Indonesia’s peer-to-peer (P2P) lending sector has entered a new regulatory phase following the issuance of Circular Letter No. 19/SEOJK.06/2025 concerning Information Technology-Based Joint Funding Services by the Financial Security Service (Otoritas Jasa Keuangan or OJK) in July 2025 (Circular Letter). The Circular Letter provides operational guidance for P2P lending platforms and replaces Circular Letter No. 19/SEOJK.06/2023 concerning Organization of Information Technology-Based Koint Funding Services. It also functions as an implementing framework for OJK Regulation No. 40 of 2024 concerning Information Technology-Based Joint Funding Services, which introduced broader structural reforms in Indonesia’s digital lending industry.
The updated rules affect multiple participants within the ecosystem—including platform operators, lenders, and borrowers—and are intended to strengthen transparency, risk control, and consumer protection while supporting the continued growth of financial technology services. Full compliance with the new framework must be achieved by 1 January 2026.
Stronger Risk Controls for Lenders and Borrowers
One notable development introduced by the Circular Letter is the classification of lenders into professional and non-professional categories based on their investment capacity assessed through annual income. Each type of lender is subject to different investment threshold.
Professional lenders include financial institutions, company established under Indonesian or foreign law, as well as Indonesian individuals with annual income above IDR 500 million. Professional lenders may allocate up to 20% of their annual income to a single platform. The professional category may also include foreign individuals, central or regional government, foreign governments, and multilateral organizations participating in fintech lending activities. While non-professional lenders consist of domestic individuals whose annual income is IDR 500 million or less. Non-professional lenders are restricted to 10% of their annual income per platform. In addition, platforms must ensure that total funding from non-professional lenders does not exceed 20% of the platform’s outstanding funding portfolio.
Borrower eligibility requirements have also been clarified. Individual borrowers must be Indonesian citizens aged at least 18 years (or married) and demonstrate a minimum monthly income of IDR 3 million. Legal and/or business entities established under Indonesian law may also obtain funding through these platforms. These measures aim to align borrowing activity with users’ financial capacity and reduce default risks.
New Approach to Credit Assessment
The Circular Letter also revises how platforms evaluate borrower creditworthiness. Although operators remain free to develop their own credit-scoring methodology, the regulation provides clearer parameters on repayment capacity and acceptable data sources. In addition, platform may consider other aspects such as capital, condition of economy, and/or collateral.
The platform operator must conduct credit scoring in the course of extending funding by, at a minimum, verifying the authenticity of documents submitted by prospective borrowers in accordance with its credit scoring guidelines, and performing clarification and confirmation processes—whether through in-person, electronic face-to-face, or non-face-to-face electronic means—in line with applicable anti-money laundering, counter-terrorism financing, and counter-proliferation financing regulations. In addition, the operator must process relevant data obtained from third parties and carry out a comprehensive analysis of the prospective borrower to support its credit assessment.
Platforms may rely on several types of information when assessing borrowers, including internal platform data, data from licensed information service providers, government databases, or other registered institutions. By clarifying these sources, OJK seeks to standardize credit assessment practices while preserving flexibility in risk modelling.
Loan Performance
Another major update concerns loan performance reporting. The previous Successful Payment Rate (Tingkat Keberhasilan Bayar or TKB) indicator has been replaced with a Funding Quality Level (Tingkat Kualitas Pendanaan) classification system. The revised categories range from performing loans to non-performing loans with arrears exceeding 90 days, giving lenders a clearer picture of portfolio risk.
Revised Funding and Pricing Rules
The Circular Letter also introduces clearer financial thresholds governing the P2P lending market. The general funding cap remains IDR 2 billion per borrower for both consumptive and productive loans. However, productive lending may reach IDR 5 billion if a platform maintains a non-performing loan rate of no more than 5% over the preceding six months and is not subject to regulatory sanctions by OJK.
Another significant change concerns the maximum economic benefit that platforms may charge borrowers. Economic benefit includes: (a) interest, profit-sharing or margin, (b) administrative charges, commission fee, platform fee, and (c) other fees other than late penalty, e-signature fee, and tax. As opposed to the previous regulatory framework, the new circular introduces fixed limits based on loan type, loan size, and tenure, providing clearer cost parameters for both platforms and borrowers.
General Meeting
A General meeting of lenders may be convened whenever deemed necessary by the platform operator, lenders, and/or borrowers. The operator is required to establish formal guidelines governing such meetings, which must at minimum regulate procedural aspects, including lenders’ rights to attend and vote, the conditional participation of borrowers, and the option to conduct meetings either physically or electronically. The guidelines must also ensure adequate prior notice to participants and clear disclosure of the meeting agenda.
In addition, the guidelines must set out governance and operational mechanisms, such as the appointment of a meeting chair, structured stages of the meeting, and fair decision-making processes. They must further include practical guidance covering how meetings may be proposed, proper documentation of proceedings and resolutions, allocation of costs (to be borne by the operator), and the selection of the meeting leader. These guidelines should be tailored to the operator’s scale and capacity, and all meetings must be conducted in accordance with the established framework.
Management of Data and Information
The platform operator is only permitted to access a user’s device camera, location, and microphone strictly for the purpose of conducting its business activities. It is prohibited from disclosing any user’s personal data or information to third parties, except where the user has provided explicit written consent or where such disclosure is required or permitted under applicable laws and regulations.
Expanded Transparency and Platform Disclosure
To improve user awareness, the Circular Letter requires P2P platforms to disclose more detailed information on their websites or applications. This includes the platform’s legal identity, ownership structure, governance arrangements, and licensing status under OJK supervision.
Platforms must also publish key operational data, such as the total amount of funding disbursed, the number of lenders and borrowers, and indicators reflecting loan performance. Additionally, risk warnings must be displayed prominently so that users understand the potential risks associated with digital lending services.
Operational Flexibility with Safeguards
While strengthening oversight, the Circular Letter also introduces limited operational flexibility. One example concerns outsourcing arrangements. Core functions—such as credit feasibility assessments and critical IT operations—must remain under the platform operator’s direct control.
However, the regulation allows outsourcing of IT development activities, provided certain safeguards are met. Platform operators must retain ownership of the application source code and maintain control over server access, and outsourcing cannot extend to deployment or production-stage maintenance. These restrictions are designed to protect system security and data integrity while still enabling technological development.
Transitional Provisions
The transitional provisions stipulate that any funding agreements executed prior to the enactment of this circular letter shall remain valid until their expiry. However, if such pre-existing agreements are amended after the circular letter comes into force, any amendments must comply with the new provisions set out therein. Furthermore, agreements between borrowers and lenders that were already in effect before the circular letter must be updated to include a funding portfolio transfer mechanism, with such adjustments to be completed no later than six months from the effective date of the circular letter.
Implications for P2P Lending Operators
Overall, the Circular Letter represents a significant refinement of Indonesia’s regulatory framework for P2P lending. Rather than introducing an entirely new regime, the circular builds on earlier rules by clarifying operational standards, tightening risk management, and enhancing transparency requirements.
For platform operators, the transition period must be done at the latest on 1 January 2026. Companies should review their internal policies, risk-assessment procedures, pricing structures, and disclosure practices to ensure alignment with the updated regulatory expectations.
At the same time, the circular signals OJK’s broader regulatory objective: enabling continued innovation in digital finance while ensuring that the P2P lending market develops in a stable, transparent, and responsible manner.
For further information, please contact:
MetaLAW, Legal Consultant, Jakarta, Indonesia
general@metalaw.id
