OJK REGULATION NO. 32 OF 2025

ON THE IMPLEMENTATION OF BUY NOW PAY LATER (BNPL)

BY THE GRACE OF THE ALMIGHTY GOD,

THE COMMISSIONER COUNCIL OF THE FINANCIAL SERVICES AUTHORITY,

Considering:
a. that in order to support the creation of a reliable digital financing ecosystem in the financial sector, regulations are needed that aim to provide legal certainty, strengthen governance, and protect consumer interests and the stability of the financial services sector; b. that the operation of the buy now pay later (buy now pay later) business model requires regulation so that its implementation is in line with prudential principles, good governance, and supports the growth of a healthy and sustainable financial services industry;
c. that based on the considerations as referred to in letters a and b, it is necessary to establish a Financial Services Authority Regulation on the Implementation of Buy Now Pay Later (Buy Now Pay Later);

Recalling:

1. Law Number 21 of 2011 on the Financial Services Authority (State Gazette of the Republic of Indonesia Year 2011 Number 111, Supplement to the State Gazette of the Republic of Indonesia Number 5253) as amended by Law Number 4 of 2023 on the Development and Strengthening of the Financial Sector (State Gazette of the Republic of Indonesia Year 2023 Number 4, Supplement to the State Gazette of the Republic of Indonesia Number 6845);
2. Law Number 4 of 2023 on the Development and Strengthening of the Financial Sector (State Gazette of the Republic of Indonesia Year 2023 Number 4, Supplement to the State Gazette of the Republic of Indonesia Number 6845);

DECIDES:

Establish: FINANCIAL SERVICES AUTHABILITY REGULATION ON THE IMPLEMENTATION OF BUY NOW PAY LATER (BUY NOW PAY LATER).

CHAPTER I

GENERAL PROVISIONS

Article 1

In this Financial Services Authority Regulation, the following terms are meant:

1. Buy Now Pay Later (Buy Now Pay Later), hereinafter referred to as BNPL, is a financing facility provided by a financial institution through an electronic system for the purchase of goods and/or services.
2. General Bank is a bank that conducts business activities conventionally or conducts business activities based on Sharia Principles, which in its activities provides services in payment transactions, including branch offices of banks located outside the country and Sharia business units.
3. Financing Company is a legal entity that conducts financing activities for goods and/or services to the public, including those that conduct their business activities either partially or entirely based on implementing business activities based on Principles.
4. Sharia Principles are Islamic legal principles based on fatwas and/or statements of Sharia compliance issued by institutions that have the authority to issue fatwas in the field of Sharia.
5. Electronic System is a series of electronic devices and procedures that function to prepare, collect, process, analyze, store, display, announce, send, and/or disseminate electronic information.

CHAPTER II

FINANCIAL INSTITUTIONS OPERATING BNPL

Article 2

(1) Financial institutions that operate BNPL include:
a. General Banks; and b. Financing Companies.

(2) The implementation of BNPL by General Banks as referred to in paragraph (1) letter a is implemented by referring to the provisions of laws and regulations for General Banks.

(3) The implementation of BNPL by Financing Companies as referred to in paragraph (1) letter b is implemented by referring to the provisions of laws and regulations for Financing Companies, after obtaining approval from the Financial Services Authority.

(4) Regulations regarding the procedure for approval of BNPL Implementation as referred to in paragraph (3) are established by the Financial Services Authority.

CHAPTER III

BNPL IMPLEMENTATION

First Section

General

Article 3

BNPL implementation must meet certain characteristics, including:
a. aimed at financing the purchase of goods and/or services non-cash to customers/debtors; b. without collateral;
c. having a specific limit (ceiling);
d. repayment of principal and/or interest/margin/remuneration/ujrah is carried out according to the agreed installment/schedule scheme; e. the approval process for customers/debtors to use BNPL is carried out through the following mechanisms:

1. electronic face-to-face meetings; and/or
2. non-electronic face-to-face meetings; and
   f. carried out through an Electronic System.

Article 4

(1) General Banks or Financing Companies may operate BNPL conventionally or based on Sharia Principles.

(2) The implementation of BNPL based on Sharia Principles as referred to in paragraph (1) is implemented in accordance with the provisions of laws and regulations regarding Sharia Principles for General Banks or Financing Companies.

