Chapter 6

Marks Without Prices

Roughly Rp9.1 trillion of Saratoga's Rp60.7 trillion portfolio has no quoted price behind it. The audited notes describe the methods in three short paragraphs, disclose no discount rate, multiple or range, and state that a sensitivity analysis would not be practicable. That slice has tripled as a share of the portfolio since 2022. Writing all of it to zero moves the discount to published net asset value from 60% to 53%.

Sources: FY2025 audit report, key audit matter [1]; FY2025 Annual Report, Note 17 Fair Value of Financial Instruments [2]; discount derived from the Rp1,760 close of 27 July 2026.

How big the unpriced book is

The auditor draws the line for you. At 31 December 2025 the Group held Rp34,543,686 million of Level 2 and Level 3 investments, including those measured at cost — 55.26% of consolidated assets — and of that, Rp25,485,721 million sits in entities that themselves own directly-quoted listed shares [3]. Those are the Bersama Digital and Adaro Strategic holding vehicles, whose value moves with TBIG, ADRO and AADI screen prices. The residual — Rp9,058 billion — is the part that does not trace to any quoted instrument. It is 14.9% of the Rp60,659 billion of investments the balance sheet carries, and 38% of Saratoga's Rp23,874 billion market capitalisation.

Four consecutive audit reports state the same two figures, so the series can be built on the auditor's own definition rather than a constructed one.

Sources: key audit matters, FY2022 [4], FY2023 [5], FY2024 [6] and FY2025 [7]; portfolio totals from the fair value hierarchy tables, FY2023 [8] and FY2025 [9].

Both halves of the ratio moved. The unpriced balance rose from Rp3,054 billion to Rp9,058 billion over three years while the portfolio itself first shrank — Rp61,518 billion at end-2022 to Rp49,008 billion at end-2023 as listed marks fell — then recovered to Rp60,659 billion [10] [11]. The management discussion reports the same trend in its own words: non-listed entities Rp5,142 billion at end-2025 against Rp3,647 billion a year earlier, up 41% [12].

Where the 2025 increase came from

Level 3 investments in shares went from Rp1,914,320 million to Rp5,143,569 million during 2025 [13]. Note 5's position-by-position table lets that Rp3,229,249 million increase be rebuilt, and most of it is accounting category rather than value.

Source: derived from Note 5 Investments in Shares, FY2025 Annual Report [14] [15] [16], and Note 17 [17].

Rp2,627,512 million of the increase — 81% — is positions arriving at their existing carrying values. Growth companies 9 and 10 were carried at cost of Rp1,472,491 million and Rp259,748 million at end-2024 and are Level 3 at end-2025 [18]. Growth companies 11 and 12 had no 2024 line at all; the footnote says their value was previously inside the Bersama Digital mark, and the BDIA footnote puts the non-tower assets held there at Rp895,273 million [19] [20].

The two positions that came off cost are now carried 24.0% and 22.8% above their prior-year figures — Rp412,592 million between them, 10% of the Rp4,107,537 million of fair-value gains booked on investments in shares for the year [21]. How much of that is fresh cash and how much is the change in measurement basis is not disclosed. Note 5's roll-forward runs by strategy bucket, not by hierarchy level, and its 2025 presentation merges additions with reclassifications into a single column where the 2024 version showed additions alone [22].

The timing points to the two investments made in 2024. Saratoga acquired a majority stake in the Brawijaya hospital chain in the first quarter of 2024 and a significant minority of the food-ingredients maker Foodex in the first half [23]. The cost approach applies for twelve months after acquisition [24], the two positions carried at cost at end-2024 hold ownership bands of above 50% and 20-50% matching those two deals, and both moved onto models a year later. The note anonymises, so this is an inference from ownership band and timing rather than a disclosure.

What stands behind the numbers

Note 17 sets out three methods. Anything bought in the last twelve months is held at cost. Where an investee's own net assets are themselves Level 1, Saratoga uses the carrying amount of those net assets. Everything else is valued by management using discounted cash flow and comparable-company multiples [25]. No discount rate, growth rate, multiple or valuation range appears anywhere in the accounts, and no external valuer is named. The note then closes the question explicitly: because the investees span varied industries with unique assumptions, "providing an aggregated disclosure of sensitivity analysis on the key inputs used would not be practiceable nor meaningful" [26].

