Financial Aggregator Business in Indonesia Now Regulated

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In Indonesia, consumers can access many types of financial products and services ranging from savings products that help collect funds to loan products that distribute funds. Usually, each financial institution markets its products separately, highlighting their own benefits. To help consumers easily compare these different options and match them with their personal risk preferences, financial aggregator businesses have emerged.

Previously, under the digital financial innovation regime, aggregators were classified as a specific cluster for financial product comparison and required to be recorded and/or registered with the Financial Services Authority (Otoritas Jasa Keuangan – “OJK”). However, with the issuance of OJK Regulation No. 4 of 2025 on Financial Services Aggregation Operators (“OJK Reg 4/2025”), the regulatory framework has shifted. OJK now consolidated four business types which were previously independent: aggregator, financing agent, funding agent, and wealth tech, into a single category known as Financial Services Aggregation Operator (Penyelenggara Agregasi Jasa Keuangan – “PAJK”). A specific PAJK license is now mandatory for businesses operating in this sector.

This ARMA Update will further discuss whether your aggregation business is subject to the mandatory business license requirement as a PAJK under OJK Reg 4/2025, as well as the regulatory obligations applicable to a PAJK.

Is Your Business Subject to Aggregator Licensing Rules?

Business parties engaging in the activities of collecting, filtering, and/or comparing information on product and/or financial services amongst financial services institutions (Lembaga Jasa Keuangan or “LJK”) and/or parties engaging in activities in financial services sector (“Aggregation”) in Indonesia are mandated to obtain license as PAJK from the OJK.

The scope of Aggregation activity itself includes the following: ¹

1. Displaying information on financial services products and/or services and providing options to consumers; and/or

2. Providing services in the form of:

   1. forwarding prospective consumer information to LJK and/or parties conducting activities in the financial services sector (i.e. providing data and/or information on qualified potential consumer data to LJK and/or parties engaging in activities in financial services sector based on eligibility, interest, or profile suitability);
   2. distributing financial services products and/or services to consumers; and/or
   3. administering documents related to financial services products and/or services for the benefit of consumers and Financial Services Institutions or other parties conducting activities in the financial services sector.

In addition to its core functions, PAJK may also offer special products and/or services in partnership with LJK and/or financial sector entities. Such products and/or services refer to collaboration between both parties to provide added value to consumers, as well as through co-branded products. ²

Other types of businesses, including: (i) providing products and/or services involving reciprocal process between PAJK, LJK, consumers, and other third parties; and (ii) aggregation of bill payment services, may also be conducted by PAJK, provided that it has obtained prior approval from the OJK. ³

As for the scope of products and/or services covered under the Aggregation activity, it includes:

1. fundraising activities;
2. fund distribution activities; and/or
3. other financial products and services approved by the OJK, beyond those previously mentioned. In the case of such other products and/or services that require a specific license and/or approval from other sectoral authorities, compliance with those requirements is mandatory.

These products and/or services must be limited to those offered by LJK and/or parties conducting activities within the financial services sector. ⁵

Exempted Aggregation Activities: When Is a License Not Required?

Certain businesses conducting Aggregation activities may be exempted from the obligation to obtain an PAJK license if their Aggregation fulfils any of the following criteria: ⁶

1. the Aggregation activity is carried out to support the main business activities;
2. it is performed internally within the company and its corporate group;
3. the party conducting the activity is already supervised by the OJK in another financial services sector;
4. the activity is limited to one-way information delivery without processing consumer data for the Aggregation purposes; or
5. the activity is not intended for marketing or distributing financial service institution products and/or services, or those of other parties engaged in the financial services sector.

Foundational Requirements for PAJK

The primary requirements to obtain a PAJK business license from the OJK include the following:

Requirement	Details
Type of Legal Entity	Limited liability company (perseroan terbatas) 7
Paid-up Capital	Minimum IDR 500 million 8 Or as otherwise stipulated by the OJK at its sole discretion 9
Types of Shareholders 10	Indonesian citizens Indonesian legal entities Foreign citizens Foreign legal entities
Restriction on Foreign Ownership	Maximum 85% of issued capital, either directly or indirectly, unless shareholding is through the capital market 11
Management Composition	Minimum of:12 2 (two) board of directors 1 (one) board of commissioners For the board of directors: At least one director must have knowledge and/or experience in Aggregation, IT, and/or LJK, proven by certification or at least three years of relevant experience May only hold concurrent positions in non-profit companies, organizations, or institutions

Dos and Don’ts’s

In carrying out Aggregation activities, a PAJK is required to: ¹³

1. Enter into a cooperation with LJK and/or parties conducting activities in the financial services sector and be liable for every action related to the Aggregation in accordance with the cooperation agreement. Such cooperation must involve more than 1 (one) LJK and/or party conducting activities in the financial services sector within the same line of business.
2. Disclose to the consumers that PAJK only provides Aggregation services and is not responsible for the underlying financial products and/or services offered by LJK and/or parties conducting activities in the financial services sector;
3. Provide access to the OJK to supervise the Aggregation activities of the PAJK;
4. Register itself as electronic system operator to the Ministry of Communications and Digital Affairs; ¹⁴
5. Establish and maintain its data center and disaster recovery center within the territory of the Republic of Indonesia; ¹⁵
6. Ensure the reliability and security of the electronic system used by PAJK in accordance with the prevailing laws and regulations; and
7. Cooperate with more than 1 (one) LJK and/or parties conducting activities in the financial services sector.

