A New Chapter in Indonesia’s Payment System Regulatory Framework: What It Means for Businesses

Fintech & PDP
Written By ARMA Admin
 

Authors

Authors
Filza Adwani
Filza Adwani

Of Counsel

Ninda Maghfira
Ninda Maghfira

Associate

As Indonesia approached the final phase of the Indonesia Payment System Blueprint 2025, Bank Indonesia (“BI”) introduced the Indonesia Payment System Blueprint 2030 (“BSPI 2030”) in 2024. BSPI 2030 sets out BI’s roadmap to build a resilient and consolidated payment system, safeguard the central bank’s core functions, and promote financial inclusion. One of its main pillars is the industry initiative, aimed at creating a more consolidated industry structure through risk-based access and entry requirements, enhanced risk management standards, and regulatory reforms.

As an initial step in this regulatory reform, towards the end of 2025 BI issued BI Regulation No. 10 of 2025 concerning Regulation of the Payment System Industry (“PBI 10/2025”) together with its implementing regulation, that is Regulation of the Board of Governors Members No. 32 of 2025 concerning Regulation of the Payment System Industry (“PADG 32/2025”) (collectively, the “Payment System Regulations”), revoking PBI No. 22/23/PBI/2020 and PADG No. 24/7/PADG/2022. Other relevant regulations, such as PBI No. 23/6/PBI/2021, remain in force to the extent they do not conflict with the new framework.

Effective from 31 March 2026, the Payment System Regulations form the primary regulatory framework for payment system market players and introduce significant changes to the regulatory landscape. This ARMA Update outlines the key new provisions, while also briefly noting which requirements under the previous regime remain applicable and how the transition to the new framework will be implemented.

Regulated Parties

Previously, BI regulated only Payment Service Providers (Penyedia Jasa Pembayaran - “PJP”) and Payment Infrastructure Providers (Penyelenggara Infrastruktur Sistem Pembayaran - “PIP”) in the payment industry. The Payment System Regulations now expand the scope of regulated payment system industry players to include BI, Payment System Service Provider (Penyelenggara Jasa Sistem Pembayaran - “PSP”), and Supporting Service Providers. Within the PSP category, BI includes PJP and PIP thereunder, together with commercial banks, which are included as PSP as they carry out fund transfer activities pursuant to the Fund Transfer Law. 1

BI also regulates the capacity of the aforementioned payment system industry players to have access as: (i) Participants (Peserta) to the payment system infrastructure; and (ii) Connected Parties (Pihak Terhubung) to the payment system data infrastructure provider. Other parties related to payment system industry, such as Self-Regulatory Organization (“SRO”), parties cooperating with PSP and Participants, and parties affiliated with PSP, are also regulated. 2

TIKMI: Introduction of New Parameters for Market Players

One of the newly introduced concepts is TIKMI, which stands for Transaction, Interconnection, Competency, Risk Management, and Information Technology Infrastructure criteria. 3 TIKMI serves as a set of reference criteria in the operation of payment systems for the purposes of performance assessment and the classification of PSPs. 4

TIKMI compliance is assessed through PSP self-assessments, which must be conducted periodically and submitted to BI, followed by BI’s evaluation. Based on the prescribed methodology, variables, indicators, mechanisms, and thresholds, BI determines the final TIKMI assessment results for each PSP. 5 Further technical guideline for such TIKMI assessment shall be stipulated in a separate technical guideline as published by BI. 6

The timeline for such TIKMI assessment shall be as follows:

Agenda PSP Timeline
Transitional Period
First TIKMI Assessment Result 7 Primary PSP and Non-Primary PSP No later than 1 April 2027
Regular Period
Submission of TIKMI Self-Assessment 8 Primary PSP No later than each 1 February (for July-December previous year) and 1 August (for January-June ongoing year)
Non-Primary PSP No later than 1 February (for January-December previous year)
BI Assessment Period 9 Primary PSP At least once every six months
Non-Primary PSP At least once every six months for transaction and interconnection criteria;

At least once annually or no later than once in every three years for competence, risk management, and IT infrastructure criteria
Announcement of TIKMI Assessment Result by BI 10 Primary PSP Every March and September
Non-Primary PSP No later than September

Failure to submit TIKMI self-assessment according to the stipulated timeline may be subject to administrative sanctions by BI.

