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
ing continuity of loan administration in distressed scenarios. The P2P Circular Letter reflects the OJK’s continuing efforts to enhance transparency, governance and risk management in Indonesia’s P2P lending landscape. It introduces a comprehensive operational framework for P2P lending platforms to implement OJK Regula - tion 40. The phased implementation timeline provides a structured transition period for P2P lending plat - forms to adapt, with the aim of ensuring a seamless transition towards full compliance. Alongside regulatory tightening by the OJK, Indone - sia’s P2P sector has come under increasing scrutiny from the KPPU. The KPPU has taken the position that guidelines issued by the Indonesian Fintech Lending Associa - tion ( Asosiasi Fintech Pendanaan Bersama Indone- sia or AFPI), including the cap on daily interest rates (reduced from 0.8% to 0.4% in 2021), may constitute an internal and exclusive agreement among competi - tors. Another key regulatory trend is the further elaboration of soundness-level ( tingkat kesehatan ) requirements for P2P lending platforms, which were first introduced by OJK Regulation 40. Platforms are assessed using a composite ranking system from one (most sound) to five (least sound), based on capital, funding quality, profitability, liquidity, and management – similarly to traditional financial services. To facilitate implementation of the new rules, the OJK Board of Commissioners Regulation 38 of 2025 was issued on 8 December 2025 to provide further clar - ity. Unlike earlier draft guidance that contemplated a self‑assessment regime subject to OJK oversight, the new regulation emphasises the OJK’s authority to ver - ify and validate the accuracy and fairness of data used by platforms in determining their soundness level. This approach reinforces the OJK’s supervisory discretion and aligns P2P oversight more closely with prudential standards applicable to other financial services. Taken together, these developments reflect a maturing regulatory landscape for Indonesia’s P2P industry. The
OJK’s tighter regulatory requirements and oversight indicate a decisive shift towards sustainable growth, stronger governance, and systemic risk control. For P2P lending platforms, compliance readiness and regulatory engagement will be critical as the industry adapts to this more disciplined operating environment. Financial Services Aggregator Passed OJK Sandbox Following the successful completion of the regulato - ry sandbox phase for financial services aggregation activities – namely, activities involving the collection, filtering and/or comparison of information on financial products and services offered by financial services institutions or other parties operating in the financial services sector, including financing agents, funding agents and wealthtech platforms – the OJK issued Regulation 4 of 2025 on 26 February 2025 (“OJK Reg - ulation 4”). This regulation provides a licensing and supervisory framework for financial services aggrega - tors, which were previously regulated under the gen - eral innovation regime pursuant to OJK Regulation 3 of 2024 and its implementing OJK Circular Letter 6 of 2024. OJK Regulation 4 marks the second information tech - nology‑based financial innovation ( Inovasi Teknologi Sektor Keuangan or ITSK) business model to be regu - lated under a dedicated OJK regulation, following the issuance of the alternative credit scoring (ACS) frame - work, which also attracted attention from market play - ers and investors. The regulation reflects the OJK’s growing emphasis on transitioning mature sandbox participants into fully licensed and supervised entities. The key points to note in OJK Regulation 4 follow: • Paid‑up capital: Financial services aggregators must be established as Indonesian limited liabil - ity companies with minimum paid‑up capital of IDR500 million. Similarly to other OJK‑regulated financial services entities, the paid‑up capital must not be sourced from loans. • Foreign ownership: The regulation permits direct and indirect foreign ownership of up to 85%, but this limit does not apply to publicly listed entities. • Governance and fit‑and‑proper requirements: Financial services aggregators must have at least
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