“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
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 payment funding sources;
- Forwarding payment transaction instructions; and
- Fund transfer related activities.
The framework further introduces Bundling 1, Bundling 2, and Bundling 3 classifications for PJP 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.
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.
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.
Specifically, Regulation of the Members of the Board of Governors No. 32 of 2025 (“PDAG 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.
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
Gaffar & Co. Law Firm advises domestic and international businesses on corporate, regulatory, and commercial matters in Indonesia.
For further information, please contact:
Phone : +62 811 877 216
Email : info@gaffarcolaw.com
Websites : www.gaffarcolaw.com
