04 Jun 2025
Unlocking the Future: A Deep Dive into OJK's New Financial Services Aggregation Regulations

The Financial Services Authority of the Republic of Indonesia (Otoritas Jasa Keuangan, “OJK”) has issued Regulation No. 4 of 2025 on Financial Services Aggregation Organizers (“POJK 4/2025”). The regulation aims to promote the development of financial products and services, enhance consumer protection, and manage risks associated with aggregation activities. 
 

Overview of Financial Services Aggregation Organizers

POJK 4/2025 defines financial services aggregation as the activity of collecting, filtering, and comparing information about financial products and services from various institutions in the financial sector. The goal is to help consumers evaluate and select products that best meet their needs by providing accessible comparisons. Aggregators also serve as a bridge between financial institutions and potential customers.

The regulation introduces the term Financial Services Aggregation Organizers (Penyelenggara Agregasi Jasa Keuangan or “PAJK”) to refer to entities operating under this model. PAJKs may aggregate a wide range of financial products and services, including:

• Fund collection: savings, deposits, and current accounts;

• Fund distribution: credit, financing, and loans; and

• Other OJK-approved offerings, such as capital market products, derivatives, carbon trading, insurance, guarantees, pension funds, financing companies, venture capital firms, and microfinance institutions.

General Licensing Requirements

Aggregators are subject to licensing and institutional requirements set by OJK, in line with those applied to other regulated financial services institutions. Key requirements include:

• The PAJK must be a limited-liability company with a minimum paid-up capital of IDR 500,000,000 (five hundred million Rupiah);

• Capital must not be sourced from money laundering, terrorism financing, loans, or any illegal activity;

• Foreign ownership—direct and indirect—is permitted up to a maximum of 85% of paid-up capital;

• The company must have at least two directors and one commissioner;

• Controlling shareholders and board members must pass a fit and proper test conducted by OJK;

• PAJKs must implement anti-money laundering (AML), counter-terrorism financing (CTF), and anti-proliferation measures, as well as an anti-fraud strategy.

License applications must be submitted to the OJK Department of Technological Innovation in the Financial Sector, Digital Financial Assets, and Crypto Assets.

Aggregation activities conducted by entities already supervised under other OJK regimes—such as banks, insurers, and capital market intermediaries—are excluded from the scope of PAJK. This includes in-house marketing platforms, such as websites or mobile apps used by banks, insurance brokers, or mutual fund agents.

IT Requirements

POJK 4/2025 requires aggregation activities to be conducted through an electronic system, accessible via a website or device-based application. Given the digital nature of PAJK operations, the regulation places strong emphasis on IT governance.

PAJKs must:

• Own and control their electronic systems;

• Ensure the system’s reliability and data security;

• Register as a Private Electronic System Organizer (Penyelenggara Sistem Elektronik or “PSE”) within 30 days of obtaining their PAJK license; and

• Obtain the PSE certificate within 60 days of licensing.

If OJK determines that the proposed business activity does not fall within the PAJK scope but meets the innovation criteria under OJK Regulation No. 3 of 2024 on Technological Innovation in the Financial Sector, the entity may be required to enter the regulatory sandbox.

Cooperation Obligations

PAJKs must enter into written cooperation agreements with financial institutions and other relevant parties. These agreements must ensure that:

• The aggregated products and services are licensed by OJK;

• They are eligible for digital marketing; and

• They are not subject to OJK sanctions.

Consumer Engagement

Through their digital platforms, PAJKs provide services to consumers and financial institutions by:

• Forwarding consumer data to financial service providers and related parties;

• Distributing financial products and services to consumers; and

• Managing documents related to these products and services.

PAJKs must clearly inform consumers that their role is limited to aggregating and presenting information. They are not responsible for the financial products or services offered by the institutions featured on their platforms.
 

Prohibitions

PAJKs are expressly prohibited from conducting fund collection, distribution, storage, or management activities. They must also refrain from:

• Creating unfair competition;

• Copying or publishing content without the consent of financial institutions;

• Providing misleading information;

• Promising investment returns;

• Accepting power of attorney to conduct transactions on behalf of consumers; and

• Leaking or misusing personal data.

Transitional Provisions

Aggregators, financing agents, funding agents, and wealth-tech organizers that passed the sandbox or were registered with OJK prior to POJK 4/2025 must apply for a PAJK license within 12 months of the regulation’s promulgation. Failure to do so will result in the business being considered unlicensed.

Entities with pre-existing registered status are temporarily exempt from foreign shareholding restrictions but must comply with the 85% cap within one year of obtaining their PAJK license.
 

Enforceability

POJK 4/2025 came into effect on its date of promulgation: February 26, 2025.

By partner Ayik C. Gunadi (agunadi@abnrlaw.com) and associate Ruth Mendrofa (rmendrofa@abnrlaw.com)

This ABNR News and its contents are intended solely to provide a general overview, for informational purposes, of selected recent developments in Indonesian law. They do not constitute legal advice and should not be relied upon as such. Accordingly, ABNR accepts no liability of any kind in respect of any statement, opinion, view, error, or omission that may be contained in this legal update. In all circumstances, you are strongly advised to consult a licensed Indonesian legal practitioner before taking any action that could adversely affect your rights and obligations under Indonesian law.