Digital Payments & Fintech · Indonesia
Fintech & payments regulation in Indonesia (2026)
Indonesia shaded by its digital payments & fintech status
Fintech and digital payments in Indonesia: licensing regime.
FrameworkDual-regulator regime: Bank Indonesia (payments/e-money) under PBI 23/6/PBI/2021 on Payment Service Providers (to be superseded by PBI 10/2025 effective 31 March 2026) and PBI 20/6/PBI/2018 on Electronic Money; Otoritas Jasa Keuangan (OJK) supervises fintech lending under POJK 40/2024 and BNPL under POJK 32/2025.
Indonesia operates a mature, dedicated licensing regime for digital payments and fintech split between Bank Indonesia (BI) — which licenses Payment Service Providers (PJPs), Payment System Infrastructure Operators (PIPs), and e-money issuers — and OJK, which authorises P2P lending platforms, BNPL providers, and other non-bank financial services. A comprehensive rewrite (BI Regulation 10/2025 issued 24 December 2025, effective 31 March 2026) consolidates the payment-system rules and introduces the TIKMI risk-based classification framework. Instant payments run via BI-FAST and QRIS, and open-banking APIs are standardised under BI's SNAP framework.
Key points
Bank Indonesia licenses Payment Service Providers (PJPs) and Payment System Infrastructure Operators (PIPs) under PBI 23/6/PBI/2021 and PBI 23/7/PBI/2021. From 31 March 2026 these will be consolidated under Bank Indonesia Regulation No. 10 of 2025, which classifies providers as 'Main' or 'Non-Main' PSPs based on the five-factor TIKMI assessment (Transaction, Interconnection, Competence, Risk Management, IT Infrastructure). Existing licensees receive a three-year (extendable by two) transition to meet the new requirements.
E-money is regulated by BI Regulation No. 20/6/PBI/2018. Non-bank e-money issuers must hold at least Rp 3 billion of paid-up capital (scaling with float held), licences are valid for five years, and issuers are classified between closed-loop and open-loop. E-money will be brought within the consolidated PJP framework once PBI 10/2025 takes effect.
OJK licenses Information Technology-Based Peer-to-Peer Lending services (LPBBTI) under POJK 40/2024 (effective 27 December 2024), which replaced POJK 10/2022. Licensees must reach IDR 12.5 billion in equity by 4 July 2025, maintain a 120% liquidity ratio and NPL below 5%, and observe daily interest-rate caps (e.g. 0.275%/day for short-tenor consumptive loans from 1 January 2025). Implementation guidance was issued in Circular Letter No. 19/SEOJK.06/2025 on 31 July 2025.
OJK Regulation No. 32 of 2025, promulgated and effective 15 December 2025, is the first dedicated BNPL framework. It restricts provision to commercial banks and OJK-approved financing companies, defines six cumulative characteristics of a BNPL product, and gives existing providers until 15 June 2026 to comply.
Bank Indonesia operates BI-FAST, the domestic real-time retail payment infrastructure launched in December 2021, alongside QRIS (Quick Response Code Indonesian Standard) as the mandatory national QR-payment standard for all PJPs. Both are anchored in BI's Payment System Blueprint 2025.
Open banking follows BI's Standar Nasional Open API Pembayaran (SNAP), launched in 2022 as the mandatory national open-API standard for payments. Phase 2 (2024–2025) extends APIs into lending, digital identity, and transaction categorisation via regulated sandboxes, complementing BI-FAST rails.
Timeline - major decisions & events
Under Government Regulation 49/2024 and OJK Regulation 27/2024 (implementing the P2SK Law), authority over crypto and other digital financial assets moved from the commodity-futures agency Bappebti to the Financial Services Authority (OJK), reclassifying crypto from a commodity to a regulated financial asset and bringing crypto-asset traders under OJK licensing.
SSEK Law Firm ↗OJK Regulation 40/2024 on IT-Based Joint Funding Services took effect, replacing POJK 10/2022; it lets cooperatives (not just limited liability companies) be licensed as P2P operators and imposes new financial-soundness ratios (equity at 50% of paid-up capital, liquidity ratio of 120%).
SSEK Law Firm ↗The Law on the Development and Strengthening of the Financial Sector created the umbrella legal category of ITSK (financial-sector tech innovation/fintech), split supervision between Bank Indonesia and OJK, and mandated the transfer of crypto/digital-asset oversight to OJK, the foundation for the post-2024 licensing regime.
ICLG ↗OJK's revised P2P lending rule eliminated the prior register-then-license two-step process (license-only), raised minimum paid-up capital tenfold to IDR 25 billion, and required operators to register as Electronic System Operators with the communications ministry.
HBT Law ↗BI's Payment Service Provider regulation replaced legacy rules, consolidating payment activities (information on funds, payment initiation/acquiring, fund administration, remittance) and introducing a risk-based, three-category licensing system tied to a provider's size, connectivity, complexity and irreplaceability.
Bank Indonesia ↗Via Board of Governors Regulation 21/18/PADG/2019, BI introduced the Quick Response Code Indonesian Standard, requiring all QR payment codes to interoperate under one standard (mandatory from 31 Dec 2019), unifying a fragmented digital-payment market.
Bank Indonesia ↗Replacing the 2009 e-money rule, BI distinguished closed-loop vs open-loop e-money for licensing purposes, set a 49% foreign-ownership cap and minimum IDR 3 billion paid-up capital for non-bank issuers, and exempted small closed-loop schemes (floating funds under IDR 1 billion).
Bank Indonesia ↗OJK Regulation 77/POJK.01/2016 on IT-Based Lending Services established the licensing/registration regime for peer-to-peer lending platforms, requiring operators to register with OJK and apply for a license within one year, marking OJK's formal entry into fintech supervision.
Global Legal Insights ↗Indonesia's first standalone electronic-money regulation created the original licensing framework for e-money issuers and operators, governing the sector for nine years until superseded by PBI 20/6/2018.
SSEK Law Firm ↗The ITE Law gave legal recognition to electronic transactions, signatures and certificates, the foundational statute underpinning all subsequent digital-payment and fintech regulation; later amended by Law No. 19 of 2016.
U.S. Library of Congress ↗Indonesia - other topics
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