“More fundamentally, the shift may no longer be about licensing classifications alone, but how payment activities operate within a business ecosystem.”
Indonesia’s payment regulatory landscape is shifting toward a more activity based and supervisory driven framework under Bank Indonesia through Bank Indonesia Regulation No. 10 of 2025 (“PBI 10/2025”). The framework increasingly focuses on how payment activities, operational arrangements, and business ecosystems are implemented in practice.
For businesses exploring Indonesia’s payment sector, regulatory considerations may increasingly extend beyond licensing requirements toward how the overall business model fits within the evolving payment system framework.
The Shift Toward Activity Based Assessment
For Payment Service Provider (“PSP”), one of the key developments introduced under PBI 10/2025 is the implementation of “Activity Bundling,” which categorizes payment activities based on the nature of the services being conducted. Broadly, the framework distinguishes activities involving:
- Administration of fund sources;
- Forwarding payment transaction instructions; and
- Fund transfer related activities.
The framework further introduces Activity Bundling 1, Activity Bundling 2, and Activity Bundling 3 classifications for PSP activities, each carrying different operational scopes and regulatory implications. At a high level, the framework may appear to be a restructuring of licensing classifications. More fundamentally, however, it reflects a broader shift toward assessing how payment activities operate within a business ecosystem. The activity bundling for Payment Service Providers is set out below:
- Activity Bundling 1, consisting of:
a. Administration of fund sources, which includes:
- administration of payment accounts; and
- issuance of and/or provision of access to sources of funds.
b. Payment transaction processing, which includes:
- forwarding of payment transaction data and payment instructions, which may be accompanied by the facilitation of the receipt of payment proceeds through the provision of sub-accounts to goods and/or services providers; and
- forwarding of fund transfer instructions through digital and non-digital means.
Activity Bundling 1 is further divided into Bundling 1A (available only to Main PSPs) and Bundling 1B (also available to PSPs other than Main PSPs).
- Activity Bundling 2, consisting of payment transaction processing activities, including:
a. forwarding of payment transaction data and payment instructions, which may be accompanied by the facilitation of the receipt of payment proceeds; and
b. forwarding of fund transfer instructions through digital and non-digital means.
- Activity Bundling 3, consisting of payment transaction processing activities, namely the forwarding of fund transfer instructions through non-digital means.
As a result, businesses with similar commercial offerings may face different regulatory considerations depending on:
- Transaction flow arrangements;
- Allocation of responsibilities within the ecosystem; and
- Integration of payment functionalities into broader services.
Increasingly, the regulatory focus may extend beyond the applicable license itself toward the substance of the payment activities being conducted.
Minimum Paid-Up Capital
As one of the mandatory requirements that must be fulfilled, PBI 10/2025 and PADG 32/2025 also stipulate the minimum paid-up capital requirements applicable to PSPs, as follows:
- Activity Bundling 1: at least IDR 15,000,000,000 (fifteen billion Rupiah).
- Activity Bundling 2: at least IDR 5,000,000,000 (five billion Rupiah)
- Activity Bundling 3:
- at least Rp1,000,000,000 (one billion Rupiah) for PSPs under Activity Bundling 3 that provide a system that may be used by other PSPs under Activity Bundling 3; and
- at least Rp500,000,000 (five hundred million Rupiah) for PSPs under Activity Bundling 3 that do not provide a system that may be used by other PSPs under Activity Bundling 3.
TIKMI and Supervisory Assessment
Another notable development under the new framework is the introduction of TIKMI, which assesses:
- Transactions;
- Interconnection;
- Competence;
- Risk Management; and
- Information Technology Infrastructure.
Under PBI 10/2025, TIKMI forms part of a broader supervisory framework used in connection with licensing, classification, approvals, access to participation, implementation, supervision, and operational assessment, including termination of the implementation of PSPs.
