Regulatory AlertsImplementation of Information Technology-Based Crowdfunding Services
The Financial Services Authority (OJK) issued Circular Letter No. 19/SEOJK.06/2025 to regulate the implementation of information technology-based crowdfunding services, replacing the previous 2023 circular. The regulation establishes strict operational requirements for service providers, including mandatory risk disclosures, specific eligibility criteria for Indonesian lenders, and limitations on data access and economic benefits. It also defines credit scoring data sources, emergency contact usage protocols, and a six-month transition period for adjusting existing loan agreements to comply with new portfolio transfer mechanisms.
Circular Letter of the Financial Services Authority Number 19/SEOJK.06/2025 regarding the Implementation of Information Technology-Based Crowdfunding Services
Abstract: This Circular Letter of the Financial Services Authority is drafted based on the mandate of Article 136 paragraph (3), Article 139 paragraph (3), Article 140 paragraph (3), Article 142 paragraph (12), Article 148 paragraph (8), Article 149 paragraph (3), Article 152 paragraph (5), Article 153 paragraph (9), Article 161 paragraph (2), and Article 171 paragraph (3) of Financial Services Authority Regulation Number 40 of 2024 regarding Information Technology-Based Crowdfunding Services.
Legal Basis: This Circular Letter of the Financial Services Authority is based on POJK No. 40 of 2024.
Note: This Circular Letter of the Financial Services Authority takes effect on the date it is established. This Circular Letter of the Financial Services Authority was established on July 31, 2025.
Service Providers must hold a General Meeting of Fund Providers based on guidelines for the implementation of the General Meeting of Fund Providers that have been established.
In conducting Funding, Service Providers: a. must include warnings regarding the risks of LPBBTI business activities. Risk warnings for LPBBTI business activities must be displayed on the interface pages of the website or application owned by the Service Provider, clearly visible to Users; and b. must ensure that Users understand all risks before providing Funding.
Fund Providers consist of Professional Fund Providers and Non-Professional Fund Providers.
Indonesian Citizen Fund Providers must meet the following criteria: a. be at least 18 (eighteen) years old or married; b. have an average gross income of at least Rp3,000,000.00 (three million rupiah) per month, supported by valid evidence supporting income information, such as payslips or bank account statements of the Fund Recipient; and c. use their own mobile devices in the Funding process.
Service Providers must comply with maximum economic benefit limits for Funding when facilitating Funding. Economic benefits charged by the Service Provider include: a. interest/margin/profit sharing; b. administrative fees/commission fees/platform fees/ujrah equivalent to the aforementioned fees; and c. other costs, excluding late payment penalties, electronic signature fees secured with electronic certificates, and taxes.
In conducting business activities, Service Providers may only access the camera, location, and microphone on the User's own mobile devices.
Service Providers must publish Funding performance on the main page of their website, application, and/or Electronic System, containing at least the following information: a. the value of disbursed Funding; b. the number of Fund Providers; c. the number of Fund Recipients; and d. the quality level of Funding.
The use of emergency contacts is only intended to confirm the whereabouts of the Fund Recipient and must not be used to collect Funding payments from emergency contacts.
In the context of Funding disbursement, Service Providers may cooperate with partners, conducted for the purposes of: a. delivering goods and/or services; and b. providing education to Fund Recipients.
In the context of credit scoring, Service Providers may utilize data from: a. internal Service Provider data; b. information management service providers that are registered or licensed by the relevant authority; c. government agencies, state-owned enterprises, or regional-owned enterprises; and/or d. other institutions that are registered or licensed by the relevant authority.
Service Providers subject to business activity restrictions and/or unable to be rehabilitated may transfer their Funding portfolio to other Service Providers or institutions specifically established for this purpose. The mechanism for transferring the Funding portfolio must be included in the agreement between the Fund Recipient and the Fund Provider.
Transitional Provisions: a. Funding agreements signed before this Circular Letter of the Financial Services Authority takes effect are declared to remain valid until the end of the Funding agreement. b. In the event that Funding agreements signed before this Circular Letter of the Financial Services Authority takes effect require changes after its implementation, changes to such Funding agreements must comply with the provisions in this Circular Letter of the Financial Services Authority. c. Agreements between Fund Recipients and Fund Providers that were in effect before this Circular Letter of the Financial Services Authority takes effect must be adjusted to comply with provisions regarding the inclusion of the Funding portfolio transfer mechanism in the agreement, no later than 6 (six) months from the effective date of this Circular Letter of the Financial Services Authority.
Upon the implementation of this Circular Letter of the Financial Services Authority, Circular Letter of the Financial Services Authority Number 19/SEOJK.06/2023 regarding the Implementation of Information Technology-Based Crowdfunding Services is revoked and declared invalid.