirements, and our management systems include a corporate code of conduct and other specific guidelines, policies, and directives designed to minimize and detect potential violations in a timely manner. However, there is no assurance that all of our employees, consultants, agents, or partners will comply with our corporate code of conduct and related policies, or that our management systems can fully prevent or effectively detect violations of anti-corruption laws and record-keeping requirements. The ongoing investigations by the SEC and DOJ into various issues, including accounting and disclosures issues relating to our revenue recognition, financial reporting practices, and internal control over financial reporting (“ICFR”), the findings of our internal investigation regarding transactions entered into by former management, and the Indonesian legal proceedings involving alleged fraud and corruption at our Company each represent the types of incidents that present significant reputational risk. Negative publicity arising from any of these matters, or from any adverse outcome of any ongoing investigation or proceeding, whether or not ultimately resolved in our favor, could harm our reputation with customers, investors, employees, the Government, and other stakeholders. For more information on these matters, see “— Financial Risks — If we fail to maintain an effective system of internal control over financial reporting, we may be unable to accurately report our financial results or prevent fraud”, “— Legal and Compliance Risks — We are and may be subject to legal proceedings, claims and investigations, including for allegations relating to our public disclosures and disputes and litigation with regulators, competitors and other parties. If the outcomes of these proceedings, claims and investigations are adverse to us, our business, results of operations and financial condition could be materially and adversely affected, including because we may be subject to criminal or civil sanctions, or be required to restate our financial statements from prior periods,” “Item 8. Financial Information – A. Consolidated Statements and Other Financial Information – Legal Proceedings” and “Item 15. Controls and Procedures.” If we fail to respond quickly and effectively to address reputational incidents, we may receive additional negative publicity, which could subject us to enforcement actions, legal proceedings, sanctions, fines, or penalties, compliance 30 Table of Contents conditions, or other restrictions, and we may incur substantial costs regardless of the ultimate outcome of any ongoing investigation or proceeding. Damage to our reputation could harm customer relations, reduce demand for our services and products, reduce investor confidence in us, and impair our ability to compete for customers and highly skilled employees. Any of the foregoing could have material adverse effects on our business, operating results, financial condition, reputation, and brand. 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. Since we provide connections to the internet and host websites for customers, we may be perceived as being associated with the content carried over our network or displayed on websites that we host. For example, in the past, due to an escalation in spam messages generated from email addresses on the Telkom network, Telkom was placed on certain IP blacklists which blocked all email generated from Telkom addresses for almost a week until remedial measures could be put into place. This issue has persisted into 2025, with instances of spam generation and subsequent blacklisting continuing to occur. Although we have implemented administrative and technical preventative measures to identify and combat spam, these measures may not always be effective and we could be placed on IP blacklists again in the future, disrupting our services. 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. 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 mobile phone antennae or a BTS on which local operator SIM cards are installed so that international calls can be fraudulently routed to local numbers, enabling fraudsters to bypass interconnection rates in the destination country. Such revenue leakages constitute a loss of potential revenue that is difficult to quantify and may lead to a loss of revenue for our Group, which may affect our financial conditions and results of operations. Expected benefits from investment in new networks and technologies may not be realized. We pursue new growth opportunities in the communications industry, including introducing services and products employing new technologies, such as next-generation network technologies, virtualization, software-defined networking, cloud-based technologies, new video and content delivery platforms, digital marketing, home fiber, fixed-mobile convergence, and Wi-Fi 6. The implementation of these new technologies depends on a number of factors, including the development of our network and the launch of new and commercially viable products and services involving these technologies. We may have to incur substantial expenditures to develop our network, services, and products and to gain access to related or enabling technologies in order to successfully implement these new technologies. However, 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. 31 Table of Contents 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 also “— Risks Related to Our Business — Operational Risks– The telecommunications industry is characterized by intense competition and rapid technological change, and our ability to compete effectively is dependent on significant capital investment, access to sufficient spectrum, and successful adaptation to new technologies and market entrants.” 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. 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 a number of factors, including: ● Geopolitical Events, Sanctions, and Trade Restrictions. Our supply chain is exposed to geopolitical risk, including export controls, sanctions, and trade restrictions that are largely beyond our control. Shifts in government administrations, particularly in the United States, can produce sudden changes in foreign policy and trade priorities. The U.S. Department of Commerce has added certain telecommunications equipment manufacturers to its "Entity List," substantially restricting the transfer of U.S.-sourced items to those entities. The U.S. government has also imposed, and may in the future impose, broad tariffs on telecommunications equipment and components, a significant share of which is sourced from China and other countries that have been or may be targeted. Any such actions could impair our key suppliers' ability to serve us and materially increase our equipment costs. ● Global Supply Chain Disruptions. Geopolitical conflicts have disrupted global supply chains for critical components, including semiconductors essential to our network infrastructure. The conflict in Ukraine has curtailed supplies of key semiconductor inputs, such as neon gas, of which Ukraine was a major producer, and palladium, of which Russia is a leading supplier, constraining semiconductor production capacity and contributing to delays in our data center expansion, including our Cikarang data center in 2023. The escalation of hostilities involving Israel, Iran, and the United States in 2026, including restrictions and controls on shipping in the Strait of Hormuz, has driven oil price volatility, increasing international logistics and freight costs for the network equipment and components we procure, which may compress our margins to the extent such costs cannot be passed through to customers. If any of these disruptions persist or intensify, we may be unable to obtain the components needed to maintain and upgrade our network infrastructure and roll out 5G technologies, resulting in higher costs, extended project timelines, and possible service interruptions. Finding alternative suppliers, whether due to geopolitical restrictions, epidemic or pandemic-related constraints, or other factors, may not be possible on a timely basis or on commercially acceptable terms. Any of the foregoing could negatively affect our operations, financial condition, and competitive position. 