Prior to the assessment conducted by Bank Indonesia, the PSP is required to conduct a self-assessment and inform Bank Indonesia of its fulfilment of the TIKMI requirements. The self-assessment serves as part of the PSP’s responsibility and internal oversight mechanism and does not replace or limit Bank Indonesia’s authority to independently conduct its assessment and determine the final TIKMI assessment report.
Specifically, Regulation of the Members of the Board of Governors No. 32 of 2025 (“PADG 32/2025”) stated the use of TIKMI shall be implemented by the Bank Indonesia in the following terms:
- Requirements for licensing as PSP’s, as well as the basis for evaluating licensing as PSP’s;
- Basis for determining the classification of PSP, as PBI 10/2025 introduces the PSP into two categories, namely the Main PSP (PSP Utama) and PSP other than the Main PSP (PSP selain PSP Utama);
- Basis for considering approval Payment System Business Plan (“RBSP”);
- Basis for considering approval of activity and product development, and/or cooperation;
- Fullfilment of obligations in the implementation of Payment System;
- Requirements for obtaining access as a Participant in the Payment System infrastructure;
- Basis for determining the form, approach, and scope of implementation and follow- up supervision;
- Basis for considering termination of the implementation of the Payment System; and
- Other use.
This reflects a supervisory approach where operational readiness, governance, transaction architecture, and technology resilience increasingly form part of the regulatory assessment process.
Licensing and Operational Alignment
While the new framework introduces a more activity based supervisory approach, several core principles remain relevant, including licensing requirements, governance expectations, ownership considerations, and operational oversight obligations.
PBI 10/2025 also places increasing emphasis on:
- Strategic Business Plans (“SBP”);
- Payment System Business Plans (“RBSP”); and
- Approval based development of activities, products, and cooperation arrangements.
This may become particularly relevant for businesses entering Indonesia’s payment sector or planning to expand payment-related functionalities over time.
The SBP establishes the strategic planning direction and defines the PSP’s medium-term strategy, which must be submitted to Bank Indonesia every 3 (three) years. In contrast, the RBSP functions as the annual operational document, providing the foundation for planned cooperation arrangements and key business developments. The primary difference between the SBP and the RBSP lies in their respective timeframes.
Furthermore, PBI 10/2025 and PADG 32/2025 further reinforce the provisions concerning the development of activities that may be undertaken by PSPs, including the development of activities, products, and/or cooperation arrangements that have an impact on the stages of payment transaction processing which includes initiation, authorization, clearing, and settlement In addition, PSPs may also undertake the development activities during the pre-transaction and post-transaction stages.
For each type of development, the PSP is required to obtain approval from Bank Indonesia or submit a report on the development plan to Bank Indonesia, as applicable.
Why Early Structuring Matters
Under a more activity based and supervisory driven framework, structuring decisions made at the outset may later affect:
- Licensing pathways;
- Scalability;
- Product expansion; and
- Operational flexibility.
Businesses will increasingly need to assess not only whether a proposed model is commercially workable, but also whether the operational structure remains aligned with evolving regulatory expectations as the business develops.
Strategic Consideration
Indonesia continues to present significant opportunities for businesses operating payment related services and digital transaction ecosystems. At the same time, the regulatory framework is becoming increasingly operationally focused and supervisory driven.
As Indonesia’s payment framework continues to evolve, regulatory structuring is becoming increasingly relevant not only to licensing, but also to scalability, product expansion, and long-term operational flexibility.
Authors:
Arif Gaffar , Latifah Kusumawardani, Maximus Sumber Vito & Rania Salsabilla
Gaffar & Co. Law Firm advises domestic and international businesses on corporate, regulatory, and commercial matters in Indonesia.
If you are currently operating, or planning to operate, as a PSP in Indonesia, the requirements under PBI 10/2025 and PADG 32/2025 may be relevant to your business. We would be pleased to discuss this further with you.
For further information, please contact:
Phone : +62 811 877 216
Email : info@gaffarcolaw.com
Websites : www.gaffarcolaw.com