Classification of PSP

Given the above use of TIKMI, one of its key applications is in classifying PSPs. Consistent with BI’s focus on shaping the payment system industry based on the risk profiles of market participants, BI classifies PSPs into two categories: Primary PSPs or PSPs other than Primary PSPs (“Non-Primary PSP”). 11

A PSP is classified as a Primary PSP if, due to its size, interconnectedness, and complexity within the payment system or the financial system, a disruption or failure of such PSP may cause a partial or total failure of the payment system or the financial system, whether operationally or financially. 12 The assessment therefor shall be based on TIKMI and/or other criteria, amongst others size, interconnectedness, complexity, and substitutability (SICS). 13

Result of the PSP classification assessment shall be delivered to the relevant PSP, of which the first delivery shall be announced no later than 1 year after the PBI 10/2025 is enacted. 14

New Licensing Concept: Activity Bundling

Unlike the previous regulatory regime, which used category-based licensing, BI now applies an activity-bundling approach for PJP, where the applicable licence is determined based on the specific combination of activities undertaken, as set out below:

Activity 1 Bundling
Scope of Activities 15 a. Administration of funds, including:
  • (i) administration of payment account; and
  • (ii) issuance of and/or provision of access to sources of funds.
b. Payment transaction forwarding, including:
  • (i) forwarding of payment transaction data and payment instructions, which may be accompanied by facilitation of the receipt of payment funds through the provision of sub-accounts to merchants and/or service providers; and
  • (ii) forwarding of fund transfer instructions, whether digitally or non-digitally.
Classification 16 Activity 1A Bundling: May only be conducted by PJPs classified as Primary PSPs.
Activity 1B Bundling: May only be conducted by PJPs classified as PSPs other than Primary PSPs.
Initial Capital 17 IDR 15 billion (regardless of the classification)
Activity 2 Bundling
Scope of Activities 18
  • a. Forwarding of payment transaction data and payment instructions, which may be accompanied by facilitation of the receipt of payment funds; and
  • b. Forwarding of fund transfer instructions, whether digitally or non-digitally.
Initial Capital 19 IDR 5 billion
Activity 3 Bundling
Scope of Activities 20 Forwarding of fund transfer instructions non-digitally.
Initial Capital 21 IDR 1 billion
For providing a system usable by other Activity 3 Bundling PJPs.
IDR 500 million
For those that do not provide such a system.
Exemption 22 The requirement of license for Activity 3 Bundling shall be exempted for:
  • Commercial banks
  • Rural banks (Bank Perkreditan Rakyat)

In addition to the initial capital as the above, PSPs shall also comply with the applicable ongoing capital, of which the amount shall be determined based on the assessment result to the Transaction and Interconnection aspects. 23 Furthermore, under the Payment System Regulations, changes to a PJP’s bundling, whether an upgrade or downgrade, may be made through an approval mechanism rather than a full licensing process. 24

Lastly, as BI places greater emphasis on risk management and individual risk profiles, the regulatory focus is no longer limited to the types of activities conducted, but equally on whether a business player meets the applicable TIKMI requirements for each activity bundling, which PSPs are required to satisfy in accordance with their approved bundling. 25

Reclassification of Existing PSP Licenses

Upon the entry into force of the Payment System Regulations, any PSP that has previously obtained a PJP licence or PIP determination shall continue to be recognised as a PJP or PIP, as applicable. 26 For such PSPs, BI will evaluate (i) the activities conducted by PJP and PIP and (ii) their classifications, as the basis for adjusting activity bundling and PSP classification, taking into account licensing or designation requirements and TIKMI assessment results. 27

