Indonesia’s first standalone framework for financial aggregators in effect

14 May 2025

Indonesia Financial Services Authority (Otoritas Jasa Keuangan (“OJK”)) Regulation No. 4 of 2025 on Financial Aggregators (“Regulation No. 4”) came into effect on 26 February 2025. Regulation No. 4 is mandated by Financial Law No. 4 of 2023 (“Financial Law”) to support financial markets by optimising the products and services offered by financial services institutions and/or parties operating in the financial services sector (collectively, “FSIs”), including other entities engaged in financial services activities, in their utilisation of technology in expanding financial inclusion.

Financial aggregators were regulated for the first time with the enactment of the Financial Law on 12 January 2023. They fall under the financial technology innovation framework, which is governed by OJK Regulation No. 3 of 2024 on the Implementation of Financial Technology Innovation. Regulation No. 4 on financial aggregators is unprecedented and does not replace any existing regulations.

This article provides an overview of the key provisions of Regulation No. 4.

Financial aggregators

A financial aggregator (“FA”) is an entity that conducts aggregation activities through electronic systems by using the internet, including financing agents, funding agents, and wealthtech companies. Aggregation activities include collecting, filtering, and/or comparing information about financial products and services offered by FSIs. Aggregation activities also include displaying information about financial products and/or services, offering options to consumers, transmitting information about potential consumers to FSIs, distributing financial products and/or services to consumers, and/or managing documents related to financial products and/or services on behalf of consumers and FSIs. FAs may conduct aggregation activities in accordance with Syariah principles.

FAs may offer special products and/or services in cooperation with FSIs, such as creating value-added products and/or services for consumers and co-branding FSI products with FAs.

FAs may also conduct other business activities after obtaining prior approval from OJK, such as:

  • the provision of products and/or services that involve reciprocal interactions between FAs, FSIs, consumers, and other third parties; and
  • the aggregation of bill payment services provided by payment service companies registered with the competent authority.

FAs may aggregate financial products and/or services in the form of:

  • fundraising activities, including savings, deposits, and giro (current accounts);
  • fund distribution activities, including credit, financing, and loans; and/or
  • other financial products and/or services that have been approved by OJK, including those in the capital market sector, derivative finance, carbon exchanges, insurance, guarantees, pension funds, financing institutions, venture capital companies, microfinance institutions, and other FSIs.

Requirements to establish an FA

Form and paid-up capital

An FA must be established as a limited liability company with a minimum paid-up capital of IDR500,000,000 (approximately S$39,000). However, OJK has the authority to determine a paid-up capital amount for an FA that differs from the prescribed amount, based on specific considerations, including, but not limited to, the establishment of an FA as a result of the consolidation of FAs or adjustments to the paid-up capital to strengthen or improve the operations of an FA. This capital must be fully paid in cash and deposited in the name of the FA with a commercial bank, Sharia commercial bank, or the Sharia business unit of a commercial bank in Indonesia.

Ownership

An FA can be owned by an Indonesian citizen and/or legal entity or by a foreign citizen and/or legal entity. Foreign citizens and/or foreign legal entities must not hold more than 85% of the FA’s paid-up capital. This restriction does not apply to FAs that are public companies whose shares are traded on the stock exchange.

Directors

An FA must have a board of directors with at least two members and a board of commissioners with at least one member. At least one director must have knowledge and/or experience in aggregation activities, the information technology industry, and/or an FSI. This knowledge and/or experience shall be proven by a certificate or by at least three years of relevant professional experience in the industry. The certificate must be issued by a credible or accountable body, institution, or association (“Designated Providers”), such as those that award certifications like Certified Information Systems Security Professional (CISSP), Certified Information Security Manager (CISM), Certified Information Systems Auditor (CISA), and Certified Data Privacy Solutions Engineer (CDPSE).