32 Table of Contents 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 33 Table of Contents 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 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 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 development of our infrastructure network, including our 4G/LTE and 5G infrastructure, to carry the increasing data traffic. However, our ability to improve or expand our infrastructure network is subject to various factors, a number of which are not within our control, such as regulations and changes in regulations, changes to the competitive environment or technological developments that could materially and adversely affect our ability to improve or expand our infrastructure network as expected or desired and achieve anticipated returns on our investments. 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 34 Table of Contents 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. Expected benefits from partnerships with global technology companies may not be achieved. We partner and collaborate with various global technology companies as part of our strategy of providing digital IT services to our businesses. Global technology companies have capabilities and scale that we may not be able to create and develop organically, whether in the near-term or at all, and such partnerships are necessary to achieve some of our strategic goals. Our reliance on global technology companies is especially critical for major projects, such as developing a vertical digital ecosystem in Indonesia, fostering digitalization by providing wider access to digital tools for businesses and Government agencies, and generally supporting Indonesia’s digital development through our contribution to the One Data Indonesia initiative, the Government’s plan for digitizing Government data and facilitating transfers of such data, and the Government’s implementation of the National Digital Platform. 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. 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 2025 was on undertaking a significant corporate transformation, highlighted by the partial spin-off of our Wholesale Fiber Connectivity business and assets to our subsidiary, PT Telkom Infrastruktur Indonesia 35 Table of Contents (“TIF”). This initiative, part of our broader strategy to unlock value in our digital infrastructure, alongside our continued focus on FMC, data center expansion, and B2B digital services, requires specialized expertise to manage both the complex transition and the operations of the restructured entities. 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. The implementation of our strategic initiatives, particularly the partial spin-off of a business segment to our subsidiary, TIF, involves the transfer of certain employees and requires specialized expertise to manage the transition. For more details on this transaction, see “—Risks Related to our Corporate Structure—Our efforts to streamline our corporate structure may not create expected synergies and efficiencies in a timely fashion or at all.” 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 efforts to retain and develop personnel may also result in significant additional expenses, which could adversely affect our profitability. There can be no assurance that qualified employees will continue to be employed or that we will be able to attract and retain qualified personnel in the future. Failure to retain or attract qualified personnel could have a material adverse effect on the implementation of our business strategies, our business, prospects, financial condition, and results of operations. If we are unable to manage our growth effectively, our business and financial results may be adversely affected. To continue to grow sustainably, we are expanding our operational, research, sales and marketing efforts, accounting and financial systems, procedures, controls and other internal management systems. For more information on our growth strategy, see “Item 4.B. Business Overview – Strategy.” This may require substantial managerial and financial resources, and our efforts in this regard may not be successful. Our current systems, procedures and controls may not be adequate to support our future operations. Unless our growth results in an increase in our revenues that is proportionate to the increase in our costs associated with this growth, our operating margins and profitability will be adversely affected. If we fail to adequately manage our growth effectively, improve our operational, financial and management information systems, or effectively train, motivate and manage our new and future employees, it could adversely affect our business, financial condition and results of operations. 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 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 36 Table of Contents 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. 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. Our internal investigation conducted with the assistance of outside counsel and a forensic accounting firm in connection with the SEC and DOJ investigations (the "Internal Investigation") also focused on the review of approximately 140 transactions originating from 2014 through 2021, and primarily between 2016 and 2019. Certain of these transactions were entered into by our former management or the former management of certain of our subsidiaries, primarily related to the enterprise business segment, were executed in circumvention of IFRS, our policies, and ICFR to manage reported earnings. Other members of former management, including those who were in place during later periods, failed to take corrective action when these transactions were identified as improper or potentially improper. These transactions and this absence of corrective measures reflected deficiencies in our control environment. For more information, see “Item 3D — Risk Factors — Risks Related to Our Business — Operational Risks — Damage to our reputation could negatively impact our business, financial condition, and results of operations”, “Item 3D — Risk Factors — Risks Related to Our Business — Legal and Compliance Risks — We are and may be subject to legal proceedings, claims and investigations, including for allegations relating to our public disclosures and disputes and litigation with regulators, competitors and other parties. If the outcomes of these proceedings, claims and investigations are adverse to us, our business, results of operations and financial condition could be materially and adversely affected, including because we may be subject to criminal or civil sanctions, or be required to restate our financial statements from prior periods”, “Item 8. Financial Information – A. Consolidated Statements and Other Financial Information – Legal Proceedings” and “Item 15. Controls and Procedures.” We have taken disciplinary action against involved employees and have implemented and continue to implement other remediation measures, such as the hiring of additional qualified accounting, finance, and legal personnel, engagement of technical accounting consultants, and streamlining of our organizational structure to improve oversight of our accounting and controlling functions. In 2025, we also created the Directorate of Legal & Compliance and a new Chief Integrity Officer position to strengthen our corporate governance and compliance program. Our full remediation plan is described in “Item 8. Financial Information – A. Consolidated Statements and Other Financial Information – Legal Proceedings – Remediation” in this Form 20-F. However, there can be no assurance that these efforts will be successful or will prevent the recurrence of similar issues. If we are unable to maintain an effective internal control environment, fully identify, or assess the impact of, transactions that did not or do not comply with IFRS and our policies and guidelines, we could suffer material misstatements in our financial statements, fail to meet our reporting obligations, and cause investors to lose confidence in our reported financial information, which could limit our access to capital markets, harm our results of operations, lead to a decline in the trading price of our securities, and expose us to increased risk of fraud, potential delisting, regulatory investigations, and civil or criminal sanctions. Our independent registered public accounting firm, after conducting its own independent testing, may also issue a qualified report if it is not satisfied with our internal controls or the level at which our controls are documented, designed, operated, or reviewed, or if it interprets the relevant requirements differently from us. ​ 37 Table of Contents Deterioration of the financial condition of our customers could adversely affect our operating results. 