Based on this evaluation, BI will: (i) align pre-existing PJP licences and PIP determinations with the new activity bundling as discussed above; and (ii) reclassify previously designated systemic, critical, or general PJPs into the new PSP classification of Primary PSP and Non-Primary PSP. Such results will be notified in writing no later than 1 April 2027. 28

Business Plan as Basis for Payment System Activities

Under the current Payment System Regulations, new mandatory compliance documents are introduced, requiring PSPs to prepare:

  1. Strategic Business Plan (“SBP”), which refers to a written document outlining the business activities and strategic development plans in the payment system sector for 3-years period; 29 and
  2. Payment System Business Plan (Rencana Bisnis Sistem Pembayaran – “RBSP”), which is a written document setting out a one-year payment system business and development plan, the implementation strategies, and the realization of the previous year’s plans. 30

Each SBP and RBSP must be submitted to BI periodically: the SBP every three years and the RBSP annually, no later than 30 November, of which the latter is subject to BI’s approval process. 31 Once submitted and approved, each SBP and RBSP shall serve as the guiding framework for the relevant PSP’s payment system operations during the applicable period. 32 Therefore, PSPs are advised to carefully prepare their SBP and RBSP, as BI allows revisions only once per year. 33

PSPs must submit the SBP and RBSP for the first time no later than 30 April 2026. 34 Therefore, specifically for 2026, given that the regulations have only recently come into effect, PSPs should expect two rounds of submissions within the year: (i) the first submission by no later than 30 April 2026, and (ii) the submission of the RBSP for 2027 by no later than 30 November 2026.

Further technical guideline regarding the preparation and submission of SBP and RBSP will be issued by BI in the technical guidelines. 35

Activity Development, Product Development, and/or Cooperation

As the RBSP serves as the basis for the commencement of payment system business activities, BI requires PSPs to include plans for activity development, product development, and/or cooperation in their RBSP. 36 Accordingly, approval for such plans shall be granted concurrently with the approval of the RBSP. 37 However, should such approval have not been granted by BI, PSPs are required to submit an application for approval of its development plans for each activity, product, and/or cooperation. 39

Approval of each development plan shall be subject to BI’s consideration based on the classification of the development. Compared to the previous regime, under which activity development, product development, and/or cooperation were classified based on risk levels ranging from low to high, BI now classifies them into two categories:

Complex Development 40
SUBJECT TO BI APPROVAL 41

Developments impacting payment transaction processing that include:

  1. Development of activities, Sources of Funds 42, and access to Sources of Funds;
  2. Changes to the payment system’s system and/or infrastructure with new hardware and/or software;
  3. Development involving cooperation with foreign parties (non-Indonesian citizens/legal entities); and/or
  4. Other developments determined by BI (e.g., cooperation with digital financial asset traders or Digital Financial Services).
Standard Development 43
SUBJECT TO REPORTING TO BI 44

Development of activities and products which:

  1. Impact pre-transaction and post-transaction activities;
  2. Impact payment processing stages but do not involve new hardware/software; and/or
  3. Impact payment processing stages but follow a business model previously approved by BI.

In granting any approval, BI shall use the TIKMI assessment results as its primary consideration. In this regard, the assessment results, as well as any applicable bundling, will affect the approval process, which shall proceed as follows:

TIKMI Status Category Regulatory Requirement & Development Permissions
TIKMI ≥ Threshold 1A Permissive Framework: Conduct activity/product development and cooperation based on the approved RBSP plan.

✔ Requirement: Only required to provide a realization report to BI.
1B, 2, 3 45 Transitional Framework (Until 1 April 2029): Requires BI approval for RBSP plus separate approval for each specific development/cooperation.