Second Section

Prudential Principles and Consumer Protection

Article 5

(1) General Banks or Financing Companies apply prudential principles in operating BNPL.

(2) The application of prudential principles as referred to in paragraph (1) is implemented in accordance with the provisions of laws and regulations regarding prudential principles for General Banks or Financing Companies.

Article 6

(1) General Banks or Financing Companies may establish special policies in assessing the feasibility of providing BNPL financing.

(2) In establishing special policies as referred to in paragraph (1), General Banks or Financing Companies compile guidelines for assessing the feasibility of providing BNPL financing.

Article 7

(1) General Banks or Financing Companies apply consumer protection in operating BNPL.

(2) The application of consumer protection as referred to in paragraph (1) is implemented in accordance with Financial Services Authority Regulations regarding consumer and public protection in the financial services sector.

Article 8

(1) General Banks or Financing Companies apply the principle of customer/debtor personal data protection in operating BNPL.

(2) The principle of customer/debtor personal data protection as referred to in paragraph (1) is implemented in accordance with the provisions of laws and regulations.

Third Section

Cooperation

Article 9

(1) General Banks or Financing Companies may conduct BNPL implementation cooperation with other parties based on cooperation agreements in accordance with the provisions of laws and regulations for General Banks or Financing Companies.

(2) Cooperation agreements as referred to in paragraph (1) must meet aspects of information openness to consumers.

Fourth Section

Information Disclosure

Article 10

General Banks or Financing Companies provide, convey information, and market BNPL to prospective customers/prospective debtors and/or customers/debtors in accordance with the provisions of Financial Services Authority Regulations regarding consumer and public protection in the financial services sector.

Article 11

(1) For BNPL implementation, General Banks or Financing Companies are required to provide necessary information to prospective customers/prospective debtors and/or customers/debtors on the Electronic System.

(2) Information as referred to in paragraph (1) consists of:
a. the source of financing funds in the event that financing is conducted through joint financing mechanisms, channeling financing, and/or has been transferred to other parties; b. the amount and frequency of installments; and/or
c. other information established by the Financial Services Authority.

(3) General Banks or Financing Companies that violate the provisions as referred to in paragraph (1) are subject to administrative sanctions in the form of:
a. written warnings; b. product and/or service restrictions and/or business activities for part or all;
c. freezing of products and/or services and/or business activities for part or all;
d. dismissal of management; e. administrative fines; f. revocation of product and/or service licenses; and/or g. revocation of business licenses.

(4) Administrative sanctions as referred to in paragraph (3) letters b through g may be imposed with or without prior imposition of administrative sanctions in the form of written warnings as referred to in paragraph (3) letter a.

(5) Administrative fines as referred to in paragraph (3) letter e are imposed at most IDR 15,000,000,000.00 (fifteen billion rupiah).

CHAPTER IV

COLLECTION

Article 12

BNPL collection mechanisms are implemented in accordance with Financial Services Authority Regulations regarding consumer and public protection in the financial services sector.

CHAPTER V

REPORTING

Article 13

(1) General Banks or Financing Companies compile and submit reports on BNPL implementation to the Financial Services Authority.

(2) The compilation and submission of BNPL implementation reports as referred to in paragraph (1) is implemented in accordance with the provisions of laws and regulations regarding reporting for General Banks or Financing Companies.

CHAPTER VI

TERMINATION OF BNPL IMPLEMENTATION

Article 14

(1) Termination of BNPL implementation is carried out based on:
a. the initiative of General Banks or Financing Companies; or b. orders from the Financial Services Authority.

(2) Termination of BNPL implementation carried out based on the initiative of General Banks as referred to in paragraph (1) letter a is implemented in accordance with the provisions of laws and regulations for General Banks.

(3) Termination of BNPL implementation carried out based on the initiative of Financing Companies as referred to in paragraph (1) letter a is implemented after obtaining approval from the Financial Services Authority by referring to the provisions of laws and regulations for Financing Companies.

(4) Termination of BNPL implementation carried out based on orders from the Financial Services Authority as referred to in paragraph (1) letter b is implemented with consideration in the event that:
a. violations of laws and regulations; b. increased risk profiles that cannot be adequately mitigated; and/or
c. increased number of customer complaints that cannot be resolved properly.

