27 Mar 2026
Decoding the Future of Indonesian Payments: From Primary PSPs to Critical Supporters

Bank Indonesia (“BI”) has issued Bank Indonesia Regulation No. 10 of 2025 on Payment System Industry Regulation (“Regulation 10/2025”), replacing the previous framework under Bank Indonesia Regulation No. 22/23/PBI/2020 on Payment Systems. The new regulation will come into force on 31 March 2026 and introduces a significant restructuring of Indonesia’s payment system regulatory landscape. BI has also enacted Regulation of the Members of the Board of Governors No. 32 of 2025 on Payment System Industry Regulation as the implementing provisions for Regulation 10/2025. 

This reform marks a decisive shift from an entity-based classification model of Payment Service Providers (“PSP”) toward a risk-based and activity-based via a specific scoring framework, aligned with the Indonesia Payment System Blueprint 2030. The new regime recalibrates licensing structure, systemic classification, capital requirements, governance expectations, and regulatory oversight intensity across the payment ecosystem.

Key highlights that were never addressed in the previous regulation include:

1. Introduction of the Transaction, Interconnections, Competencies, Risk Management, and Information Technology (“TIKMI”)assessment framework used by BI;

2. PSP Reclassification into primary PSP and non-primary PSP;

3. The scope of PSP which refers to the following business actors:

• Payment Service Providers (Penyedia Jasa Pembayaran or “PJP”) which constitute PSPs that provide services to facilitate payment transactions to service users; 

• Payment System Infrastructure Provider (Penyelenggara Infrastruktur Sistem Pembayaran or “PIP”) which constitute PSPs that provide infrastructure to facilitate the transfer of funds for the benefit of its participants; and

• commercial banks, to the extent they conduct payment system activities (without requiring a separate PSP licence).

4. Revised activity bundling regime for PJP;

5. Mandatory submission of Strategic Business Plans (“SBP”) and Payment System Business Plans (Rencana Bisnis Sistem Pembayaran or “RBSP”) between 31 March 2026 and 30 April 2026; and

6. Strengthened capital adequacy requirements.

This reform aligns with the objectives of the Indonesia Payment System Blueprint 2030, which aims to enhance resilience, consolidation, and systemic stability within Indonesia’s payment ecosystem.

Introduction of the TIKMI Framework

A central innovation under Regulation 10/2025 is the formal adoption of a standardized performance assessment metric known as TIKMI, which will serve as a mandatory supervisory reference throughout the lifecycle of a PSP (licensing, classification, supervision, and termination). This classification therefore directly influences a provider's approved activity bundle and the level of regulatory supervision.

BI will assess PSPs based on five core “TIKMI” criteria, which is an acronym for:

1. Transactions (Transaksi)  – Volume and nominal value of payment transactions.

2. Interconnectivity (Interkoneksi) – Level of integration between PSP and (i) BI infrastructure; (ii) PSP peers; (iii) PSP affiliates; and (iv) external partners.

3. Competency (Kompetensi) – Adequacy and capability of human resources relative to operational complexity.

4. Risk Management (Manajemen Risiko) – Effectiveness of mitigation frameworks covering operational, liquidity, and legal risks.

5. IT Infrastructure (Infrastruktur Teknologi Informasi) – System reliability, cybersecurity maturity, and data protection safeguards.

It is important to clarify that TIKMI is not a separate licensing regime, but is an assessment framework used by BI across licensing/designation and oversight processes. TIKMI functions as:

• a classification tool used by BI in determining whether a PSP is classified as primary PSP or non-primary (based on TIKMI assessment results and/or other criteria applied by BI);

• a reference point for BI’s supervision and supervisory follow‑up, including PSP obligations to conduct TIKMI self‑assessments and, where the applicable threshold is not met, to submit an action plan for TIKMI compliance;

• an assessment reference applied throughout the PSP lifecycle, as it is used by BI in licensing, designation, approvals, participation access, implementation/operation, supervision, and termination of payment system operations.

TIKMI therefore supports BI’s shift toward a risk- and impact-based supervisory model, replacing the former categorical framework under which PSP were designated as systemic, critical, or general.

All PSP must conduct self-assessments against TIKMI thresholds and submit remediation plans where deficiencies are identified. BI will independently conduct assessments, potentially involving third-party auditors. BI targets completion of initial classification determinations by 31 March 2027.

Reclassification of PSP: Primary vs Non-Primary and Legal Consequences

Under the previous regime, PSP were categorized as (a) Systemic PSP (Penyelenggara Sistem Pembayaran Sistemik or PSPS); (b) Critical PSP (Penyelenggara Sistem Pembayaran Kritikal or PSPK); and (c) General PSP (Penyelenggara Sistem Pembayaran Umum or PSPU).

Regulation 10/2025 simplifies this structure into:

1. Primary PSP – PSP whose failure could trigger systemic or operational disruption across the financial system due to its size, interconnectedness, and complexity.

2. Non-primary PSP – All other PSP.

This reclassification reflects a more risk-based and systemic impact-oriented supervisory model.