Post-Transitional (After 1 April 2029): If TIKMI stays ≥ Threshold, may proceed based solely on the approved RBSP.

✔ Requirement: Realization report is mandatory.
TIKMI < Threshold 1A 46 Approval-Heavy Framework: Must obtain BI’s approval for RBSP and separate approval for each activity development, product development, and/or cooperation.

✔ Requirement: Realization report is mandatory.
1B, 2, 3 47 Restrictive Framework: Development/cooperation permitted only for:
• Follow-up supervisory actions;
• Enhancing security standards/IT infrastructure; and/or
• Implementing BI policies.

Note: Must obtain BI approval for each instance. Realization report is mandatory.

In the transitionary period where TIKMI result has yet to be announced to the relevant PSPs, PSPs are still able to apply for approval for activity development, product development, and/or cooperation, of which BI shall assess it based on fulfilment of minimum requirements as stipulated by BI. 48

Participation on Payment System InfrastructureParticipation on Payment System Infrastructure

The activity of payment system infrastructure shall consist of clearing and/or settlement activities. 49 Under the Payment System Regulations, BI now specifically regulates participation in payment system infrastructure, distinguishing between BI-operated infrastructures and industry-operated payment system infrastructures, as follows:

Operator Infrastructure Permitted Participants
BI BI-FAST 50 1. BI;
2. PSP; and/or
3. other parties as approved or designated by BI
BI-RTGS 51 1. BI; and/or
2. PSP
SKNBI 52
Industry Fast payment infrastructure and any other infrastructures 53 PSP

It is important to be highlighted that the determination of PSP’s participation access to each of the above infrastructure shall also depend on the fulfilment of TIKMI threshold. 54

Regulatory Compliances for Supporting Service ProvidersRegulatory Compliances for Supporting Service Providers

Considering the importance of supporting service providers in the payment industry, BI has expanded its regulatory framework to cover them under the following categories:

Category Criteria/Permitted Activities
Critical Supporting Service Providers Providing supporting services to Primary PSP, and/or Non-Primary PSP 55
Important Supporting Service Providers Providing supporting services to Non-Primary PSP 56
Note: For the above categories, the services shall be at the stages of payment transaction processing, including initiation, authorization, clearing, and final settlement. 57 Whether the relevant providers is critical or important, it shall depend on BI’s assessment on the service’s criticality and scope. 58
Standard Supporting Service Providers Providing supporting services for pre-transaction and post-transaction activities 59

If a Supporting Service Provider is classified as critical or important, it must be registered with BI (or other BI-appointed party), with the registration submitted by the Supporting Service Provider and/or the cooperating PSP. 60 Such registration must be completed no later than 1 April 2029. 61 This registration is significant, as BI requires PSPs and Participants to cooperate only with critical or important Supporting Service Providers that have been registered. 62

In addition to the aforementioned registration, cooperation agreements with Supporting Service Providers now must also comply with the minimum requirements of provisions as stipulated by BI. 63

Transitional Timeline

To sum up, the following is the timeline during the transitional period of implementation of the Payment Systems Regulations:

Agenda Timeline and/or Deadline
PSPs/Supporting Services Provider Obligation
Submission of First SBP and RBSP 64 31 March – 30 April 2026
Submission of RBSP for 2027 30 November 2026
Registration of Critical or Important Supporting Services Provider 65

Submission of data and information on PSP–Supporting Service Provider cooperation, assessment of readiness to meet Supporting Service Provider registration requirements, and preparation of institutional and registration mechanisms for unregistered Supporting Service Providers 67 		No later than 1 April 2029 66
Fulfilment of licensing requirements and/or TIKMI assessment result, for PSPs which failed to fulfil the licensing requirements and/or TIKMI 68

Extension of the aforementioned fulfilment of licensing requirements and/or TIKMI with certain considerations 69 		No later than 1 April 2031
Action by BI
Stipulation of first TIKMI assessment result by BI 70

Stipulation of PSP classification 71

Announcement of evaluation for PSP license reclassification 72 		31 March 2026 – 1 April 2027
(phased implementation)
Implementation of registration and phased publication of the list of critical and important Supporting Service Providers 73 31 March 2026 – 1 April 2029

PSPs should closely adhere to the above timelines to avoid the risk of administrative sanctions from BI. PSPs are also encouraged to proactively monitor BI’s updates on the implementation of the Payment System Regulations, including any further technical guidance and any coaching clinics organised by BI.

