Most sustainability reports in Indonesian banking are assembled, not produced. The gap shows when someone asks where a figure came from.
Ask a bank’s sustainability team where the electricity-consumption figure in last year’s report came from, and the answer may be a chain of spreadsheets, emails, invoices and people. A facilities coordinator may have read the numbers from invoices and sent them by email. Someone else may have put them into a spreadsheet. By the time the figure reaches the sustainability report, the original documents may be gone.
The number may be right. But if nobody can trace it back, it is difficult to explain or reproduce.
For years, that was largely acceptable. POJK 51/2017 required banks to publish a sustainability report each year, while SEOJK 16/2021 set out its content. The sustainability report was still largely treated as a reporting document alongside the annual report. Its numbers did not necessarily go through the same controls used for financial reporting.
That is changing.
From 1 January 2027, PSPK 1 and PSPK 2, Indonesia’s adoption of the ISSB standards, will bring sustainability and climate disclosures closer to the financial statements. The standards cover governance, strategy, risk management, and metrics and targets. Climate-related metrics also include greenhouse-gas emissions across Scope 1, 2 and 3. For banks, that can extend to financed emissions across the loan portfolio.
OJK’s climate work is moving in the same direction. The 2024 Climate Risk Management and Scenario Analysis framework and the 2026 Climate Risk and Banking Resilience Assessment both require banks to work with climate data in more detail. The data needs to support risk assessment and scenario analysis, not simply appear as a figure in a report.
The practical question is what happens when an ESG figure starts being treated like a financial figure.
A financial figure has an owner, a source system, a process that can be explained, and controls to catch errors. Many ESG figures still do not.
The Five-Number Test
You do not need to start with a full ESG data assessment. Pick five numbers from your latest sustainability report and trace each one back to where it entered the bank.
A useful set could include total electricity or fuel consumption, Scope 2 emissions, the value of financing classified as sustainable or green, an employee metric such as training hours, and a figure used to support a public sustainability target.
For each number, trace its original source. Find out who handled it along the way and what happened to it before it reached the report. Then try to reproduce the number using the same inputs.
The exercise usually puts the data into three broad groups.
System-sourced numbers come from a ledger, HR system, core banking system or facilities platform. The source is identifiable and the process can generally be run again.
Spreadsheet-sourced numbers depend on a workbook maintained by a person or team. The spreadsheet itself is not necessarily a problem. The issue is whether the bank knows where the underlying data came from, who changed it, which version was used and how the final number was produced.
Estimated numbers are calculated using a factor, proxy, assumption or other form of judgment. This is common for certain emissions metrics, particularly Scope 3 and portfolio-level figures. The estimate can still be valid, but the bank needs to know which factor or assumption was used, where it came from and when it was last reviewed.
The split is rarely even. Numbers that sit close to financial or credit data, such as sustainable-financing balances, are more likely to come from existing systems. Environmental data is more likely to pass through spreadsheets. Scope 3 and portfolio-level figures often rely on estimates, sometimes using factors that have been in place for years.
What the Test Tells You
The point is not that a spreadsheet number or an estimated number is automatically wrong. Many are reasonable ways to produce a figure.
The problem comes when someone asks where the number came from and the bank cannot answer without tracking down a file, an email or the person who originally prepared it.
Those questions are becoming more relevant. An assurance provider may ask them. An audit committee may ask them when ESG information is reviewed alongside the financial statements. A supervisor may need the underlying climate data for risk assessment or scenario analysis.
The test also tends to expose the same bottleneck. It is usually ownership, not software.
A spreadsheet-sourced number may have someone responsible for collecting it, but that is not necessarily the same as having someone accountable for its accuracy. A general-ledger account has a clear owner. Many ESG metrics do not.
That is an organizational issue. It needs to be addressed before choosing a tool, because a system can manage a number. It cannot take responsibility for one.
Where to Start
Start by giving every reported ESG metric a named owner and a named source. Keep both in a register that the relevant functions, including finance, can access.
Then look at the numbers that matter most. If a figure feeds a public target, a sustainability classification or another important disclosure, it may be worth moving that data from a spreadsheet into a controlled system before tackling lower-risk metrics.
For estimated numbers, record the factor or proxy used, its source and the date it was last reviewed. That makes it possible to understand how the number was produced when it is used again or questioned later.
None of this makes a bank more sustainable.
It makes its sustainability numbers easier to trace, reproduce and defend. From 2027, that distinction will matter.
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