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. In addition, our corporate restructuring involves the transfer of certain enterprise customer contracts. In connection with our partial spin-off, the agreements with customers of the Wholesale Fiber Connectivity business will be transferred to our subsidiary, TIF. For more details, see “—Risks Related to our Corporate Structure—Our efforts to streamline our corporate structure may not create expected synergies and efficiencies in a timely fashion or at all.” A deterioration in the financial condition of our enterprise customers, including those whose contracts are transferred to TIF, or of our subscribers, whether due to the macroeconomic factors described above or otherwise, has and may continue to adversely impact our business, including by negatively affecting the collection of accounts receivable. This could also result in our customers and subscribers purchasing fewer of our products and services or delaying such purchases, which could have a material adverse effect on our business, financial condition, results of operations and prospects. For the years ended December 31, 2024 and 2025, our total trade and other receivables, net of allowance for expected credit losses were Rp12,829 billion and Rp11,410 billion (US$684 million), respectively. We regularly review the collectability and creditworthiness of our customers and trade receivables generated by specific projects and transactions, on a case-by-case basis, to determine an appropriate allowance for estimated credit losses. We assess and calculate sufficient provision for impairment of our receivables to cover losses incurred arising from uncollectible accounts based on existing data on credit losses. The allowance for expected credit losses was Rp7,196 billion (US$432 million) as of December 31, 2025, representing an increase by approximately 14.3% compared to our allowance for expected credit losses as of December 31, 2024. Otherwise, the written-off uncollectible accounts in 2025 increased by 43.1%, from Rp401 billion in 2024 to Rp574 billion (US$34 million) in 2025. We believe that the allowance for expected credit losses of trade receivables is adequate to cover losses on uncollectible accounts. If our uncollectible accounts were to exceed our current or future allowance for credit losses, our operating results would be negatively impacted. 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 and 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, 2025, approximately 49.4% (based on the aggregate then outstanding principal) of our total bank borrowings were floating-rate loans. Any future increases in interest rates would likely cause our financial expenses to increase as we enter into new loan agreements, including fixed-rate loans and credit facilities. Furthermore, while our 2025 share buyback of up to Rp3.0 trillion was funded by internal cash and not debt, the use of these internal funds could reduce our liquidity and may require us to seek external financing for future business development or operational needs, potentially at higher interest costs. 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 domestic economic growth, Bank Indonesia (“BI”) has adjusted interest rates several times in recent years. In February 2021, the BI benchmark seven-day (reverse) repo rate reached a historic low of 3.50% per annum (the “BI-Rate”). Subsequently, BI gradually increased the benchmark rate in response to global inflationary pressures, exchange rate volatility, and tightening global monetary conditions, with the BI-Rate reaching 6.00% in early 2025. During 2025, BI gradually reduced the benchmark 38 Table of Contents interest rate to support economic growth and maintain financial system stability, bringing the BI-Rate down to 4.75% by the end of 2025. As of April 2026, BI has maintained the BI-Rate at 4.75% amid continued global economic uncertainty, volatility in international financial markets, and pressure on the Rupiah foreign exchange rate. Although inflation is expected to remain within BI’s target range and certain economies, including the United States and the European Union, have experienced easing inflation and lower interest rates, there can be no assurance that interest rates in Indonesia will continue to decline or remain stable. Future increases in interest rates may occur in response to domestic or global economic pressures, including inflationary risks, geopolitical tensions, exchange rate volatility, and capital outflows. Lower than anticipated interest rate reductions, or any future increases in interest rates, may cause our financing costs to remain higher than expected or increase financial expenses associated with floating rate borrowings, which could adversely affect our financial condition and results of operations. 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, 2023, 2024, and 2025, our consolidated capital expenditures totaled Rp32,858 billion, Rp24,436 billion, and Rp24,577 billion (US$1,475 million), respectively. Our capital expenditure in 2025 was driven by allocation for the development, expansion and modernization of our telecommunications infrastructure and digital platforms. Key initiatives undertaken in 2025 included investments in radio access networks (RAN), core network solutions, gateway and signaling systems, and fixed broadband infrastructure (including fixed broadband core and submarine cable systems). Additionally, capital expenditures were directed to supporting digital service platforms like online charging systems, customer relationship management, and service control points, as well as emerging technology deployments such as Starlink-based services. A portion of the expenditure also supports large-scale infrastructure projects, including data center construction and operational technology networks, along with associated technical support and rollout services to ensure network reliability and scalability. 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. 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. As of the date hereof, we are subject to ongoing government investigations and legal proceedings in the United States and Indonesia and cannot provide any assurance about their outcomes, which may have a material adverse effect on our reputation, business, results of operations, or financial condition. 39 Table of Contents In October 2023, we received a document request from the SEC relating to Telkom Infra’s involvement in a project with the Indonesian Information and Telecommunication Accessibility Agency of the MoCD (“BAKTI Kominfo”) regarding the provision of 4G BTS infrastructure. The SEC has since expanded its investigation to include accounting and disclosure issues relating to our revenue recognition, financial reporting practices, and ICFR, as well as public reports regarding certain Indonesian legal proceedings involving our Company, various subsidiaries and affiliates, and certain of our clients and suppliers. Beginning in May 2024, we also received requests for information from the DOJ focused on compliance with the U.S. Foreign Corrupt Practices Act (“FCPA”). Each U.S. authority is aware of the other agency’s investigation. We are cooperating with the SEC and DOJ and have been carrying out our Internal Investigation into these issues. As of the date hereof, the Internal Investigation is substantially complete. The Internal Investigation focused on the review of approximately US$324 million of revenues, spread across approximately 140 transactions originating from 2014 through 2021, and primarily in 2016 through 2019, impacting historical trade receivables and revenues, to determine whether goods and services associated with these transactions were delivered or otherwise recorded in accordance with IFRS and whether such transactions were consistent with our policies, procedures, and ICFR. Our internal audit team also completed investigations for certain of these transactions, and those conclusions have been considered as part of the Internal Investigation. As of the date hereof, based on the results of our Internal Investigation, we believe that substantially all of these approximately 140 transactions that we have identified as lacking economic substance resulted in an overstatement of certain financial information, including revenues, gross trade receivables and net trade receivables, as set out in our consolidated financial statements relating to prior financial years. For a full description of the Internal Investigation findings, see “Item 8. Financial Information – A. Consolidated Statements and Other Financial Information – Legal Proceedings.” We are also responding to various requests from the SEC and DOJ relating to their investigations. The requests primarily relate to the regulators’ investigations into accounting and disclosure issues relating to our revenue recognition, financial reporting practices, and ICFR, as well as public reports regarding certain Indonesian legal proceedings involving our Company, various subsidiaries and affiliates, and certain of our clients and suppliers. The SEC’s and DOJ’s investigations remain ongoing, and we continue to cooperate fully with the SEC and DOJ. We cannot predict the duration, outcome, or impact of these investigations. Potential consequences include the imposition of material fines or penalties, monitorship, civil or criminal enforcement actions, restrictions on our business, potential delisting, additional government investigations or enforcement actions, or an inability to finalize our financial results in a timely manner, including a delay in complying with our periodic reporting obligations, any of which could have a material adverse effect on our business, financial condition, results of operations, and the market price of our shares and American Depositary Shares. An investigation or inquiry by the SEC or DOJ, even if ultimately resolved favorably, could adversely impact our reputation, business, prospects, financial condition, and results of operations. 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 DOJ enforcement of the FCPA for 180 days (renewable for an additional 180 days). Shortly thereafter, the DOJ and SEC informed our Company of an indefinite pause on the FCPA-related aspects of their investigations. We cannot be certain how any resulting changes to FCPA enforcement will affect the DOJ’s investigation of our business. We have cooperated with, and continue to cooperate with, and have in certain instances self-reported to, government authorities in Indonesia, including, among others, the Indonesian National Police, the Public Prosecution Service, and the Corruption Eradication Commission, various matters involving alleged or potential violations of Indonesian laws and regulations by our business units, subsidiaries, and affiliates, including anti-corruption, alleged fraud, embezzlement, and issues associated with trade receivables, some of which are related to the matters under investigation by the SEC and DOJ. In May 2025, the DKI Jakarta High Prosecutor’s Office designated eleven individuals as suspects and detained them in connection with alleged corruption involving fictitious financing at our Company, relating to conduct 40 Table of Contents that primarily took place between 2016 and 2019, following our submission of internal audit findings in support of the Government’s Bersih-bersih BUMN program. In April 2026, the Central Jakarta District Court issued its verdict against these eleven individuals. We have taken, and continue to take corrective actions including disciplinary action against involved employees, hiring additional qualified accounting, finance, and legal personnel to provide additional capacity and expertise to enhance our accounting and reporting review procedures, engaging consultants to provide additional technical accounting expertise, receivables collection effort, streamlining and delayering our organizational structure to improve oversight of our accounting and controlling functions, and other changes to our internal procedures. We fully support the applicable legal processes in Indonesia and continue to cooperate with Indonesian authorities. The outcomes of these proceedings remain uncertain and could expose us to additional liability, reputational harm, or operational disruption. In connection with the foregoing self-reporting and ongoing cooperation with Indonesian authorities, the OJK, as the regulator with supervisory powers over the capital markets sector, may also request clarifications or additional information from us regarding the reported matters. Any adverse outcomes of these matters could result in negative publicity, regulatory actions, reputational damage, and claims, fines, damages, and lawsuits, any of which could have material adverse effects on our business, results of operations, and financial condition. For more information, see also “Item 3D. — Risk Factors — Risks Related to Our Business — Operational Risks — Damage to our reputation could negatively impact our business, financial condition, and results of operations”, “Item 3D. — Risk Factors — Risks Related to Our Business — Financial Risks — If we fail to maintain an effective system of internal control over financial reporting, we may be unable to accurately report our financial results or prevent fraud”, “Item 8. Financial Information – A. Consolidated Statements and Other Financial Information – Legal Proceedings” and “Item 15. Controls and Procedures.” 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. 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 41 Table of Contents 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 took full effect on October 17, 2024, requiring us, as personal data controllers, to adapt our business practices to promote compliance throughout all stages of personal data processing. As a personal data controller, we are obligated to inform data subjects of the purpose and legality of data processing, obtain their consent, and process data in a limited, specific, lawful, and transparent manner. We are also required to notify data subjects promptly in the event of a data breach. Additionally, the PDP Law mandates the appointment of a Data Protection Officer (“DPO”) for companies that handle large-scale personal data, perform regular and systematic monitoring, or process data related to public services. To comply with the PDP Law, we have implemented a comprehensive data protection policy that governs personal data processing and helps establish compliance with legal and consent requirements. In 2024, Telkom appointed a DPO and formed a Data Protection Unit under the Corporate Secretary department. See also “Item 16K – Cybersecurity” for further details. However, despite these measures, there remains a risk of cybercrime, data breaches, or human error that could result in violations of personal data protections. Non-compliance with the PDP Law could result in sanctions, including written warnings, temporary suspension of data activities, deletion of personal data, or administrative penalties. 42 Table of Contents In 2025, MoCD’s Legal Bureau conducted a series of harmonization meetings on the draft Government Regulation intended to supplement the PDP Law and establish more comprehensive standards for data controllers and processors. The draft Government Regulation also outlines the proposed establishment of a Personal Data Protection Authority, which is intended to provide institutional certainty and support consistent enforcement of personal data protection rules. As of May 2026, the draft Government Regulation has not yet been finalized. While the implementing regulations under the PDP Law have not yet been finalized, we have been subject to the obligations under, and have continued to comply with, the PDP Law since it became fully effective. In anticipation of the implementing regulations and evolving regulatory expectations, since 2024 we have undertaken various preparatory and compliance measures relating to the anticipated requirements under the PDP Law. However, full compliance with the detailed requirements to be set out in the final Government Regulation may require additional resources and investments, possibly delaying specific projects. Any such additional expenditures or delays could adversely impact our operational results and, in turn, materially and adversely affect our business, financial condition, results of operations, and prospects. As of the date hereof, MoCD is in the process of developing a new regulation on AI ethics. According to MoCD’s Press Release No. 201/HM-KKD/10/2025, dated October 29, 2025, Nezar Patria, the Vice Minister of MoCD, stated that the Government was then in the process of drafting two regulatory instruments related to AI, which will cover, among others, the national development of AI and the ethical use of AI, with the objective of ensuring privacy protection, security, accountability, and ethical standards in the utilization of AI. As of the date hereof, the regulatory framework on AI ethics is limited to the MoCD AI Circular Letter and EIT Law. These regulations aim to promote ethical AI usage and protect children on digital platforms. They require Electronic System Operators (“ESOs”), including us, to implement preventive measures against risks to children posed by electronic systems. Additionally, they grant the Government significant oversight of electronic systems in Indonesia. For example, the MoCD AI Circular Letter outlines obligations for businesses using AI-based systems in public and private sectors. These include ensuring human oversight and validation of AI-driven decisions that may affect individuals, thereby prohibiting fully autonomous decision-making by AI systems without human involvement. 