Fintech 2026

INDONESIA Trends and Developments Contributed by: Vik Tang, Michelle Virgiany, Almira Tengku, Ruth Ginting and Ryu Wirjadi, Hiswara Bunjamin & Tandjung in association with Herbert Smith Freehills Kramer

Introduction Indonesia’s fintech sector continued to remain active and evolve throughout 2025 and into 2026. This was driven by new regulatory frameworks intended to enhance digital adoption across financial sectors and support sustainable growth in the fintech indus - try. Regulators, including Bank Indonesia (BI) and Indonesia’s Financial Services Authority (OJK), have introduced new regulations and guidelines across key verticals such as payments, digital banking, digital financing, digital assets, and other emerging innova - tion models. These regulatory developments reflect a shift toward a more governed, structured, and mature fintech eco - system in Indonesia. At the same time, industry play - ers continue to innovate, particularly in areas such as buy-now-pay-later (BNPL) services, alternative credit scoring (ACS), digital financial asset markets and oth - er AI‑driven financial services, contributing to more financial inclusion and digital transformation. In addition, as part of Indonesia’s broader transition toward a more integrated supervisory framework, it appears that more financial conglomeration will be set up, although its implementation is still at an early stage and market practices continue to evolve. This article provides an overview of the key regulatory and market developments observed across Indone - sia’s fintech industry over the past year and highlights emerging trends that are likely to shape the sector in In late 2025, Bank Indonesia issued Bank Indonesia Regulation 10 of 2025 and its implementing regula - tion, as part of a broader redesign of the payment system industry framework. Some of the notable changes are: • The introduction of a new core concept known as a TIKMI assessment, covering Transaction, Intercon - nection, Competence, Risk management, and IT infrastructure. The BI will issue further guidelines on the variables and indicators to be taken into account, the assessment mechanisms, and the the year ahead. Digital Payment

assessment thresholds, and will finalise its first TIKMI assessments by 1 April 2027. The TIKMI assessment results will be used by the BI to deter - mine, among other things: (a) whether a particular payment services provider (PSP) is deemed a Primary PSP; (b) the package/bundling of activities that can be carried out by a front-end payment services provider (PJP); (c) access to participate in the payment system infrastructure; and (d) the type of co-operation that PSPs may enter into. • Replacement of static PJP categorisation with a more modular bundling of the activities that each PJP can do. Under the new regulatory framework, a PJP’s assigned bundle of activities may change, based on: (a) the PJP’s own initiative; (b) its TIKMI assessment results or evaluation to determine its classification; (c) the result of the BI’s supervision; and (d) other aspects determined by the BI. • Introduction of a requirement for PSPs to put together a three-year Strategic Business Plan (SBP) and a one-year business plan called a Pay - ment System Business Plan (RBSP). Licensed payment companies must submit their first set of business plans by 30 April 2026. • Unlike the current regulatory regime, the new framework regulates supporting operators more comprehensively, with the BI classifying them into one of three categories: critical, important or standard. In determining the category of a support - ing operator, the BI will consider how critical the services provided by the supporting operator are, and the scope of their services. Critical and impor - tant supporting operators must register with the BI, either directly or through the PSP with which they are co-operating. This registration requirement will take effect by 31 March 2029. In addition to the regulatory refresh, the BI has been pushing for faster, more seamless retail adoption through Near Field Communication (NFC)-based Quick Response Code Indonesian Standard (QRIS) Tap (including “Tap In–Tap Out” use cases), with an initial focus on public transport and public services.

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