Fintech 2025

INDONESIA Trends and Developments Contributed by: Vik Tang, Michelle Virgiany, Novita Wulandari and Fransiska Larasati, Hiswara Bunjamin & Tandjung

Lastly, considering the current economic situ - ation in Indonesia and the limited access to funding for the public not served by the non- P2P lending industry, through its press release on 31 December 2024 and letter to market players OJK announced revised maximum dai - ly economic benefit limits and updated some requirements under OJK Circular Letter No 19/ SEOJK.06/2023 on Implementation of Informa - tion Technology-Based Joint Funding Services (the “P2P Circular Letter” ). Effective from 1 January 2025, the maximum daily economic benefit limits for P2P lending platforms are categorised based on loan tenor while maintaining the differentiation between consumptive and productive funding. For consumptive funding, the limits are: • 0.3% per day for loans with tenors of six months or less; and • 0.2% per day for loans with tenors exceeding six months. For productive funding, the limits vary: • for micro and ultra micro businesses, the limit is 0.275% per day for tenors of six months or less, and 0.1% per day for tenors exceeding six months; and • for small and medium-sized businesses, the limit is 0.1% per day regardless of the tenor. Previously, the maximum economic benefit limits for consumptive funding were set only for short- term loans (less than 12 months), while the limits for productive funding did not take into account a borrower’s background. OJK now allows a higher maximum daily economic benefit limit for micro and ultra micro businesses – 0.175%

higher than the previous limit and higher than the current limit for small and medium businesses. BNPL The term BNPL has been around for quite some time, having been introduced as a subset of financing products in 2014. From 2019 to 2023, BNPL experienced significant growth, peak - ing in December 2023 when BNPL contracts dominated around 80% of financing contracts. Despite such growth, the total asset associated with BNPL made up only 2% of total assets of financing companies. In its 2024–28 Financ - ing Companies Roadmap, OJK opined that the BNPL portfolio was still very small and did not yet have a significant impact on the overall per - formance of the lending industry. Previously, none of the regulations applicable to financing companies provided a definitive set of provisions specifically for BNPL, but it is gener - ally understood that BNPL refers to a lending facility for the purchase of goods/services (with “deferred” payment mechanism for the borrow - er) that is carried out using an electronic system and without physical face-to-face interaction between the borrower and the lender. In December 2024, OJK issued Regulation No 46 of 2024 on Development and Strengthening of Financing Companies, Infrastructure Financ - ing Companies and Venture Capital Compa - nies ( “OJK Regulation 46” ). The new regula - tion amended various provisions applicable for financing companies, including OJK Regulation No 47 of 2020, which deals with licensing and institutional aspects, and OJK Regulation No 38 of 2018, which deals with business and opera - tions aspects. One of the updates under OJK Regulation 46 was the introduction of Digital Financing Ser -

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