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. In response, our subsidiaries that manage distribution platform services, such as gaming and entertainment contents, have implemented data updates to display user age ratings. Instances of non-compliance with these requirements could lead to severe administrative penalties, including the possibility of system suspension or shutdown. Furthermore, the amendments emphasize the Government’s broader regulatory authority within Indonesia’s digital environment and grants the Government the power to compel ESOs to modify their operations, with penalties for non-compliance. While intended to promote a safe, fair, and innovative digital space, the broad scope of these powers has generated concerns over potential Government overreach and its implications for innovation and business growth within the sector. 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 43 Table of Contents 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. 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, including the Job Creation Law of 2023 and its implementing regulation, Ministry of Communication and Informatics Regulation No. 5 of 2021, require telecommunications providers to share network infrastructure. We are required to grant other operators access to our passive infrastructure, such as ducts, towers, and poles, on a fair, reasonable, and non-discriminatory basis. Furthermore, we may be mandated to provide access to our active infrastructure and network capacity based on mutual agreement between operators. As the operator with the most extensive infrastructure in Indonesia, these sharing mandates could allow competitors to expand their coverage and services by leveraging our network without incurring the significant capital expenditure required to build their own. The regulations grant the Ministry of Communication and Informatics the authority to determine tariffs if a commercial agreement cannot be reached between operators, creating a risk that we may not be able to charge rates that we consider commercially acceptable. If we are mandated to share our infrastructure and lease capacity at regulated, non-commercial rates, it could diminish our competitive advantage, erode our revenue, and have a material adverse effect on our financial condition and results of operations. 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. 44 Table of Contents 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. The implementation of IP-based interconnection initiated on January 1, 2025. However, until such implementation is fully completed, our network will continue to operate partially on legacy systems. While this does not immediately impact our revenue, future regulations — particularly the MoCD’s decision on tariffs for full IP-based interconnection — could affect our interconnection revenue model. 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 protecting 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 infrastructure sharing obligations for its passive infrastructure including towers and fiber optics. The implementation of these requirements, coupled with the potential issuance of multiple 5G licenses, could limit the availability of new sites for BTS towers in certain regions. Additionally, any mandates for the retrofitting of existing towers to accommodate multiple operators could lead to our incurrence of additional expenses. 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, 45 Table of Contents vandalism could result in damaged equipment. In the year ended December 31, 2025, we were involved in 61 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. 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, e-wallet, and remittance 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 holds a majority equity stake in PT Fintek Karya Nusantara (“Finarya”). Finarya has obtained a PJP Category 1 license from BI which covers E-Money and remittance services. However, BI has the authority to take further actions as it sees fit, such as revoking a license, shortening the license period, or limiting the license holder’s activity. If BI imposes any such actions on Finarya, our ability to conduct our ordinary course E-Money business would be limited, which may adversely affect our business, financial condition, and results of operations. See also “Item 4B. Information on the Company — Licensing — Payment Method Using E-Money” for more details on BI’s requirements for licensing. 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 and Finarya, fail to comply with any of these obligations, we will be subject to administrative sanctions. Any sanction imposed on Finarya could materially and adversely affect our business, financial condition, results of operations and prospects. 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. 46 Table of Contents Risks Related to our Corporate Structure and Governance 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. As of the date hereof, the Government is our ultimate controlling shareholder. This control is exercised through a dual-layer structure comprising both direct and indirect mechanisms that grant the Government substantial influence over our governance, operations, and strategic direction. Directly, the Government, through the SOE Regulatory Agency, holds our single, non-transferable Dwiwarna Share. This share grants the Government special rights under our Articles of Association and Indonesian law, including the power to approve the appointment, removal, and nomination of all members of our Board of Directors and Board of Commissioners, as well as veto rights over amendments to our Articles of Association, decisions on mergers or dissolution, and changes to our capital structure. These rights allow the Government to exert direct and decisive influence over fundamental corporate governance matters. Indirectly, the Government exercises control through its majority ownership of our Series B Shares. Pursuant to a restructuring formalized by Law No. 16 of 2025 and its implementing regulations, the Government’s majority stake in our Series B Shares is held by PT Danantara Asset Management (“DAM”), an operational holding company. DAM, in turn, is wholly owned by the Daya Anagata Nusantara Investment Management Agency (Badan Pengelola Investasi Daya Anagata Nusantara or “BPI Danantara”), which is a Government-owned entity vested with the statutory authority to establish strategic guidelines and policies for SOEs, including our Company. As a result, the Government, acting through BPI Danantara and DAM, is able to exert significant influence over our operational management and strategic direction. The Government also holds a Dwiwarna Share in our competitor, PT Indosat Tbk (“Indosat Ooredoo Hutchison” or “IOH”), and may have the ability to exercise similar control over IOH. The interests of the Government, as our ultimate controlling shareholder, may differ from the interests of our other shareholders. The Government may prioritize broader public policy objectives or national interests, such as the development of the telecommunications sector in a manner that favors one operator over another, which may not align with our commercial objectives or the goal of maximizing shareholder value. Should the Government cause us to pursue initiatives or enter into transactions that prioritize public policy considerations without adequate commercial justification or compensation, or if its control over us and our competitors, such as IOH, leads to market conditions or specific directives that favor any other telecommunications operator, our business, financial condition, results of operations and prospects could be materially and adversely affected. We may experience further changes in governance as an SOE. The Government enacted Law No. 1 of 2025 on the Third Amendment to the SOE Law, introducing a restructuring framework for SOEs, including the establishment of Operational Holding and Investment Holding entities under the management of BPI Danantara. As part of this restructuring, Government Regulation No. 15 of 2025 on the Additional State Capital Participation of the Republic of Indonesia into the Share Capital of PT Biro Klasifikasi Indonesia (Persero) (“BKI”) for the Establishment of an Operational Holding (“GR 15/2025”) mandated the transfer of the Government’s Series B shares in various SOEs, including our Company, to DAM (previously known as BKI) through in-kind state capital participation, thereby designating DAM as an operational holding responsible for overseeing the operational activities of assigned SOEs. In addition, Government Regulation No. 16 of 2025 on State Capital Participation of the Republic of Indonesia in BPI Danantara (“GR 16/2025”) further formalised DAM’s status as an operational holding by transferring all of its Series B shares to BPI Danantara, resulting in BPI Danantara becoming DAM’s majority shareholder, while the Government retained ultimate control through the Dwiwarna Share. Collectively, these regulatory actions constituted the initial phase of the restructuring of SOE governance under the new statutory framework. 