Fintech 2026

INDONESIA Law and Practice Contributed by: Emir Nurmansyah, Monic N. Devina, D. Meitiara P. Bakrie and Nesya Ashari, ABNR Counsellors at Law

ment initiation, acquiring, source of fund administra - tion, money remittance). Governance and risk BI Reg 10/2025 requires enhanced corporate gov - ernance, comprehensive risk management, Payment System Business Plan ( Rencana Bisnis Sistem Pem- bayaran ) business plans, and end‑to‑end supervision (licensing → monitoring → enforcement/exit). BI Reg 22/2020 determined that governance and risk management was required, but it was not anchored to the unified TIKMI assessment and bundling model. There is a significant number of players in the Indo - nesian fintech lending sector. The Otoritas Jasa Keuangan (OJK), Indonesia’s independent financial services authority, has recognised 96 Peer-to-Peer (P2P) lending companies that obtained P2P lending business licences from the OJK as of August 2025. Nevertheless, currently, P2P lending companies are outnumbered by fintech players in the payment sys - tems sector. It has been reported that 566 payment service providers have been licensed by the Bank of Indonesia (BI). 2.2 Regulatory Regime Indonesia’s fintech industry is supervised by two discrete regulators: the BI and the OJK. While the BI supervises fintech and payment systems (e-money, e-wallets and other unclassified payment system fin - tech providers), the OJK supervises non-payment fin - tech (P2P lending, equity crowdfunding and financial sector technology innovation (FSTI)). The regulations that serve as the main legal basis for the aforementioned fintech models are: • BI Reg 10/2025; • BI Regulation No 23/6/PBI/2021 on Payment Sys - tem Providers (“BI Reg 23/2021”); • BI Regulation No 23/7/PBI/2021 on Payment Sys - tem Infrastructure Providers; 2. Fintech Business Models and Regulation in General 2.1 Predominant Business Models

• BI Regulation No 14/23/PBI/2012 on Fund Trans - fers as partially revoked by BI Reg 23/2021 (“BI Reg 14/2012”); • OJK Reg 40 of 2024 on Information Technolo - gy-Based Joint Funding Services (“OJK Reg. 40/2024”), for P2P Lending; • OJK Regulation No 17 of 2025 on Securities Offer - ings via Information Technology-based Equity Crowdfunding Services (“OJK Reg 17/2025”) for Equity Crowdfunding; • OJK Regulation No 3 of 2024 on the implementa - tion of FSTI (“OJK Reg 3/2024”); • OJK Regulation No 29 of 2024 on Alternative Credit Scoring; • OJK Regulation No 27 of 2024 on the implemen - tation of Financial Digital Asset Trading Including Crypto Assets, as amended by OJK Regulation No 23 of 2025 (“OJK Reg 27/2024”); and • OJK Regulation No 4 of 2025 on Financial Services Aggregation Organiser, as amended. 2.3 Compensation Models There are no specific requirements for charging cus - tomers, and compensation models depend on the contractual arrangements between fintech providers and their customers. 2.4 Variations Between the Regulation of Fintech and Legacy Players Banks, as traditional financial institutions, are sub - ject to a robust regulatory regime designed to ensure financial stability and protect depositors. This includes strict capital adequacy norms, liquidity requirements, and comprehensive risk management frameworks. While some fintechs, such as P2P lending and pay - ment system providers, must meet minimum capital and governance standards, others, like aggregators and funding or financing agents, face fewer financial requirements. Fintechs supervised by the OJK (as opposed to those under BI supervision) are subject to consumer protection, anti-money laundering (AML), and governance requirements, including “fit-and- proper” tests where applicable (eg, P2P lending and digital banks). Meanwhile, BI-regulated fintechs (such as payment system providers) are also subject to AML obligations under BI regulations.

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