INDONESIA Trends and Developments Contributed by: Vik Tang, Michelle Virgiany, Novita Wulandari and Fransiska Larasati, Hiswara Bunjamin & Tandjung
establish interconnectivity for the w-Digital Rupi - ah to facilitate complex cross-border transac - tions. Digital Financing The two main subsectors within digital financing that recorded significant growth in 2024 were P2P lending and Buy Now Pay Later (BNPL). As of November 2024, outstanding lending/financ - ing numbers were at an all-time high since 2021, respectively at IDR75.60 trillion (circa USD4.58 billion) for P2P lending and IDR501.37 trillion (circa USD30.39 billion) for BNPL. P2P lending P2P lending recorded a year-on-year increase of 27.32% in November 2024 with a stable TWP90 of 2.52% (the percentage of loan defaults and non-performing loans exceeding 90 days). Despite the growth, OJK maintained its mora - torium on the issuance of P2P lending licences, noting that the last licence was issued in Decem - ber 2021. OJK issued Regulation No 40 of 2024 on Infor - mation Technology-Based Joint Funding Ser - vices ( Layanan Pendanaan Bersama Berbasis Teknologi Informasi ) on 24 December 2024 (the “2024 P2P Regulation” ), revoking OJK Regu - lation No 10/POJK.05/2022 (the “2022 P2P Regulation” ). This was driven by the mandate under the Financial Services Omnibus Law and the need to both harmonise provisions with the ITE Law and strengthen regulations on various aspects, including maximum lending limits, credit scoring, transparency in write-offs, and monitoring mechanisms (among others). Some notable updates in the 2024 P2P Regula - tion are as follows.
• Capital and equity: a minimum paid-up capital requirement of IDR25 billion (circa USD1.52 million) and equity maintenance requirements have been introduced. Plat - forms licensed before the issuance of the 2024 P2P Regulation must gradually meet these thresholds by: (a) maintaining equity of at least IDR7.5 bil - lion (circa USD454,545) at the time the regulation came into effect (27 December 2024); and (b) achieving equity of at least IDR12.5 billion (circa USD757,575) by 4 July 2025, which is consistent with the deadline set under the 2022 P2P Regulation. • Ratio: P2P lending platforms must also ensure that their equity-to-paid-up capital ratio never falls below 50%, maintain a liquid - ity ratio of at least 120%, and not have a ratio of non-performing loans above 5%. Existing P2P lending companies have one year to comply with these requirements. • Investment: total direct investments by a P2P lending company cannot exceed 20% of its total equity, and direct investments in entities within the same group are capped at 10% of the P2P’s total equity. Such direct investment may only be made in companies operating in the financial services sector in Indonesia and/ or companies involved in P2P lending activi - ties. • Expanded permitted activities: P2P lend - ing platforms can now engage in additional activities, including acting as a distribution partner for government securities, collaborat - ing on informational services, and conducting other activities with prior approval from OJK. • Sharia operations: the regulation allows P2P lending platforms to operate both convention - al and Sharia activities within the same entity, with specific requirements for establishing Sharia Units.
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