Abstract: In Indonesia the concept of corporate governance has been formally introduced in 1999 when the Government established the National Committee on Corporate Governance (NCCG). As other countries Indonesia through the NCCG created its national code of corporate governance in 2000 which was revised in 2006. The code is reference points for all companies in Indonesia include State-owned Enterprises (SOES) regardless of types.

Indonesian SOES is regulated under Law No. 19 of 2003 concerning State-Owned Enterprises. According to the law there are two types of SOES; public and non-public SOES. While the former is SOES listed companies or companies with shares are fragmented, the latter is companies with shares are concentrated in the hand of government as a sole shareholder. Consequently, the Indonesia’s code of good corporate governance applies to nonpublic SOES as well.

As companies owned by State, the primary characteristic of non-public SOES is concentrated ownership. The article examines the applying of Indonesia’s code of corporate governance to Indonesian non-public SOES; whether the code is suitable for Indonesian non-public SOES means the code can be a tool in puzzling out the existing problems of non-public SOES. The code is sacred to be discussed since a national code of code of corporate governance is the soul of implementation of a country corporate governance regime.