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
BI-reported adoption metrics show that in the fourth quarter of 2025, QRIS Tap processed more than 1.44 million transactions with a total value of over IDR28 billion. This is an early indicator that NFC-style User Experience (UX) may become a meaningful layer on top of QRIS over time (even while device/UX coverage remains uneven). In February 2026, the BI joined the Bank for Interna - tional Settlements (BIS) Nexus project to enable faster cross-border payments by connecting Indonesia’s BI- FAST system with the payment systems of five other central banks in Asia. Digital Banking The 2025 Indonesian Banking Booklet published by the OJK highlights the regulator’s commitment to accel - erating digital transformation across all segments of the Indonesian banking industry. The OJK strengthens digital banking through a regulatory framework cover - ing IT implementation, technology risk management, cybersecurity, and digital maturity assessments. In the past five years, the OJK has issued several key guidelines, including Digital Resilience Guidelines and an AI Governance Framework for Indonesian banks. In line with the 2020–2025 Indonesian Banking Devel - opment Roadmap published by the OJK, banks are being incentivised to evolve into advanced digital institutions through the adoption of Application Pro - gramming Interface (API), cloud computing, AI, and cross‑sector digital partnerships. Digitalisation trends also extend to rural and syariah banks (BPR/BPRS), which are increasingly adopting mobile services, QRIS, open API, and fintech collaboration models. It should be noted that competition among Indone - sia’s digital banks is likely to intensify as they attempt to increase their market share and profitability. Digital Financing BNPL The OJK has introduced a new regulatory frame - work for BNPL services in Indonesia through OJK Regulation 32 of 2025, which became effective on 15 December 2025. This regulation responds to the rapid expansion of BNPL in Indonesia, with banks
and multi‑finance companies recording significant year‑on‑year growth in BNPL credit and financing. The regulation defines BNPL as “a financing facility provided by financial services institutions through electronic systems for the purchase of goods and/ or services”. Its key features include unsecured, electronic system‑based financing facilities for non- cash purchases, with set credit limits and repayment through agreed instalments. The BNPL regulation permits both commercial banks and multi-finance companies to offer BNPL services as long as they comply with their respective secto - ral regulations. Multi‑finance companies, in particu - lar, must obtain prior approval from the OJK before launching BNPL products. The regulation also allows co-operation with third parties such as e-commerce platforms, provided that transparency requirements and other applicable regulatory obligations are met. BNPL providers must comply with information dis - closure and consumer protection requirements. They must disclose information on funding sources and instalments through electronic channels to support responsible consumer decision-making. The regulation also gives the OJK wide supervisory authority. This includes the ability to impose maximum economic benefit limits for BNPL services provided by a multi-finance company and to order the cessation of BNPL operations in the case of a regulatory breach or increased risk profile that cannot be properly miti - gated, or an increase in customer complaints which cannot be resolved satisfactorily. Transitional provisions give existing BNPL providers until 15 June 2026 to align their services with the new rules, with existing agreements remaining valid unless amended. The OJK is expected to issue further imple - menting guidelines on BNPL services. P2P lending Indonesia’s peer‑to‑peer (P2P) lending sector contin - ues to undergo significant regulatory change, reflect - ing regulators’ broader push to strengthen govern - ance, consumer protection, and market discipline in the fintech ecosystem. Recent developments involv -
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