Indonesia's 2026 Fintech Regulatory Landscape: Payments Overhaul, Foreign Capital Caps, and Strict Crypto Offerings

Indonesia—Southeast Asia's largest economy—has entered a phase of highly structured, mature, and rigorous regulatory oversight. Throughout late 2025 and early 2026, the two primary financial regulators, Bank Indonesia (BI) and the Financial Services Authority (OJK), have enacted sweeping overhauls across multiple fintech verticals. For US fintech companies evaluating expansion into Indonesia, these updates represent a critical shift from a lenient "sandbox" growth era to a highly prescriptive, bank-like compliance and governance model.

1. Sweeping Payments Overhaul: BI Reg 10/2025

On March 31, 2026, Bank Indonesia Regulation No. 10 of 2025 (BI Reg 10/2025) on the Regulation of the Payment System Industry came into force. This regulation completely redraws the payment system framework:

• Dynamic Classification (TIKMI): It replaces static Payment Service Provider (PJP) categories with a risk- and capability-based "TIKMI" assessment. TIKMI stands for Transaction (transaksi), Interconnection (interkoneksi), Competence (kompetensi), Risk management (manajemen risiko), and IT Infrastructure (infrastruktur teknologi informasi). BI will use these metrics to classify providers into "Primary PSPs" or "Other PSPs."
• Modular Bundling: Static licenses are replaced with modular "activity packages" (Bundled Activity 1, 2, and 3).
  • Bundled Activity 1 is the most comprehensive, covering payment account administration and issuance, and is strictly restricted to Primary PSPs.
• Mandatory Business Plans: All licensed companies must submit a three-year Strategic Business Plan (SBP) and a one-year Payment System Business Plan (RBSP) by April 30, 2026.
• Supporting Operator Registration: Supporting operators are classified as critical, important, or standard, with critical/important operators required to register with BI by March 31, 2029.

2. Financial Services Aggregators: OJK Reg 4/2025

Following the graduation of wealthtech, financing agents, and funding agents from the regulatory sandbox, the OJK issued Regulation No. 4 of 2025 on February 26, 2025, to establish a formal licensing framework:

• Paid-Up Capital: Aggregators must incorporate locally as a Perusahaan Terbatas (PT) with a minimum paid-up capital of IDR 500 million (which cannot be sourced from loans).
• Foreign Capital Cap: Direct and indirect foreign ownership is capped at 85% (excluding publicly listed entities). This is a vital baseline for US fintechs structuring local joint ventures.
• Fund Handling Ban: Aggregators are strictly prohibited from directly collecting or holding consumer funds; they may only forward them to a licensed payment service provider.
• Licensing Deadline: Existing registered aggregators had until February 21, 2026, to apply for a full license and must comply with the 85% foreign capital cap within one year of licensing.

3. Buy Now Pay Later (BNPL): OJK Reg 32/2025

Effective December 15, 2025, the OJK enacted Regulation No. 32 of 2025 to govern the explosive growth of BNPL:

• Prior Approval: Multi-finance companies must secure prior OJK approval before launching BNPL products.
• Transparency Requirements: Providers must disclose all funding sources, credit limits, and installment structures through electronic channels.
• Compliance Deadline: Existing BNPL providers have until June 15, 2026, to align their operations with the new rules.

4. Peer-to-Peer (P2P) Lending: OJK Circular Letter 19/2025

Issued on July 31, 2025, implementing OJK Regulation 40 of 2024, this circular establishes a highly prescriptive model aimed at retail investor protection:

• Lender Income-Based Segmentation:
  • Professional Lenders (annual gross income > IDR 500 million) can lend up to 20% of their income.
  • Non-professional Lenders (income <= IDR 500 million) can lend up to 10% of their income.
• Retail Funding Cap: Platforms must ensure that funding from non-professional retail lenders does not exceed 20% of total outstanding loans.
• Group Exposure Limits: The maximum funding limit of IDR 2 billion per borrower applies to related borrowers (group/affiliate exposure) to prevent circumvention of lending caps.
• Interest and Penalty Caps: Differentiated by loan type and tenor. Productive loans > IDR 50 million or with a tenor > 6 months are capped at 0.1% per day. Consumptive lending is capped at 0.3% per day (<= 6 months) or 0.2% per day (> 6 months). Combined interest and late penalties cannot exceed 100% of the original principal.

5. Digital Assets & Crypto: OJK Reg 23/2025 and Primary Issuance Guidelines

Oversight of digital assets officially transferred from Bappebti to the OJK on January 10, 2025. Under OJK Regulation No. 23 of 2025 (amending OJK Reg 27/2024):

• Expanded Scope: The concept of "Financial Digital Assets" now officially includes crypto-assets, digital financial assets, and their derivatives.
• Staking Licenses: Staking services are permitted, but traders must establish co-operation with the Ministry of Home Affairs to access national population data for AML/CFT verifications.
• Onshore Issuance (Draft Regulation): The OJK's draft regulation on the Public Offering of Digital Financial Assets (released September 2025, in finalization) mandates that:
  • Offerings of tokenized or backed crypto assets >= IDR 1 billion require local business licensing and OJK approval.
  • Strict Localization: Crypto/token issuers must incorporate locally as a PT and maintain a majority Indonesian board and key personnel domiciled locally. This represents a substantial operational barrier for foreign token issuers.

Verbatim Quotes

From Fintech 2026 - Indonesia - Chambers and Partners:

"On 24 December 2025, the Bank of Indonesia enacted Bank of Indonesia Regulation No 10 of 2025 on the Regulation of the Payment System Industry (BI Reg 10/2025)... This regulation will come into force on 31 March 2026."

"BI Reg 10/2025 introduces a risk-based and capability-based classification, thereby updating the framework previously established under Bank Indonesia Regulation No 22/23/PBI/2020 on Payment System... Bank Indonesia will determine the PSP classification on the basis of a criterion called "TIKMI"..."

"Following the successful completion of the regulatory sandbox phase for financial services aggregation activities... the OJK issued Regulation 4 of 2025 on 26 February 2025 ("OJK Regulation 4"). This regulation provides a licensing and supervisory framework for financial services aggregators... Paid‑up capital: Financial services aggregators must be established as Indonesian limited liability companies with minimum paid‑up capital of IDR500 million... Foreign ownership: The regulation permits direct and indirect foreign ownership of up to 85%, but this limit does not apply to publicly listed entities."

"On 31 July 2025, the OJK issued OJK Circular Letter 19/2025 on Implementation of Information Technology-based (P2P) Lending Services... [Non-professional lenders] may lend up to 10% of their annual income through a P2P lending platform. Importantly, platforms must ensure that funding from non‑professional lenders does not exceed 20% of the total outstanding loans, reinforcing the OJK's focus on retail investor protection."

"Corporate Structure: All market participants (including issuers) must be locally incorporated as a limited liability company... The Draft Regulation specifies that issuers must maintain a majority Indonesian board and key personnel domiciled locally. As the regulation requires local incorporation and Indonesian directors for issuers, this means foreign issuers may participate only through local entities or partnerships that meet these requirements."