47 Table of Contents On October 16, 2025, the Government enacted Law No. 16 of 2025 on the Fourth Amendment to the SOE Law, which introduced further adjustments to the SOE governance framework, including the transformation of the former MSOE into the SOE Regulatory Agency. Under this amendment, the SOE Regulatory Agency was established as a Governmental body mandated to perform regulatory, supervisory, and policy-formulating functions in the SOE sector. Given its status as a Government agency and the absence of any statutory indication that it constitutes a separate legal entity, the SOE Regulatory Agency effectively assumes the legal and functional position previously held by the MSOE, including acting as the Government’s representative in exercising the rights attached to the Dwiwarna Share in SOEs. Its authorities largely mirror those of the former MSOE, with certain enhanced powers such as approving the work plan of BPI Danantara. As a regulator established under statutory law, the SOE Regulatory Agency also exercises regulatory authority consistent with the broader legislative framework under Law No. 12 of 2011 on the Establishment of Laws and Regulations. The Fourth Amendment to the SOE Law also reallocates certain strategic governance rights, previously attached to the Government’s Dwiwarna Share to BPI Danantara. Under the revised framework, BPI Danantara is vested with statutory authority to formulate strategic guidelines and policies for SOEs, including in areas such as legal compliance, accounting and finance, operational planning, and risk management. This constitutes a material shift in the governance architecture of SOEs and may affect our corporate governance framework, as strategic directions or policy determinations issued by BPI Danantara could influence our internal policies, operational priorities, and management processes. The involvement of BPI Danantara in certain of our decision-making processes could also impact the pace of our decision-making processes. For example, pursuant to amendments to our Articles of Association adopted at our Extraordinary General Meeting of Shareholders on December 12, 2025, and restated in Notarial Deed No. 07 dated January 6, 2026, any write-off of our uncollectible receivables, including bad principal receivables, interest receivables, fines, fees, and other non-principal receivables written off for purposes of restructuring or settlement, must first obtain the prior approval of BPI Danantara before the Board of Commissioners may grant its own approval. These changes may also alter the coordination dynamics among BPI Danantara, the SOE Regulatory Agency, and operational holding entities, potentially affecting the balance between shareholder rights and Governmental regulatory authority. While the transformation of the MSOE into the SOE Regulatory Agency is not expected to have a material impact on our governance structure, the expansion of BPI Danantara’s statutory authority introduces uncertainty into the future governance landscape for SOEs, including our Company. At this stage, no implementing regulations have been issued to clarify the scope, mechanisms or practical application of BPI Danantara’s newly vested strategic policy-setting authority. As a result, we cannot predict how BPI Danantara will exercise such authority going forward, whether future strategic directives may materially affect our operations, compliance frameworks or financial policies, or how coordination among the SOE Regulatory Agency, BPI Danantara and Operational Holding entities will function in practice. We continue to monitor the issuance of implementing regulations under the amended SOE Law, as these may further define the scope of BPI Danantara’s authority and introduce governance adjustments that could affect our operations, strategic planning and internal processes. We are dependent on our subsidiary, Telkomsel, a cellular telecommunications services and cellular telecommunications networks company. We derived 74.9%, 73.1% and 72.2% of our revenue in 2023, 2024 and 2025 respectively, from our mobile business through our 69.9% majority-owned subsidiary, Telkomsel. The remaining 30.1% interest in Telkomsel is held by Singapore Telecom Mobile Pte. Ltd. (“Singtel”). In addition, in line with our FMC initiative, we entered into an agreement with Telkomsel to combine our fixed broadband and mobile broadband services into a single business entity, by transferring a portion of our assets and liabilities allocated to the IndiHome business segment to Telkomsel (the “IndiHome Integration”). After the IndiHome Integration, there has been an increase in the contribution from Telkomsel to our consolidated revenue, including in 2025, compared to Telkomsel's contribution prior to the IndiHome Integration. See “Item 5A—Operating Results.” 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, 48 Table of Contents 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 efforts 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. 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. A cornerstone of this strategy in 2025 has been the partial spin-off of our Wholesale Fiber Connectivity business and assets to our controlled subsidiary, TIF. We signed a Conditional Spin-Off Agreement on October 20, 2025, for this transaction, valued at approximately Rp35.79 trillion, which represents a key phase in our plan to establish TIF as a dedicated digital infrastructure company. The spin-off is intended to create a more focused business, unlock the value of our fiber assets, and improve operational efficiency. This initiative is part of a multi-phase plan, with subsequent stages of asset transfers to TIF anticipated in 2026, subject to further assessment and approvals. These streamlining efforts, however, have been delayed, and we may experience further delays or unforeseen challenges. In addition, during transition periods, we may incur costs inherent to the implementation of such streamlining efforts without realizing the anticipated benefits to our business, competitiveness, costs, and synergies, which could have a negative effect on our financial condition and results of operations. 