Bank Indonesia (“BI”), the country’s central bank, recently issued BI Regulation No. 10 of 2025 regarding the Payment System Industry (“BI Reg. 10/2025”). This regulation revokes BI Regulation No. 22/23/PBI/2020 on Payment Systems and amends provisions of BI Reg. 23/6/PBI/2021 regarding Payment Service Providers (“BI Reg. 23/6”) and BI Reg. 23/7/PBI/2021 on Payment Service Infrastructure Providers (“BI Reg. 23/7”).
These amendments are further complemented by Members of the Board of Governors Regulation No. 32 of 2025 regarding the Payment System Industry (“MBG Reg. 32/2025”), which revises Members of the Board of Governors Regulation No. 24/7/PADG/2022 regarding the Organization of Payment Systems by Payment Service Providers and Payment System Infrastructure Organizers (“MBG Reg. 24/7”).
Both BI Reg. 10/2025 and MBG Reg. 32/2025 are intended to further structure and strengthen the national payment system industry to support the integration of Indonesia’s digital financial economy within a more consolidated and resilient regulatory framework, in line with BI’s Indonesia Payment System Blueprint 2030.
Amendments to the Classification of Payment Service Providers
One of the most significant developments introduced under BI Reg. 10/2025 is the revised classification of Payment Service Providers (“PSPs”). Under the new framework, both PSPs and Payment System Infrastructure Providers (“PSIPs”) now fall within the newly defined regulatory category known as Payment System Service Providers (“PSSPs”).
Under the previous regulatory framework, the activities that a PSP could undertake were determined based on its license category, namely Category One, Category Two, and Category Three.
A Category One PSP license permitted the holder to conduct activities comprising (i) the provision of information on source of funds; (ii) payment initiation and/or acquiring services; (iii) administration of source of funds; and (iv) remittance services. A Category Two PSP license was limited to (i) the provision of information on source of funds; and (ii) payment initiation and/or acquiring services. A Category Three PSP license covered remittance services and/or other activities as stipulated by BI.
However, BI Reg. 10/2025 has amended this licensing framework. Rather than classify PSPs by license category, the regulation now groups permitted activities into defined “activity bundles,” with PSPs licensed based on the specific bundle corresponding to their intended activities.
Pursuant to BI Reg. 10/2025, the allowed scope of activities for a PSP-licensed entity are the following:
- Administration of source of funds: This includes the administration of payment accounts, as well as the issuance of, or provision of access to, source of funds; and
- Forwarding of payment transactions: Encompasses the forwarding of payment transaction data and payment instructions (which may include facilities for receiving payments), as well as the forwarding of fund transfer instructions (digitally or otherwise).
Additionally, pursuant to BI Reg. 10/2025, PSP licenses issued by BI are divided into three “bundles,” depending on which of the above activities the license holder is authorized to undertake:
- Activity Bundle 1: This category covers the full breadth of activities set out above;
- Activity Bundle 2: This category covers the full breadth of activities under forwarding of payment transactions; and
- Activity Bundle 3: This category covers forwarding of payment transactions activities solely in the form of non-digital fund transfer instructions.
A further distinction is introduced within Activity Bundle 1, which is divided into Bundles 1A and 1B. However, the regulation does not clearly distinguish between the specific activities permitted under each sub-bundle.
Mandatory Registration Obligation for Supporting Providers
Under BI Reg. 10/2025, Supporting Providers are now classified into three categories, as determined by BI: (i) Critical Supporting Providers, (ii) Crucial Supporting Providers, and (iii) Standard Supporting Providers.
Critical and Crucial Supporting Providers provide services at the transaction processing stages, including initiation, authorization, clearing, and final settlement, and may also provide services at the pre-transaction and post-transaction stages. In light of the critical nature and scope of these services, BI requires Critical and Crucial Supporting Providers to undergo mandatory registration.
Such registration must be completed no later than three years from the effective date of BI Reg. 10/2025, i.e., by March 31, 2029. This registration may be submitted by the relevant Critical or Crucial Supporting Provider and/or by the PSSP cooperating with the Supporting Provider.
BI’s Authority to Dismiss or Replace Members of the Board of Directors, Board of Commissioners, Shareholders, and/or Executive Officers
BI Reg. 10/2025 contains a grandfathering clause that exempts PSPs that have obtained licenses and PSIPs that have obtained designations from complying with the updated ownership requirements, provided that there is no change in the composition of foreign ownership.
However, it must be noted that BI Reg. 10/2025 also introduces a new sanctioning power under which BI may issue an order and/or recommendation for the dismissal or replacement of members of the board of directors, members of the board of commissioners, shareholders, and/or executive officers (or their equivalents) in the event of a violation.
The imposition of such a sanction could result in a change to the ownership composition of the relevant PSP or PSIP. In such circumstance, the entity would no longer benefit from the grandfathering exemption from the revised foreign shareholding and control restrictions and would therefore be required to comply with the new ownership requirements under BI Reg. 10/2025.
Introduction of Core Concepts
With the issuance of BI Reg. 10/2025 and MBG Reg. 32/2025, BI has introduced the TIKMI framework – an assessment framework based on five core criteria: Transactions, Interconnection, Competence, Risk Management, and Information Technology Infrastructure.
The TIKMI framework serves as a reference for determining whether a PSSP is deemed a primary PSSP or a non-primary PSSP. The difference in classification, i.e., primary or non-primary, results in different compliance obligations and submission deadlines.
PSSPs are required to submit a TIKMI self-assessment on 1 February and 1 August of each year, starting from 2027. Based on the self-assessment and BI’s evaluation, the final TIKMI classification will be issued by BI in March and September of each year, starting in 2027.
Regulatory Transition
Although BI Reg. 10/2025 and MBG Reg. 32/2025 revoke the prior regulations, BI Reg. 10/2025 expressly preserves the continued applicability of BI Reg. 23/6, BI Reg. 23/7, and BI Regulation No. 23/11/PBI/2021 regarding National Payment System Standards, to the extent that their provisions do not conflict with BI Reg. 10/2025 or MBG Reg. 32/2025.
Accordingly, business actors in the payment system sector must consider both the provisions that remain in force and those that have been amended under the new regulatory framework.
While MBG Reg. 32/2025 provides more detailed technical guidelines for the implementation of BI Reg. 10/2025, additional implementing provisions will be issued separately through subsequent regulations, decrees, or official publications on BI’s website or other designated media.
These forthcoming implementing measures are expected to cover, among others, the determination of pricing schemes; technical guidelines on the TIKMI assessment mechanism and self-assessment procedures; and technical guidelines on the form and details of licensing document requirements for licensing as a PSP or designation as a PSIP.
Conclusion
Collectively, BI Reg. 10/2025 and MBG Reg. 32/2025 reflect BI’s commitment to further integrate and strengthen Indonesia’s payment system regulatory framework. The new regime introduces a more consolidated classification of service providers, mandatory registration, and clearer thresholds.
Payment system actors should therefore carefully assess both the transitional obligations and the forthcoming implementing measures to ensure continued regulatory compliance. (19 February 2026)