  1. Article 1 (7) and 7 of PBI 10/2025 ↩
  2. Article 79 paragraph (3) of PADG 32/2025 ↩
  3. Article 22 of PBI 10/2025 ↩
  4. Article 63 paragraph (1) of PADG 32/2025 ↩
  5. Article 67 paragraph (1) juncto Article 65 paragraph (1) of PADG 32/2025 ↩
  6. Article 70 of PADG 32/2025 ↩
  7. Article 236 of PADG 32/2025 ↩
  8. Article 67 paragraph (5) of PADG 32/2025 ↩
  9. Article 67 paragraph (2) of PADG 32/2025 ↩
  10. Article 67 paragraph (8) of PADG 32/2025 ↩
  11. Article 80 paragraph (1) of PADG 32/2025 ↩
  12. Elucidation of Article 80 paragraph (1) of PADG 32/2025 ↩
  13. Elucidation of Article 80 paragraph (2) of PADG 32/2025 ↩
  14. Article 80 paragraph (3) and (4) of PADG 32/2025 ↩
  15. Article 34 paragraph (3) of PBI 10/2025 ↩
  16. Article 35 paragraphs (1) and (2) of PBI 10/2025 ↩
  17. Article 102 paragraph (1) point b of PADG 32/2025 ↩
  18. Article 34 paragraph (4) of PBI 10/2025 ↩
  19. Article 102 paragraph (1) point b of PADG 32/2025 ↩
  20. Article 34 paragraph (5) of PBI 10/2025 ↩
  21. Article 102 paragraph (1) point b of PADG 32/2025 ↩
  22. Article 88 paragraph (5) of PADG 32/2025 ↩
  23. Article 162 paragraph (1) point b of PADG 32/2025 ↩
  24. Article 86 paragraph (2) of PADG 32/2025 ↩
  25. Article 24 of PBI 10/2025 ↩
  26. Article 179 point a of PBI 10/2025 ↩
  27. Article 176 paragraph (1) of PBI 10/2025 ↩
  28. Article 176 paragraphs (2) and (3) of PBI 10/2025. Note: Although a time frame of 1 (one) year or 3 (three) years after 31 March 2026 would, in principle, fall on 31 March 2027 or 31 March 2029, Bank Indonesia’s TIKMI timeline applies a deadline of 1 April in the relevant year. This approach is also reflected in Bank Indonesia’s dissemination materials, which consistently use 1 April, rather than 31 March, as the applicable deadline. Thus, we have aligned it accordingly. ↩
  29. Article 28 juncto Article 1 point 17 of PBI 10/2025; Article 71 paragraph (3) of PADG 32/2025 ↩
  30. Article 28 juncto Article 1 point 18 of PBI 10/2025; Article 71 paragraph (4) of PADG 32/2025 ↩
  31. Article 72 paragraph (1) and Article 73 paragraph (1) and (3) of PADG 32/2025 ↩
  32. Article 77 of PADG 32/2025 ↩
  33. Article 72 paragraph (6) and Article 73 paragraph (11) of PADG 32/2025 ↩
  34. Article 74 paragraph (1) of PADG 32/2025 ↩
  35. Article 78 of PADG 32/2025 ↩
  36. Article 118 paragraphs (1) and (2) of PADG 32/2025 ↩
  37. Article 118 paragraph (2) and (3) of PADG 32/2025 ↩
  38. Article 118 paragraph (8) of PADG 32/2025 ↩
  39. Article 124 paragraph (1) of PADG 32/2025 ↩
  40. Article 124 paragraph (2) of PADG 32/2025 ↩
  41. Article 125 point a of PADG 32/2025 ↩
  42. Sources of Funds refers to sources of funds used to fulfil obligations in payment transactions and administered in a payment account, consisting of deposits, monetary value in electronic money, and deferred payment (Article 9 paragraph 2 of PADG 32/2025) ↩