On the other hand, PAJKs are prohibited from: ¹⁶

1. Conducting activities related to fund collection, distribution, storage, and/or management of consumer funds, except for the receipt and forwarding of transactions to partners through payment service providers;
2. Engaging in unfair business competition as regulated under laws on anti-monopoly and unfair competition;
3. Providing Aggregation services through user-generated content platforms or content duplication without cooperation with LJK and/or other financial service providers;
4. Making false or exaggerated claims regarding financial products offered by LJK and/or financial service providers through PAJK;
5. Guaranteeing or promising investment returns and/or specific benefits from financial products of LJK and/or parties conducting activities in the financial services sector through PAJK;
6. Accepting authority to conduct transactions on behalf of consumers; and
7. Illegally disclosing and/or misusing consumers’ personal data or other data.

Transitional Provisions

Under the previous digital financial innovation framework set by OJK, Aggregation-related businesses were categorized into several different clusters, namely aggregators, financing agents, funding agents, and wealth tech. As a result, many businesses had either completed the sandbox process or were in the process of entering the sandbox or were in the process of being registered with OJK under these categories.

With the enactment of OJK Regulation No. 4 of 2025, which consolidates all such clusters under a single category of Aggregators, businesses that had previously passed the regulatory sandbox and registered with OJK as aggregators, financing agents, funding agents, or wealthtech are now required to obtain a PAJK business license no later than 26 February 2026. However, businesses conducting Aggregation business with specific existing conditions are subject to special provisions in addition to the mandatory license application, as outlined below.

Status Quo	Mandatory Follow-Up Actions / Exemptions
In the process of registering and has yet to obtain any certificate of registration.	Continue registration process, and remain mandatory to apply for PAJK business license no later than 26 February 2026.
Obtained certificate of registration before the enactment of OJK Reg 4/2025.	Exempted from provisions regarding shares ownership composition by foreign individuals and/or legal entities. However, such entities must comply with the maximum shareholding limit within no later than 1 (one) year after obtaining the business license.
Registered or in the process of registration and conducting Aggregation: (i) solely for internal purposes of the company and its group of companies; and (ii) limited to one-way information delivery and does not involve the processing of consumer data for the purpose of conducting Aggregation.	Adjust its business activities to be in accordance with OJK Reg 4/2025 no later than 26 February 2026.

Concluding Remarks

The issuance of OJK Reg 4/2025 represents a major regulatory shift for Aggregation businesses in Indonesia. By consolidating various business models into a single PAJK regime, OJK aims to provide clearer oversight and strengthen consumer protection. Businesses engaged in Aggregation activities should promptly assess whether they fall under the new licensing requirement and begin preparing for compliance ahead of the 26 February 2026 deadline to ensure uninterrupted operations. Please feel free to reach out to us should you require any assistance or advice in navigating these new requirements.

1. Article 3 (1) of OJK Reg 4/2025 ↩
2. Article 3 (2) of OJK Reg 4/2025 ↩
3. Article 3 (3) of OJK Reg 4/2025 ↩
4. Article 3 (7) of OJK Reg 4/2025 ↩
5. Article 3 (5) of OJK Reg 4/2025 ↩
6. Article 3 (4) of OJK Reg 4/2025 ↩
7. Article 4 (2) of OJK Reg 4/2025 ↩
8. Article 4 (3) of OJK Reg 4/2025 ↩
9. Article 4 (4) of OJK Reg 4/2025 ↩
10. Article 5 (1) of OJK Reg 4/2025 ↩
11. Article 5 (2) and (4) of OJK Reg 4/2025 ↩
12. Article 6 (1) of OJK Reg 4/2025 ↩
13. Articles 28 and 29 of OJK Reg 4/2025 ↩
14. Article 12 of OJK Reg 4/2025 ↩
15. Article 25 (5) of OJK Reg 4/2025 ↩
16. Article 32 of OJK Reg 4/2025 ↩

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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.

Go to

1. Is Your Business Subject to Aggregator Licensing Rules?
2. Exempted Aggregation Activities: When Is a License Not Required?
3. Foundational Requirements for PAJK
4. Dos and Don’ts’s
5. Transitional Provisions
6. Concluding Remarks

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