In the final month of 2025, the Financial Services Authority of the Republic of Indonesia issued Regulation No. 38/PADK.06/2025 on the Assessment of the Financial Soundness of Online Lending Operators (“Regulation No. 38/2025”). This regulation serves as an implementing measure of the Financial Services Authority Regulation No. 40 of 2024 on Online Lending Services (“POJK No. 40/2024”), which had been enacted one year earlier. In general, Regulation No. 38/2025 provides guidance and establishes indicators for evaluating the financial soundness of peer-to-peer lending operators (“P2P Operator”) in Indonesia.
The financial soundness ratings of P2P Operators in Indonesia are divided into five tiers of composite rating. These ratings are based on an assessment of each operator’s ability to withstand significant adverse impacts arising from changes in business conditions or other factors.
The importance of maintaining financial soundness is underscored by Article 167(1) of POJK No. 40/2024 jo. Regulation No. 38/2025, which stipulates that P2P Operator in Indonesia must achieve a minimum composite rating of 3. Article 231(1) of Regulation No. 40 of 2024 stipulates that the obligation of P2P Operator to maintain at least a composite rating of 3 will take effect one year after the regulation’s enactment. Accordingly, this requirement becomes enforceable starting 27 December 2025.
Section III of the Attachment to Regulation No. 38/2025 further stipulates that the assessment of a P2P Operator’s financial soundness encompasses five key factors, namely, capital adequacy, funding quality, profitability, liquidity, and management. The indicators and parameters for each factor are detailed within the regulation, providing a structured framework for assessing the overall health of P2P Operator. In essence, these indicators and parameters function as mandatory benchmarks that every operator must meet to obtain at least a composite rating of 3.
The key requirements that P2P Operator must fulfill to secure a minimum composite rating of 3 can be summarized as follows, among others:
| No | Category | Requirements |
| CAPITALIZATION | ||
| Capital Adequacy and Capital Projections in Anticipating Risks | ||
| 1. | Minimum Equity | Minimum equity of more than Rp12.5 billion |
| 2. | Equity Ratio to Paid Up Capital (EPC) | 50% ≤ EPC < 75% |
| Capital Capacity in Anticipating Risks | ||
| 3. | Qualitative Measurements | The P2P Operator has an adequate level of capitalization and is sufficiently capable of anticipating the adverse impacts. |
| 4. | Qualitative Measurements | The quality of the capital components is generally fairly good, reasonably permanent, and adequately capable of absorbing losses. |
| 5. | Qualitative Measurements | The P2P Operator demonstrates fairly good capital management and/or maintains a reasonably sound capital adequacy assessment process. |
| 6. | Qualitative Measurements | The P2P Operator has fairly good access to sources of capital; however, support from shareholders is not provided explicitly. |
| FUNDING QUALITY | ||
| Quality of Earning Assets and Concentration of Risk Exposure | ||
| 1. | Non-Performing Funding Quality Ratio (Rasio Kualitas Pendanaan Macet – “NPL”) | The NPL ratio shall be no more than 5% |
| 2. | Risk Exposure Concentration through the Funding per User Ratio | Risk Exposure Concentration through the Funding per User Ratio (Lender) Lender = Total ending balance (outstanding) of funding Total active lender accounts |
| Risk Exposure Concentration through the Funding per User Ratio (Borrower) Borrowers = Total ending balance (outstanding) of funding Total active borrower accounts | ||
| The adequacy of policies and procedures, documentation systems, and the performance of handling non-performing funding | ||
| 3. | Qualitative Measurements | The funding distribution portfolio is dominated by exposure to relatively high credit risk |
| 4. | Qualitative Measurements | There is a fairly significant concentration in funding distribution |
| 5. | Qualitative Measurements | The quality of funding distribution is less than satisfactory |
| 6. | Qualitative Measurements | The P2P Operator’s funding distribution strategy is generally considered fairly stable |
| 7. | Qualitative Measurements | The funding distribution portfolio is fairly affected by changes in external factors |
| 8. | Qualitative Measurements | The P2P Operaor has reasonably adequate policies and procedures, documentation systems, and handling of non-performing funding. |
| PROFITABILITY | ||
| The ability of earning assets to generate profit | ||
| 1. | Return of Asset (RoA) | RoA of at least 1% |
| 2. | Return on Equity (RoE) | RoE of at least 2% |
| 3. | Return on Disbursement (RoD) | RoD of at least 0.25% |
| Operational efficiency level | ||
| 4. | Operating Expenses to Operating Income Ratio (OEOI) | OEOI ratio of less than 95% |
| 5. | Qualitative Measurements | The P2P Operator’s performance in generating profit (profitability) is fairly adequate |
| 6. | Qualitative Measurements | The main source of profitability derived from core earnings is fairly dominant, although there is a considerable influence from non-core earnings |
| 7. | Qualitative Measurements | The components supporting core earnings are fairly stable |
| 8. | Qualitative Measurements | The ability of earnings to strengthen capital and the prospects for future profitability are fairly good |
| LIQUIDITY | ||
| Ability to Fulfil Short Term and Long Term Obligations, and the Potential for Mismatch between Short Term and Long Term Obligations | ||
| 1. | Short term liquidity ratio current ratio (CR) | CR of at least 120% |
| 2. | Long term liquidity ratio | = Total assetsTotal liabilities |
| 3. | Qualitative Measurements | Cash flows from assets and liabilities are fairly well matched |
| Adequacy of Liquidity Management Policies | ||
| 4. | Qualitative Measurements | Liquidity management is fairly good |
| MANAGEMENT | ||
| The quality of general management, including the fulfilment of commitments to the Financial Services Authority and other partiesImplementation of good governanceCompliance of the P2P Operator with Sharia Principles and the execution of social functions, for P2P Operator operating based on Sharia Principles | ||
| 1. | Good governance | Good governance principles include: Transparency;Accountability;Responsibility;Independence; andFairness. |
| Implementation of risk management, particularly management’s understanding of the P2P Operator’s risksCompliance of the P2P Operator with Sharia Principles and the execution of social functions, for P2P Operator operating based on Sharia Principles | ||
| 2. | Risk management | Implementing risk management effectively |
Failure to Achieve Rating of 3
Referring to Article 178 of POJK No. 40/2024, failure to achieve a minimum composite rating of 3 may result in the imposition of administrative sanctions by the Financial Services Authority of the Republic of Indonesia. These sanctions are not merely symbolic, they encompass a wide spectrum of measures, including written warnings, suspension of business activities or restrictions on certain operation, revocation of approval, prohibition from acting as a controlling shareholder, administrative fines of up to Rp 50 million, downgrading of health assessment results and risk profile ratings, mandatory reassessment of compliance and performance indicators, and/or recordation of the track records.
Conclusion
Regulation No. 38/2025 establishes the framework and guidance for assessing the financial soundness of P2P Operators in Indonesia. By setting clear parameters and evaluation methods across capital adequacy, funding quality, liquidity, profitability, and management, the regulation provides legal certainty regarding the mechanisms used to determine the soundness of P2P Operator.
The regulation requires that every P2P Operator maintain a minimum composite rating of 3. This threshold signifies that an operator is considered sufficiently sound and reasonably capable of withstanding adverse impacts. If the P2P Operator fail to meet the minimum composite rating of 3 by 27 December 2025, the Financial Services Authority of the Republic of Indonesia reserves the right to impose administrative sanctions.
For further Information, please contact:
MetaLAW, Legal Consultant, Jakarta, Indonesia
general@metalaw.id