  43. Article 124 paragraph (3) of PADG 32/2025 ↩
  44. Article 125 point b of PADG 32/2025 ↩
  45. Article 119 of PADG 32/2025 ↩
  46. Article 120 paragraph (1) of PADG 32/2025 ↩
  47. Article 120 paragraph (2) of PADG 32/2025 ↩
  48. Article 118 paragraph (5) of PADG 32/2025 ↩
  49. Article 10 paragraph (7) of PBI 10/2025 ↩
  50. Article 115 paragraph (2) point a of PADG 32/2025 ↩
  51. Article 115 paragraph (2) point b of PADG 32/2025 ↩
  52. Article 115 paragraph (2) point c of PADG 32/2025 ↩
  53. Article 116 of PADG 32/2025 ↩
  54. Article 64 paragraph (2) point f and Article 65 paragraph (3) point b of PADG 32/2025 ↩
  55. Elucidation of Article 65 paragraph (2) point a of PBI 10/2025 ↩
  56. Elucidation of Article 65 paragraph (2) point b of PBI 10/2025 ↩
  57. Article 65 paragraph (5) of PBI 10/2025 ↩
  58. Article 65 paragraph (3) of PBI 10/2025; Article 150 paragraph (3) of PADG 32/2025 ↩
  59. Article 65 paragraph (6) of PBI 10/2025 ↩
  60. Article 152 paragraph (4) of PADG 32/2025 ↩
  61. Article 153 paragraph (2) of PADG 32/2025. Note: Although a time frame of 1 (one) year or 3 (three) years after 31 March 2026 would, in principle, fall on 31 March 2027 or 31 March 2029, Bank Indonesia’s TIKMI timeline applies a deadline of 1 April in the relevant year. This approach is also reflected in Bank Indonesia’s dissemination materials, which consistently use 1 April, rather than 31 March, as the applicable deadline. Thus, we have aligned it accordingly. ↩
  62. Article 68 of PBI 10/2025 ↩
  63. Article 70 juncto Article 58 paragraph (3) of PBI 10/2025 ↩
  64. Article 74 paragraph (1) of PADG 32/2025 ↩
  65. Article 153 paragraph (2) of PADG 32/2025 ↩
  66. It should be noted that while the Payment System Regulations generally stipulate certain timelines as one or three years from their entry into force on 31 March, BI has explicitly indicated that at least one deadline calculated as one year from enactment falls on 1 April (see Article 26 of PBI 10/2025 and Article 236 of PADG 32/2025). This approach is also reflected in BI’s dissemination materials, which consistently refer to certain deadlines as falling on 1 April. ↩
  67. Article 153 paragraph (3) point a of PADG 32/2025 ↩
  68. Article 177 paragraph (1) of PBI 10/2025 ↩
  69. Article 177 paragraph (2) of PBI 10/2025 ↩
  70. Article 236 of PADG 32/2025 ↩
  71. Article 80 paragraph (3) of PADG 32/2025 ↩
  72. Article 176 paragraph (3) of PBI 10/2025 ↩
  73. Article 153 paragraph (3) point b of PADG 32/2025 ↩

Disclaimer:
This client update is the property of ARMA Law and intended for providing general information and should not be treated as legal advice, nor shall it be relied upon by any party for any circumstance. ARMA Law has no intention to provide a specific legal advice with regard to this client update.

 
 

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