Regulatory AlertsIndonesia: lending & credit regulation
RegulatedOJK regulates fintech lending (LPBBTI) and BNPL; strict capital and reporting rules apply
- Lead regulator
- Otoritas Jasa Keuangan (OJK)
- Also involved
- Bank Indonesia (payment systems/liquidity) · OJK (supervision) · PPATK (AML/CFT)
- Core law
- Financial Sector Development and Strengthening Law (2020) & OJK Regulations
- Entry capital
- IDR 12 billion (LPBBTI)
- Approval timeline
- 6-12 months for LPBBTI license
- Customer assets
- Funds must be held in segregated accounts at licensed banks
- Data protection
- Personal Data Protection Law (UU PDP) · OJK reporting
- Sandbox
- Yes - OJK Regulatory Sandbox
Indonesia strictly regulates digital lending under the OJK. The primary framework for fintech lending is OJK Regulation No. 40 of 2024 on Information Technology-Based Collective Financing Services (LPBBTI), requiring significant capital and data reporting. Buy Now Pay Later (BNPL) is also regulated by OJK Regs No. 32 of 2025 and No. 2 of 2026. Traditional microfinance and SME lending are supervised under separate OJK frameworks for Financing Institutions and Microfinance Institutions.
Which licence do you need?
| Your activity | Requirement | Capital | Timeline | Authority |
|---|---|---|---|---|
| Consumer lending | LicenceFinancing Institution License[1][2] Requires OJK license as Financing Institution or LPBBTI | IDR 12 billion (for LPBBTI) | 6-12 months | OJK |
| SME / commercial lending | LicenceFinancing Institution License[3][1] OJK Reg 19/2025 mandates facilitation; LPBBTI covers SME financing | IDR 12 billion (for LPBBTI) | 6-12 months | OJK |
| Microfinance | LicenceMicrofinance Institution License[4] Regulated under OJK Reg 41/2024; local gov ownership allowed | Varies by scale (Small/Medium/Large) | — | OJK |
| Buy-now-pay-later | LicenceBNPL Service License[5][2] Strictly regulated for Financing Companies and Commercial Banks | IDR 12 billion (for LPBBTI) | 6-12 months | OJK |
| P2P lending platform | LicenceLPBBTI License[1][6] P2P lending is now classified as LPBBTI under OJK Reg 40/2024 | IDR 12 billion | 6-12 months | OJK |
| Credit bureau / scoring | Uncertainverify with regulator Scoring used internally; external bureaus regulated differently | — | — | — |
| Debt collection | Uncertainverify with regulator General business license required; specific debt collection rules unclear | — | — | — |
New — what changed recently
- 2026-01-01OJK Regulation No. 2 of 2026 — Comprehensive regulation of BNPL for financing and Sharia financing companies[2]
- 2025-01-01OJK Regulation No. 32 of 2025 — Regulation of BNPL services by commercial banks and financing companies[5]
- 2025-01-01OJK Regulation No. 19 of 2025 — Mandates banks and non-banks to facilitate MSME financing access[3]
- 2024-01-01OJK Regulation No. 40 of 2024 — Establishes LPBBTI framework with IDR 12 billion minimum equity[1]
Market-entry checklist
- 1Secure OJK LPBBTI LicenseObtain license as Information Technology-Based Collective Financing Service Provider
- 2Meet IDR 12 Billion CapitalEnsure minimum paid-up capital of IDR 12 billion for fintech lending operations
- 3Implement Data ReportingConnect to OJK's fintech lending data center for periodic transaction reporting
- 4Establish Segregated AccountsOpen segregated customer fund accounts at licensed Indonesian banks
- 5Adopt Risk Management FrameworkImplement OJK-mandated risk management and consumer protection policies
Sources
- OJK Regulation No. 49 of 2024 on Supervision, Supervision Status Determination, and Follow-up for Financing Institutions, Venture Capital Companies, Microfinance Institutions, and Other Financial Service Institutions · 2024-12-31
- Regulation of the Board of Commissioners of the Financial Services Authority Number 2 of 2026 Concerning the Implementation of Buy Now Pay Later for Financing Companies and Sharia Financing Companies · 2026-05-04
- OJK Regulation No. 19 of 2025 on Facilitating Financing Access for Micro, Small, and Medium Enterprises · 2025-08-28
- Financial Services Authority Regulation Number 41 of 2024 on Microfinance Institutions · 2024-12-27
- OJK Regulation No. 32 of 2025 on the Implementation of Buy Now Pay Later (BNPL) · 2025-12-15
- Procedures and Mechanisms for Submission of Financing Transaction Data and Reporting by Information Technology-Based Joint Financing Service Providers (LPBBTI) · 2024-02-01