(5) Regulations regarding the termination of BNPL implementation for Financing Companies as referred to in paragraph (3) are established by the Financial Services Authority.

CHAPTER VII

OTHER PROVISIONS

Article 15

(1) The Financial Services Authority may establish maximum economic benefits for Financing Companies in BNPL implementation.

(2) Regulations regarding the establishment of maximum economic benefits as referred to in paragraph (1) are established by the Financial Services Authority.

Article 16

The Financial Services Authority may establish policies that differ from this Financial Services Authority Regulation based on certain considerations.

CHAPTER VIII

TRANSITIONAL PROVISIONS

Article 17

At the time this Financial Services Authority Regulation takes effect:
a. BNPL financing agreements and BNPL implementation cooperation agreements that have been signed before this Financial Services Authority Regulation takes effect are declared to remain valid until the end of the BNPL financing agreements and BNPL implementation cooperation agreements; b. General Banks or Financing Companies that have operated BNPL before this Financial Services Authority Regulation is promulgated must adjust to meet the BNPL characteristics as referred to in Article 3 within a maximum period of 6 (six) months from the date this Financial Services Authority Regulation is promulgated; and
c. Changes to BNPL financing agreements and changes to BNPL implementation cooperation agreements that have been signed before this Financial Services Authority Regulation takes effect must be implemented in accordance with the provisions in this Financial Services Authority Regulation.

CHAPTER IX

CLOSING PROVISIONS

Article 18

This Financial Services Authority Regulation takes effect on the date it is promulgated.

In order that everyone knows it, it is ordered to promulgate this Financial Services Authority Regulation by placing it in the State Gazette of the Republic of Indonesia.

Established in Jakarta on 5 December 2025

THE CHAIRMAN OF THE COMMISSIONER COUNCIL
FINANCIAL SERVICES AUTHORITY
REPUBLIC OF INDONESIA,

MAHENDRA SIREGAR

Promulgated in Jakarta on

MINISTER OF LAW OF THE REPUBLIC OF INDONESIA,

SUPRATMAN ANDI AGTAS

STATE GAZETTE OF THE REPUBLIC OF INDONESIA 2025 NUMBER

EXPLANATION

OF

FINANCIAL SERVICES AUTHORITY REGULATION

OF THE REPUBLIC OF INDONESIA

NUMBER 32 OF 2025

ON

THE IMPLEMENTATION OF BUY NOW PAY LATER

(BUY NOW PAY LATER)

I. GENERAL

The development of digital technology in the financial services sector has driven innovation in financing business models, one of which is BNPL operated by General Banks and Financing Companies. BNPL offers ease and speed of access to financing for the public, including groups of people who were previously not served by conventional financial institutions. However, the growth of this service also brings new risks that need to be anticipated, such as the potential for consumer default, information imbalance between business actors and consumers, and operational and systemic risks arising from the use of digital technology.

Therefore, regulations are needed so that the implementation of BNPL in the financial services sector, specifically General Banks and Financing Companies, is carried out by paying attention to prudential principles, consumer protection, and good governance. This regulation aims to ensure that this business model not only promotes healthy and sustainable industry growth, but also remains within the framework of effective supervision by the Financial Services Authority.

Furthermore, in order to support the creation of a reliable digital financing service ecosystem, this regulation is drafted to provide legal certainty for business actors, strengthen aspects of governance and risk management, and protect consumer interests and the stability of the financial services sector as a whole.

Regulations regarding BNPL Implementation are also in line with the Financial Services Authority's policy direction in strengthening the digital transformation of the financial services sector and supporting the sustainable improvement of national financial inclusion.

II. ARTICLE BY ARTICLE

Article 1

Clear enough.

Article 2

Paragraph (1)

Clear enough.

Paragraph (2)

What is meant by "laws and regulations for General Banks" includes, among others, Financial Services Authority Regulations regarding the implementation of general bank products.

Paragraph (3)

What is meant by "laws and regulations for Financing Companies" includes, among others, Financial Services Authority Regulations regarding the implementation of financing company businesses.

Paragraph (4)

Clear enough.