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 49 Table of Contents 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. Public demonstrations have frequently been triggered by social and political concerns, including regional election laws, civil rights, democratic processes, and controversial public policies. Although many demonstrations have remained peaceful, some have escalated into violence. Most recently, beginning on August 25, 2025, large-scale demonstrations took place outside the national parliament in Jakarta in response to public dissatisfaction over legislative compensation and broader governance concerns. These protests escalated into violent clashes between demonstrators and security forces, prompting the authorities to deploy significant police and military personnel and impose traffic restrictions around key Government areas. The demonstrations subsequently extended over several days and spread to multiple cities, where public anger widened to include criticism of law-enforcement practices and perceived lack of Government accountability. Reports indicated the use of tear gas and water cannons by security forces, road closures affecting mobility, arrests of participants, and continued unrest across affected regions. These events underscore the potential for political grievances to escalate and generate broader disruptions. In addition to evolving political dynamics, Indonesia continues to face significant social and civil unrest, particularly in Papua, where separatist tensions have intensified. In the first quarter of 2025, over 86,000 people were internally displaced due to armed confrontations between Indonesian National Military (Tentara Nasional Indonesia or “TNI”) and the West Papua National Liberation Army (Tentara Pembebasan Nasional Papua Barat – Organisasi Papua Merdeka or “TPNPB-OPM”) separatist group, with serious clashes reported in Intan Jaya and ultimatums issued by separatist elements to the military. In April 2025, members of the TPNPB-OPM killed approximately 15 civilian gold miners in Yahukimo Regency, prompting calls from civil society and Papuan leaders for a more peaceful, humanitarian approach. Senior regional officials have publicly questioned the continued deployment of security forces, noting that the current strategy has not sufficiently reduced violence and has contributed to civilian suffering. These developments highlight ongoing challenges to stability and unity across Indonesia’s culturally and regionally diverse population, and the escalation of conflict in Papua poses risks to our operations, including security concerns, potential supply chain disruptions, and reputational exposure. Moreover, during the course of President Prabowo Subianto and Vice President Gibran Rakabuming Raka’s administration, the direction and pace of policy implementation remain in transition. The Government has announced numerous policy initiatives, including reforms in food security, defense modernization, fiscal spending and budget allocation, social welfare programs, infrastructure development, and energy transition plans, many of which have not yet been accompanied by detailed implementing regulations. This combination of policy breadth and regulatory uncertainty may create short-term volatility and unpredictability in the business environment. In addition, the incumbent administration has initiated several changes to existing legislation, including the fourth amendment to the SOE Law, which may result in further adjustments to the regulatory framework. Challenges in implementation, coupled with frequent judicial reviews, may further affect the stability and predictability of the legal and regulatory environment, potentially impacting business operations across sectors. 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. ​ 50 Table of Contents 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. While the Indonesian economy continues to recover, certain internal and external pressures could have an adverse effect on our business, financial condition, results of operations and prospects. 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. Since 2025, these tensions have significantly intensified, with the U.S. imposing sweeping additional tariffs on Chinese goods and China implementing retaliatory measures, including increased tariffs and export restrictions on critical goods. In 2026, this trajectory has accelerated: a broad-based U.S. tariff reset, partially triggered by U.S. court proceedings and executive action, has disrupted global trade patterns and 51 Table of Contents created significant volatility in emerging market currencies and capital flows. U.S.-China bilateral ties remain structurally adversarial, and any resumption of active trade hostilities could further reduce capital inflows and investment in emerging markets such as Indonesia, exerting downward pressure on the Rupiah, disrupting regional supply chains, and increasing external financing costs. Further, the U.S. Federal Reserve's monetary policy decisions continue to impact global markets. Through 2025 and into 2026, the U.S. Federal Reserve has navigated a complex policy environment, balancing residual inflation concerns, tariff-induced price pressures, and signs of slowing U.S. economic growth, resulting in a prolonged period of elevated interest rates relative to the pre-2022 baseline. This sustained higher-rate environment causes fluctuations in capital flows and currency values in emerging markets, including Indonesia. Persistent inflationary pressures in Indonesia and higher borrowing costs remain a concern, potentially impacting our profitability if we are unable to pass on increased financing expenses. In addition, China's economic slowdown persisted into 2026, with ongoing challenges in its property sector, consumer demand, and financial markets. This has had ripple effects across the region, dampening business sentiment and investment appetite. The sluggish recovery in China continues to strain global supply chains and weighs on regional economic growth, creating uncertainty for countries reliant on trade with China, including Indonesia. 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, with ongoing conflict and geopolitical escalation in the region in 2025 and into 2026 continuing to exert upward pressure on global energy prices and contributing to intermittent supply disruptions. These geopolitical tensions increase uncertainty in global markets, contributing to inflationary pressures and reducing global business and consumer confidence. The reconfiguration of global security arrangements, including shifts in NATO commitments, increased defense spending across Europe and Asia, and heightened great-power competition, has introduced an additional layer of structural unpredictability into the global trade and investment environment. Further regional escalations could pose a significant downside risk to global growth and stability, with cascading effects on developed and emerging economies, including Indonesia and other Southeast Asian markets. 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, geopolitical developments, and internal strategic and governance risks could suppress business activity, disposable income, and consumer purchasing power, which may reduce demand for communication services, including our services. Such a decline in demand, or a failure to successfully execute our strategic initiatives, could have a material adverse effect on our business, financial condition, results of operations and prospects. Prolonged global uncertainties or future economic instability could have a material and adverse impact on the performance of our business. 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 to a low of Rp16,676 to US$1.00 on December 31, 2025, (based on the middle exchange rate published by Reuters Refinitiv), due to, among other factors, the slowing global economy and strong U.S. Dollar. The Indonesian Rupiah may continue to soften in the future. 52 Table of Contents 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 1.57% and 2.92% in the years ended December 31, 2024 and 2025, respectively. Based on ongoing economic pressures in the wake of the military conflict in Ukraine, it is anticipated that inflation may continue to rise in the near future. Interest rates have increased rapidly and substantially as central banks in several countries and regional blocks raised interest rates in an effort to subdue inflation. If inflation causes interest rates to further increase significantly and results in a rapid increase in benchmark rates, it could have a material adverse effect on Indonesia’s economy, business climate and consumer confidence. Even if we have not yet experienced any such impact on our revenues in 2025, higher inflation rates generally lead to a reduction in purchasing power, thus increasing the likelihood of a lower level of demand for our products and services in Indonesia, which would have a negative impact on our revenues. Further, any increase in our costs and expenses due to inflationary pressures that we would not be able to match (partially or fully) by increasing our prices would decrease our profit margin. Eventually, tighter monetary policy and potentially higher long-term interest rates may drive a higher cost of capital for our business. As a result, a high inflation rate in Indonesia could have a material adverse effect on our business, financial condition, results of operations and prospects. 