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

conglomeration” to consolidate ownership through the establishment or designation of a financial holding company ( perusahaan induk konglomerasi keuangan or PIKK), subject to prescribed asset thresholds. The PIKK may be either operational or non-operational. The regulation applies across a broad set of financial services subsectors, including banking, insurance, securities, multifinance, P2P lending, venture capi - tal, pawnshops and other financial institutions under the OJK’s supervision. OJK Regulation 30 does not expressly include non-bank payment services pro - viders regulated by the BI as financial conglomera - tion members. However, the OJK has discretion to designate additional entities as part of the financial conglomeration, provided they are subsidiaries of the PIKK and/or financial conglomeration members that support the activities of financial services institutions and/or the financial conglomeration. This includes, among others, financial sector technological inno - vation providers (including ACS entities) and entities which receive bank capital participation to support banking activities. A PIKK must be established or designated when a financial group meets either: • an aggregate asset threshold of at least IDR100 trillion and comprises at least two financial services institutions from different subsectors; or • an aggregate asset threshold of at least IDR20 trillion but below IDR100 trillion and comprises at least three institutions from three different subsec - tors.

The calculation of the total assets here described will (a) be based on the total asset value over six consecu - tive months, and (b) only cover the assets of financial services institutions (excluding pension funds) that are members of the financial conglomeration. The second threshold is the number (and types of) financial services institutions. The OJK has the dis - cretion to require the establishment of a PIKK even if these thresholds are not met, or to exempt a group that technically fulfils them. Concluding Remarks Indonesia’s fintech industry is entering a phase of stronger regulatory oversight and greater integration with the broader financial services sector. Regulators have shown a continued commitment to promote innovation while enhancing governance and con - sumer protection across the fintech industry. Looking ahead, Indonesia’s fintech industry is expect - ed to experience sustained growth supported by ongoing regulatory developments, strong consumer demand, and expansion of digital integration across sectors. Market players should proactively strength - en their compliance and governance to navigate this evolving industry.

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