Article 3

Letter a

What is meant by "purchase of goods and/or services non-cash" does not include credit card facilities.

Letter b

Clear enough.

Letter c

What is meant by "specific limit (ceiling)" does not include credit card limits.

Letter d

Clear enough.

Letter e

Number 1

What is meant by "electronic face-to-face meetings" includes, among others, conducted using video calls/video conferences.

Number 2

What is meant by "non-electronic face-to-face meetings" includes, among others, not conducted physically and conducted using applications or websites without video calls/video conferences.

Letter f

Clear enough.

Article 4

Paragraph (1)

Clear enough.

Paragraph (2)

What is meant by "laws and regulations regarding Sharia Principles for General Banks or Financing Companies" includes, among others, Financial Services Authority Regulations regarding the implementation of Sharia financing company businesses and Sharia business units of financing companies, and Financial Services Authority Regulations regarding the application of governance for Sharia General Banks and Sharia business units.

Article 5

Paragraph (1)

Clear enough.

Paragraph (2)

What is meant by "prudential principles" includes the application of good corporate governance, risk management, the application of anti-money laundering programs, counter-terrorism financing, and counter-proliferation of weapons of mass destruction financing, and the application of anti-fraud strategies.

Article 6

Paragraph (1)

What is meant by "Establishment of special policies in assessing the feasibility of providing BNPL financing" includes, among others, in the event that historical data of prospective customers/prospective debtors from financial service information systems with non-performing receivables values that are not material are found, but prospective customers/prospective debtors still have repayment capacity, and the provision of BNPL financing is still in accordance with the risk appetite of General Banks or Financing Companies, General Banks or Financing Companies may consider prospective customers/prospective debtors to still be able to obtain financing disbursement.

Paragraph (2)

Clear enough.

Article 7

Clear enough.

Article 8

Paragraph (1)

Clear enough.

Paragraph (2)

What is meant by "provisions of laws and regulations" includes, among others, Laws regarding personal data protection and Financial Services Authority Regulations regarding consumer and public protection in the financial services sector.

Article 9

Paragraph (1)

What is meant by "other parties" includes, among others, e-commerce.

Paragraph (2)

What is meant by "aspects of information openness to consumers" includes, among others:

1. the use of customer/debtor data in accordance with the provisions of laws and regulations;
2. the conveyance of BNPL operators including the owners of products and/or services; and
3. the mechanism for conveying information to customers/debtors regarding General Banks or Financing Companies that provide funds.

Article 10

Clear enough.

Article 11

Paragraph (1)

Clear enough.

Paragraph (2)

Clear enough.

Paragraph (3)

The imposition of administrative sanctions is imposed with considerations, including:
a. complexity of violations of regulations; b. repeated violations of regulations; and/or
c. the impact of violations of regulations on consumer losses, the financial condition of General Banks or Financing Companies, and the financial services sector.

Paragraph (4)

What is meant by "written warnings" includes written reprimands on General Banks.

Paragraph (5)

Clear enough.

Article 12

Clear enough.

Article 13

Clear enough.

Article 14

Paragraph (1)

Clear enough.

Paragraph (2)

See Explanation of Article 2 paragraph (2).

Paragraph (3)

See Explanation of Article 2 paragraph (3).

Paragraph (4)

Clear enough.

Paragraph (5)

Clear enough.

Article 15

Clear enough.

Article 16

Different policies are intended among others for:
a. supporting national policies; b. maintaining public interests;
c. maintaining industry growth; and/or
d. maintaining healthy business competition.

The consideration of supporting national policies is intended so that the growth of the General Banks and Financing Companies industry does not become an obstacle to national policies established by the government, the Financial Services Authority, and/or relevant authorities.

The consideration of maintaining public interests is intended so that the General Banks and Financing Companies industry always meets the needs of the broad public with equal access and quality, as well as affordable costs.

The consideration of maintaining industry growth is intended so that the industry can grow optimally in society.

The consideration of maintaining healthy business competition is intended so that the implementation of General Banks and Financing Companies can be conducted honestly, not contrary to law, or not hindering business competition.

Article 17

Clear enough.

Article 18

Clear enough.

SUPPLEMENT TO THE STATE GAZETTE OF THE REPUBLIC OF INDONESIA NUMBER