INDONESIA Law and Practice Contributed by: Emir Nurmansyah, Monic N. Devina, D. Meitiara P. Bakrie and Nesya Ashari, ABNR Counsellors at Law
1. Fintech Market 1.1 Evolution of the Fintech Market Evolution of the Sector The new payment system regulation
(ii) Forwarding of payment transactions, which consists of first, forwarding of pay - ment transaction data and forwarding of payment instructions, which may be ac - companied by facilitation of the receipt of payment proceeds through the provision of sub‑accounts to Goods and/or Service Providers, and second, forwarding of fund transfer instructions in both digital and non‑digital forms. The PJP who conducts this activity may be classified as an Other PSP. (i) The forwarding of payment transaction data and payment instructions, which may include the facilitation of the receipt of funds arising from payment transactions. The PJP who conducts this activity may be classified as an Other PSP. (ii) The forwarding of fund transfer instruc - tions through digital and non‑digital means. The PJP who conducts this activ - ity may be classified as an Other PSP. (c) Bundled activity 3, which covers the forward - ing of a non-digital fund transfer. The PJP who conducts this activity may be classified as the Other PSP. Comparison from the previous regime Industry classification BI Reg. 10/2025 introduces a Main PSP v Other PSPs, determined by TIKMI to assess the impact, role, and/ or contribution of the activity within the national pay - ment system ecosystem. BI Reg. 22/2020 established the use of a PJP and the criticality classes Systemic Payment System Provider (PSPS), Critical Payment System Provider (PSPK), and General Payment System Provider (PSPU). Licensing model BI Reg 10/2025 uses bundled “activity packages” (eg, bundling activity 1)a) 1)b), 2, and 3). Bundled activity 1)a) is the most comprehensive and is limited to the Main PSP. (b) Bundled activity 2, which covers: BI Reg 22/2020 used licences categorised by indi - vidual activities (eg, source‑of‑fund information, pay -
On 24 December 2025, the Bank of Indonesia enact - ed Bank of Indonesia Regulation No 10 of 2025 on the Regulation of the Payment System Industry (BI Reg 10/2025). The objective of BI Reg 10/2025 is to strengthen the structure of the payment system industry by increasing the capabilities of the payment system industry and infrastructure in risk manage - ment. This objective was mandated by the Indonesian Payment System Blueprint 2030 issued by Bank of Indonesia in 2024, as the subsequent policy outlook after Indonesian Payment System Blueprint 2025. This regulation will come into force on 31 March 2026. What changed? BI Reg 10/2025 introduces a risk-based and capabil - ity-based classification, thereby updating the frame - work previously established under Bank Indonesia Regulation No 22/23/PBI/2020 on Payment System (“BI Reg 22/2020”). Key changes from the prior frame - work are summarised as follows: • Payment system service providers (PSP) consist of a payment system provider (PJP), a payment infra - structure provider (PIP), and a commercial bank. They are now classified into a Main PSP and Other PSPs, as elaborated in the following. • Bank Indonesia will determine the PSP classifi - cation on the basis of a criterion called “TIKMI”, ie, transaction ( transaksi ), interconnectedness ( interkoneksi ), competence ( kompetensi ), risk management ( manajemen risiko ), and infrastructure of information technology ( infrastruktur teknologi informasi ). • Bank Indonesia will determine the bundling activi - ties for the payment system provider (PJP) based on the following: (a) Bundled activity 1, which covers: (i) Administration of the source of the fund, which consists of, first, payment ac - counts. and second, the issuance and/or provision of access to sources of funds. The PJP who conducts this activity must be classified as the Main PSP.
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