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, under Dual-regulator regime: Bank Indonesia (BI) licenses payment service providers and e-money under the Payment System Law (UU 4/2023) and PBI No. 23/6/PBI/2021; the Financial Services Authority (OJK) licenses fintech lending and BNPL under POJK No. 40/2024 and POJK No. 32/2025, plus the ITSK innovation regime under POJK No. 3/2024..
Indonesia operates a clear, mature licensing regime for digital payments and fintech split between two regulators. Bank Indonesia authorises and supervises payment service providers (PJP) and electronic money issuers and runs national rails (BI-FAST, QRIS) and the SNAP open API standard, while OJK licenses peer-to-peer lending, BNPL and other technology-based financial innovation (ITSK). Both regulators have issued substantial new or updated rules in 2024-2025.
Key points
Non-bank and bank payment service providers must obtain a PJP licence from Bank Indonesia under PBI No. 23/6/PBI/2021, with licences granted by activity category and requirements covering capital, risk management and IT capability. A new payment-system industry framework (BI Regulation No. 10 of 2025) takes effect 31 March 2026, and non-bank PJPs require at least 15% Indonesian ownership.
BI runs the national real-time retail rail BI-FAST (launched December 2021, 24/7, ISO 20022, IDR 250 million per-transaction cap) and the unified QRIS QR-code standard (developed with ASPI), which uses bank accounts and server-based e-money as funding sources.
Bank Indonesia introduced the National Open API Payment Standard (SNAP) via BI Governor Decree No. 23/10/KEP.GBI/2021 (16 Aug 2021), mandating standardised technical, security and data specifications for open API payments to ensure interoperability; ongoing governance has been passed to the payments association ASPI.
P2P/IT-based co-funding providers must obtain an OJK business licence; POJK No. 40/2024 (in force 27 Dec 2024, replacing POJK 10/2022) raised minimum paid-up capital to IDR 25 billion, set equity and liquidity ratios, and capped combined interest plus fees at 0.3% per day for consumptive funding.
POJK No. 32 of 2025 governs Buy Now Pay Later, effective 15 Dec 2025; BNPL may only be offered by commercial banks and licensed financing companies, and from 1 Jan 2027 users must be at least 18 years old with a minimum monthly income of around IDR 3 million.
OJK Regulation No. 3 of 2024 created a licensing/registration regime for Technological Innovation in the Financial Sector (ITSK), covering activities such as crowdfunding, credit scoring, aggregators, e-KYC and digital financial assets including crypto-assets supervised by OJK.
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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