Bank Indonesia (“BI“) has officially issued BI Regulation Number 10 of 2025 on the Regulation of the Payment System Industry (“PBI 10/2025“). As a derivative of the Indonesia Payment System Blueprint 2030 (“BSPI 2030”), this regulation is designed to strengthen the structure of the payment system industry and risk management to make it more consolidative and resilient. This regulation is effective on 31 March 2026, officially revoking the previous regime, namely BI Regulation No. 22/23/PBI/2020 on the Payment System. PBI 10/2025 marks a shift in BI’s supervision, which is now significantly more stringent, structured, and risk based. As its main foundation, BI introduces the TIKMI criteria (Transaction, Interconnection, Competence, Risk Management, and Information Technology Infrastructure), which are applied end-to-end, from the licensing process and product development approval to ongoing supervision. Through these criteria, PBI 10/2025 simplifies Payment System Service Providers (“PSP“) into two categories: major PSPs which have a systemic impact and could potentially cause a payment system failure if disrupted and non-major PSPs.
In line with this classification, the activities of Payment Service Providers (“PJP“), the PBI 10/2025 also introduces the revamped version of three classifications to the categorization previously stipulated under the prior regulations, which consist of the following:
1. Package 1
a. Fund management administration includes:
i. Administration of payment accounts (payment account); and
ii. Issuance and/or provision of access to Source of Funds.
b. The forwarding of payment transactions, including:
i. Forwarding of payment transaction data and payment order forwarding which may be accompanied by facilitation of payment result fund receipt through provision of sub-accounts to Goods and/or Services Providers; and
ii. Forwarding of digital and non-digital fund transfer orders
Package 1 is divided into two subcategories: Package 1A, which is exclusively designated for operation by major PSPs, and Package 1B, which is reserved solely for non-major PSPs.
2. Package 2 (Operated by Non-Major PSPs)
a. forwarding of payment transaction data and payment order forwarding which may be accompanied by facilitation of payment result fund receipt; and
b. forwarding of digital and non-digital fund transfer orders.
3. Package 3 (Operated by Non-Major PSPs)
Authorizes payment transaction forwarding activities specifically non-digital fund transfer order forwarding.
Furthermore, BI classifies Supporting Providers into three tiers: Critical, Significant, and Standard. Critical and Significant Supporting Providers must officially register with BI no later than three years after the PBI 10/2025 takes effect. From a financial perspective, BI now mandates a dynamic capital system. PJPs and Payment System Infrastructure Providers (“PIP”) must maintain a minimum capital adequacy ratio of 10% of risk-weighted transactions, plus a surcharge of 1.5% – 2.5% for PJPs and 2.5% – 5% for PIPs.
To maintain market structure and prevent monopolistic practices, this regulation imposes very strict boundaries regarding corporate actions such as mergers and acquisitions. PJPs or PIPs in the form of Non-Bank Institutions (“LSB”) are prohibited from conducting corporate actions that change the controlling party, or change parties owning 25% or more of the shares, during the first five years since the license or designation is first granted. In addition, no party is allowed to own 25% of shares or act as a controller in more than one LSB with PJP status engaging in similar activities, a prohibition that also applies to simultaneous dual ownership in a PJP and a PIP. In terms of administrative compliance, reporting obligations are now segmented, PSPs are required to prepare medium-term projections through a Strategic Business Plan and annual tactical plans through a Payment System Business Plan, with the first submission due no later than 30 April 2026. For those holding existing licenses, their status will remain valid with a maximum adjustment period of three years (extendable by two years) to meet the new requirements, including an exemption from ownership limits provided there is no change in composition.
Operationalization through PADG 32/2025
To bridge this structural vision with day-to-day operational compliance, this regulatory architecture requires robust technical guidance. In its effort to modernize and strengthen the national payment landscape, BI introduced BSPI 2030 with a clear emphasis on institutional restructuring and regulatory refinement. The issuance of the Board of Governors Regulation Number 32 of 2025 (“PADG 32/2025”) marks the moment when this regulatory architecture is translated into concrete action. While PBI 10/2025 lays out the structural vision to reform the industry, PADG 32/2025 provides the operational grammar that enables this vision to be realized, which consist of the following technical and practical implementations:
1. Risk-Based Supervision (TIKMI)
While PBI 10/2025 establishes TIKMI as the foundation for risk-based supervision, Article 63 PADG 32/2025 operationalizes it by introducing clear evaluation criteria, structured review cycles, and defined supervisory actions, thereby transforming a general concept into a functional system.
2. PSP Classification
While PBI 10/2025 introduces the classification of PSPs into Major and Non-Major categories, Article 80 PADG 32/2025 clarifies how this classification is applied in practice through clear designation procedures, periodic reviews, and adjustments based on risk levels.
3. Licensing Controls
While PBI 10/2025 requires approval for new activities or business expansions, Article 68 of PADG 32/2025 simplifies this by setting out clear procedures, required documents, and defined timelines for the approval process.
4. Business Plans
While PBI 10/2025 requires PSPs to submit business plans, Article 71 PADG 32/2025 strengthens their role by requiring forward-looking risk projections and linking them to expansion approvals.
5. Data Governance
While PBI 10/2025 sets general reporting obligations, Article 206 PADG 32/2025 makes them more practical by defining what data must be reported, how it should be submitted, and when.
6. Regulatory Testing (Sandbox)
While PBI 10/2025 provides the overall supervisory framework, Article 50 PADG 32/2025 supports innovation by introducing a controlled sandbox mechanism with clear limits and risk safeguards.
Building on the framework established by PBI 10/2025, PADG 32/2025 operates as its practical extension by translating broad regulatory principles into clear and structured procedures. It introduces the technical detail needed to guide implementation and reduce uncertainty in application. This ensures that supervisory objectives are supported by consistent and enforceable mechanisms. As a result, what was initially a high-level regulatory vision becomes a system that can be effectively executed in practice.
Written by: Zuhesti Prihadini Muhamad Destianto, Nadira Karisma Ramadanti, and Afanin Fariq
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