A PSP may be designated as a Primary PSP where its TIKMI assessment demonstrates: 

• transaction amounts and volumes processed, 

• degree of interconnection (including number of connections and/or payment transaction connectivity), 

• competency (including fulfillment of required human‑resource qualifications), and

• risk management and IT infrastructure reliability/security (including cyber resilience). 

The classification reflects BI’s assessment across TIKMI components and may also take into account other criteria used by BI (including size, interconnectedness, complexity, and substitutability).

Revised Licensing and Activity Bundling

Regulation 10/2025 shifts toward an activity-based and modular licensing model, whereby each PJP license reflects specific approved activity bundles and expansion into new activities requires regulatory approval and alignment with the PSP’s approved business plan.

The regulation also restructures activity bundling for PJP to become as follows.

This restructuring introduces clearer activity demarcation and aligns operational scope with systemic importance.

New Business Planning Obligations

PSPs are required to submit the SBP and RBSP within the designated initial submission period from 31 March 2026 to 30 April 2026. The SBP is a written document setting out the strategic business activity plan and development plan in the payment system for the medium term, including the strategies to implement such plans. Meanwhile, RBSP is a written document outlining the short-term business activity plan and development plan in the payment system, the strategies for their implementation, and the realization of the business activity and development plans in the preceding year.

RBSP will function as the primary operational reference for PSP activities, and thus it requires explicit BI approval. Such amendments are limited to once per year and require prior BI approval, along with its reasons or explanations. 

Strengthened Capital Requirements

Regulation 10/2025 introduces a structured dual capital framework which distinguishes between: (i) Initial Paid-Up Capital (minimum capital at licensing stage); and (ii) Ongoing Capital Requirement (maintained capital calibrated to operational risk exposure).

This risk-weighted capital model mirrors prudential regulatory approaches in other financial sectors and reinforces systemic resilience.

Supporting Organizers

In addition to reforming PSP licensing and capital standards, Regulation 10/2025 significantly enhances regulatory oversight of third parties that support payment system operations.

Under the previous regulation, supporting organizers (penyelenggara penunjang) were not subject to close supervision by BI. However, under Regulation 10/2025, supporting organizers are subject to classification as critical supporting organizers, important supporting organizers, or standard supporting organizers. 

Previously, there was no requirement for the supporting organizers to register with BI, but now this obligation has been introduced and imposed on the critical and important supporting organizers. Mandatory registration must be completed by submitting a formal application to BI and should be accompanied by documentation demonstrating compliance with the minimum requirements related to human resources, operational processes, and technology. The mandatory registration of critical and important supporting organizers must be carried out no later than 3 (three) years after Regulation 10/2025 comes into force.

The regulation also provides the minimum required provisions that must be stipulated under the cooperation agreement between the PSPs and the supporting organizers. Such minimum provisions consist of the (a) scope of cooperation (including outsourced functions); (b) rights and obligations; (c) time period; (d) security and confidentiality; (e) service level agreement for the implementation of cooperation; (f) monitoring of cooperation; (g) availability of access to BI supervision; (h) choice of law; (i.) dispute resolution; and (j) changes and termination of cooperation.

Supporting organizers are now subject to administrative sanctions that did not exist under the previous regulations. These sanctions can take the form of a written reprimand, prohibition or restriction on cooperation with PSPs, and/or removal of the supporting organizers from the BI register.

ABNR Commentary

Regulation 10/2025 represents more than a technical amendment to the existing framework. It constitutes a structural regulatory tightening and structural recalibration of Indonesia’s payment system industry. Industry participants should:

• conduct early TIKMI gap assessments;

• review activity bundling eligibility under the new regime;

• prepare capital adequacy recalculations;

• begin drafting SBP and RBSP well in advance of the April 2026 deadline;

• assess whether their systemic footprint may result in designation as a primary PSP.

• conduct registration of critical and important supporting organizers to BI;

• adjust the cooperation agreement with the supporting organizers to meet the minimum requirements stipulated under the regulation. 

This reformation signals BI’s clear policy direction toward a more resilient, integrated, and prudentially supervised payment ecosystem.

The new framework is likely to affect market participants in differentiated ways. For large, technology-driven PSP, particularly those operating super-app or ecosystem models, migration toward Primary PSP classification may be commercially inevitable, resulting in increased capital commitments, heightened governance expectations, and the need to integrate regulatory considerations earlier into product development cycles. Mid-sized or niche operators may initially benefit from the proportionality afforded by the non-primary tier, however, their growth strategies must account for the possibility of reclassification as transaction volume, interconnection, and systemic footprint expand. Smaller or undercapitalised players may face more immediate pressure from recalibrated capital and governance requirements, potentially accelerating consolidation, strategic partnerships, or capital restructuring. In this respect, the reform may indirectly catalyse broader industry rationalisation within Indonesia’s payment ecosystem.

TL;DR: 

By partners Chandrawati Dewi (cdewi@abnrlaw.com), Monic Devina (mdevina@abnrlaw.com) Meitiara Bakrie (dbakrie@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.