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 negative outlook by Moody’s, “BBB” with stable outlook by Standard & Poor’s and “BBB” with negative 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 53 Table of Contents 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 promote proportionality and adequate living standards for employees. The Constitutional Court also directed the Government and legislature to draft a standalone manpower law by 2026, adding further uncertainty to the Indonesian labor regulatory framework. As of September 30, 2025, the Government has formed an official drafting team comprising representatives from relevant ministries and tripartite stakeholders, and has commenced a series of public consultations with labor unions, employer associations, business chambers, and civil society groups. These consultations remain ongoing, and the scope, structure, and substantive policy direction of the forthcoming manpower law continue to be subject to further deliberation. Given the early stage of the drafting process and the possibility of material revisions arising from stakeholder negotiations, the timing and final content of the new manpower law remain uncertain and may result in additional regulatory changes affecting employment arrangements, wage determinations, outsourcing practices, and other labor-related obligations applicable to employers in Indonesia. The evolving regulatory landscape creates significant uncertainties in Government oversight and compliance standards, which could affect our strategic and financial planning. The mandate to enact a standalone manpower law by 2026 adds another layer of complexity, as potential changes to core labor provisions could require adjustments to our employment practices. New labor regulations may increase operational costs as we adjust to meet stricter compliance requirements, particularly in areas such as employee compensation, benefits, and severance. We may need to make additional investments in human resources and compliance systems to address these challenges. The changes necessitated by the evolving labor regulatory landscape could have a material and adverse effect on our cost base, which would in turn materially and adversely affect our business, financial condition, results of operations, and prospects. 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. In November 2025, following a cyclone, floods caused fatalities and damages in Sumatra. From time to time, natural disasters have killed, affected or displaced large numbers of people and damaged our equipment. These events in the past have 54 Table of Contents 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. 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 policy-making across all jurisdictions in which we operate, including as a result of initiatives relating to various United Nations climate summits advocating for global actions to limit temperature rise. For example, many countries are incorporating environmental targets into their domestic policies, with increased pressure to set ambitious sustainability goals. We anticipate that the climate-related regulatory environment in which we operate will be subject to further regulatory developments. Such regulatory developments, together with existing guidance and expectations, may increase the potential transition risks for us, by mandating investments of resources for regulatory compliance, potential GHG emission taxes, and additional environmental monitoring and reporting obligations. These developments may raise the costs associated with energy consumption, notably as expenses on electricity represent a substantial portion of our operational costs. In addition, customer and public perceptions of our efforts to mitigate climate change may limit demand for our products and services, particularly if people perceive our efforts to be less effective than those of our competitors. 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. 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 55 Table of Contents continuance of any of the above-mentioned risks could have a material adverse effect on our financial condition, results of operations and, if severe or prolonged, our prospects. 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: · Variations in our revenue, earnings, cash flow and operating data; · Regulatory or legal developments in Indonesia, jurisdictions where we carry out our operations or in the United States; · Announcements of new investments, acquisitions or strategic partnerships by us or our competitors; · General economic, political, and market conditions and overall fluctuations in the financial markets in Indonesia, the United States, and other countries where we carry out our operations; · Sales volumes of our ADSs or ordinary shares, or sales of our ADSs or shares by our senior management, directors, or our large shareholders, or the anticipation that such sales may occur in the future; · Stock market price and volume fluctuations of comparable companies and, in particular, companies that operate in the telecommunications industry or with most of their operations in Indonesia; · Investors’ general perception of us and our business; · Announcements of new products, services and expansions by us or our competitors; · Changes in financial estimates or recommendations by securities analysts; · Detrimental adverse publicity about us, our services or our industry; · Additions or departures of key personnel; and · Potential litigation or regulatory investigations. 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 could be influenced by research reports that industry or securities analysts publish about us or our business. If one or more analysts who cover us downgrade our ADSs or ordinary shares, the market price for our ADSs would likely decline. If one or more of these analysts cease to cover us or fail to regularly publish reports on us, we could lose visibility in the financial markets, which in turn could cause the market price or trading volume for our ADSs to decline. 56 Table of Contents 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 ordinary shares differ from time to time due to currency fluctuations and other factors. 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 that have significant negative impact specifically on the U.S. capital markets may result in a decline in the trading price of our shares notwithstanding that such event may not impact the trading prices of securities listed on the IDX generally or to the same extent, or vice versa. 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, 2025, on May 12, 2026. We furnished such financial results to the SEC on a Form 6-K dated May 12, 2026, which contains our Consolidated Financial Statements as of and for the year ended December 31, 2025, which were prepared in conformity with IFAS. IFAS differs in certain significant respects from IFRS and, as a result, there are differences between our financial results as reported under IFAS and IFRS, including profit for the year attributable to owners of the parent company and net income per share. We distribute dividends based on profit for the year attributable to owners of the parent company and net income per share determined in reliance on IFAS. Based on the financial statements prepared in accordance with IFAS, our profit for the year attributable to owners of the parent company amounted to Rp23,186 billion and Rp22,403 billion (as restated) in 2023 and 2024, respectively, and Rp17,814 billion (US$1,068 million) in 2025. Our earnings per share were Rp234.0 and Rp226.1 (as restated) in 2023 and 2024, respectively, and Rp179.8 in 2025. For the fiscal year ended December 31, 2023, dividends declared per share were Rp178.5 and dividends declared per ADS were Rp17,850. For the fiscal year ended December 31, 2024, dividends declared per share were Rp212.47 and dividends declared per ADS were Rp21,247. The dividends for the fiscal year ended December 31, 2025 will be decided at the 2026 AGMS, scheduled for June 8, 2026. 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. 57 Table of Contents 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 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 58 Table of Contents 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. 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 judgment would be considered admissible as evidence during the subsequent enforcement proceedings in Indonesia. However, it is important to note that the Indonesian courts retain the discretion to assess the appropriateness of a foreign judgment under the given circumstances. 59 Table of Contents 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. ​ ​