An FA may employ foreigners for a term of office of no more than three years. Foreigners are allowed to hold positions one level below directors and/or serve as experts or consultants. The FA must assign an Indonesian worker to accompany the foreign employee and facilitate the transfer of technology and/or skills to the former through education or vocational training. Foreigners may not be employed in human resources or compliance functions. An FA that employs foreigners is required to submit a report to OJK at least five working days before the relevant employee commences their employment, with supporting documents as stated in Regulation No. 4.

Licences

Applications for an FA business licence must be submitted via the OJK licensing system at https://sprint.ojk.go.id. OJK shall issue its decision on the application no more than 20 business days after receiving the complete application.

Once an FA has obtained a business licence from OJK, it must then apply for registration as an electronic service provider (“ESP”) from the authorised agency no later than 30 calendar days from the date of issuance of its business licence. An FA must be registered as an ESP before conducting aggregation business activities. A copy of the registration application must be submitted to OJK at the same time as it is submitted to the authorised agency.

The ESP registration certification must be provided to OJK no later than seven working days from its issuance. The FA must commence its business activities no later than 30 calendar days from the date of ESP registration.

Platform-based aggregation requirements

Aggregation should be implemented via websites and/or device-based applications that are accessible to consumers and which display aggregated and/or compared financial products and/or services, along with related information, terms and conditions, privacy policies, and consumer service details. Data centres and disaster recovery centres must be in Indonesia.

An FA must own, possess, and control its electronic system but is able to utilise third party services for support functions, such as maintaining system reliability, data management, security, help desk services, and consumer complaint handling.

Cooperation

An FA must cooperate with FSIs to perform aggregation and formalise such cooperation in a written agreement (“Agreement”). The FA is responsible for all aggregation activities under the Agreement and are required to disclose to consumers that they act solely as aggregators and are not responsible for the financial products and/or services provided by the FSIs. FAs are required to ensure the reliability and security of the electronic systems they use.

FAs may cooperate with more than one FSI of the same type, such as two banks offering deposit products. An FA may also cooperate with other parties such as payment service providers for payment system integration or alternative credit rating agencies to assist in creditworthiness assessments.

FAs must also provide OJK with access to supervise their aggregation activities.

Prohibitions

FAs are prohibited from, among other things:

  • engaging in activities related to fundraising, fund distribution, fund storage, and/or consumer fund management, except for receiving and routing transactions to partners through payment service providers;
  • providing aggregation services in the form of a user-generated content platform, i.e. offering information on financial products and/or services submitted by consumers without conducting curation or due diligence;
  • copying content, such as crawling or scraping data, from websites and/or device-based applications owned by FSIs without their consent; and
  • obtaining a power of attorney from consumers to conduct transactions.

Reporting

Regulation No. 4 mandates a reporting framework for FAs, stipulating that the following must be submitted to OJK:

  • Periodic reports, that is, semi-annual and annual reports, the contents of which are specified in Regulation No. 4 and further detailed in OJK Circular No. 4/SEOJK.07/2025, which provides guidance for such reporting; and
  • Incidental reports, including reports on changes in business activities, fraud, instances of force majeure, legal disputes, or cyberattacks.

OJK may request other reports be provided, such as a report on the maturity assessment of the FA’s platform.

Transitional policies

FAs that have passed the sandbox test phase or were registered with OJK before 26 February 2025 must apply for a business licence under Regulation No. 4 no later than 26 February 2026. Failure to do so will result in the FA being deemed as operating without a licence whereupon it must cease its business activities and settle consumer obligations no later than six months after being declared unlicenced and unsupervised by OJK. The sandbox participant pass certificate or proof of registration certificate will be invalid once the FA has obtained a business licence.

FAs that (1) have obtained registered status, (2) been in operation before 26 February 2025, and (3) are conducting activities outside aggregation activities are able to operate such additional activities without the need for further OJK approval. However, they must submit data and information regarding such additional activities when applying for a business licence.

FAs that have obtained registered status before 26 February 2025 must also adjust their foreign ownership to comply with the requirements of Regulation No. 4 within one year of receiving their business licence from OJK.

Any party that has carried on FA business prior to 26 February 2025 must apply for a business licence in accordance with Regulation No. 4 no later than 26 February 2026.

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