That is a standing position, not a new one. The same statement sits in the FY2021 accounts [27] and in the Q1 2026 interim statements [28]. The reasoning is defensible for a portfolio of a dozen unrelated private businesses; the consequence is that the 15% of net asset value most exposed to judgment is the 15% for which no quantified sensitivity exists.

The contrast within the same set of accounts is sharp. Note 18(e) discloses, holding by holding, what a 10% share-price move does: Rp1,866,273 million for Tower Bersama, Rp1,426,264 million for the Adaro complex, Rp1,080,604 million for Merdeka and Rp244,153 million for Mitra Pinasthika — Rp4,617 billion in total [29]. Price risk is quantified precisely for the 85% that is observable and not at all for the 15% that is not.

Two further features limit what an outside reader can do with the unlisted table. The anonymised labels are not stable identifiers: the FY2023 report shows Growth company 9 at Rp135,290 million at 31 December 2023 [30], while the FY2024 report's comparative column for that same date shows Growth company 9 at Rp318,975 million and Growth company 6 at Rp135,290 million [31]. Tracking one private position across two annual reports is not possible from the published numbering.

And the investor-facing net asset value table takes the presentation one step further out. Every listed holding is shown with its effective ownership and its closing share price; the unlisted book appears as a single "Others" line under Growth Focused of Rp6,298 billion, against Rp4,330 billion a year earlier, with no price, no ownership percentage and no components [32]. That table also sits outside the audit. The auditor's report covers the consolidated financial statements only and records that the 2025 Annual Report "is expected to be made available to us after the date of this auditors' report" [33]. The Rp4,444 per share against which the whole discount is measured is management's own presentation, built from audited components.

What the marks have done when they moved

The one unlisted bucket old enough to show a full cycle is digital technology, and it has been marked down almost to nothing.

Sources: Note 5 Investments in Shares, FY2021 [34], FY2023 [35] and FY2025 [36].

From the Rp525,293 million peak at end-2022 the bucket is down 90%, and 2025's Rp240,092 million decline was Rp236,046 million of fair-value change against Rp4,046 million of divestment [37]. The exits from that book, examined in Realisation Record, were almost entirely markdowns rather than sales. What that record establishes about the estimates themselves is that they are revised, and revised hard, when the underlying businesses disappoint — a point in favour of the marks as much as against them.

The stronger evidence for management on this question comes from 2023. Saratoga reported a Rp13,811,067 million net loss on investments in shares and other securities that year, the largest in its listed history [38]. Level 3 investments in shares nonetheless rose from Rp1,395,722 million to Rp1,617,926 million over the same twelve months [39]. The write-down came from quoted prices, not from a discretionary sweep of the unlisted book while attention was elsewhere. Nor do the growth marks run one way: the growth-focused bucket took Rp594,610 million of negative fair-value change in 2024 before adding Rp1,134,325 million in 2025 [40].

What a haircut does to the discount

The unpriced book is Rp9,058 billion, or Rp668 per share on 13,564,835,000 shares. Applying a haircut to all of it and holding the rest of the published net asset value constant gives the following.

Source: derived from the FY2025 fair value hierarchy [41], the audit report's Level 2 split [42] and the published net asset value table [43]; share price at the 27 July 2026 close.

The read this supports: the unpriced book is not what creates the discount, and it is not large enough to remove it either. A complete write-off of every rupiah that does not trace to a quoted price still leaves the shares 53% below the remainder. For an investor working from a margin-of-safety frame, the estimation risk in the notes is bounded at roughly seven points of a sixty-point gap.

The fact that cuts hardest against reading the unpriced book as immaterial runs the other way, and it is about direction of travel rather than level. The three net asset value lines outside the blue-chip block carrying no share price — growth-focused "Others", digital fund investments, and other shares and securities — went from Rp7,674 billion to Rp9,602 billion during 2025, an increase of Rp1,928 billion [44]. That is Rp142 of the Rp464 by which published net asset value per share rose during the year — 31% of the gain, from lines an outside reader cannot verify. The slice is small enough to survive a write-off and large enough to move the reported number, and both statements matter.

What would change the read in either direction is the same event: a transaction. A listing or trade sale of one of the larger private positions would price the model against a market for the first time since the digital book began its decline, and would say more about the reliability of the remaining Rp9 trillion than any further disclosure. Failing that, a Level 3 reconciliation separating transfers from revaluation, or the unobservable-input table the accounts currently decline to give, would let the next reader do the work this chapter had to do by inference.