Indonesia streamlines fit and proper assessment of FinTech and digital finance stakeholders

27 October 2025

On 1 October 2025, Indonesia’s Financial Services Authority Regulation No. 16 of 2025 on Fit and Proper Assessment and Reassessment for Key Stakeholders in FinTech Innovation, Finance, and Digital Financial and Crypto Assets (“Regulation”) came into effect.

Issued by the Financial Services Authority (Otoritas Jasa Keuangan “OJK”) on 20 June 2025, the Regulation consolidates and streamlines OJK’s fit and proper assessment framework for key stakeholders across the FinTech and digital finance sectors. It also revokes the provisions on fit and proper requirements set out in the following OJK regulations:

  • Regulation No. 27 of 2024 on Trading in Digital Financial Assets, Including Crypto Assets;
  • Regulation No. 29 of 2024 on Alternative Credit Scoring; and
  • Regulation No. 4 of 2025 on Financial Aggregators.

The Regulation applies to all entities providing FinTech innovation, digital financial asset, and crypto asset services (“Providers”) and provides that their key controlling stakeholders and key managing stakeholders must meet the fit and proper criteria as set out in the Regulation. The term “key controlling stakeholders” refers to a Provider’s controlling shareholders, while “key managing stakeholders” refers to members of the Provider’s board of directors and board of commissioners (collectively, “Key Stakeholders”). No person may act as a Key Stakeholder without prior OJK approval, even if they already hold shares or have been appointed by shareholders in a general meeting.

Assessment process

Prospective key controlling stakeholders must demonstrate integrity and financial viability in order to be assessed as fit and proper. In turn, prospective key managing stakeholders must demonstrate integrity, financial reputation, and competence as described in the table below.

Criteria

Requirements

Integrity

·         Ability to perform legal acts;

·         Commitment to complying with laws and regulations (including those on consumer protection and anti-fraud legislation) and supportive of OJK policies; and

·         Not prohibited from becoming a Key Stakeholder in financial services institutions and/or Providers.

Financial viability

·         Capable of supporting, financially and otherwise, the development of the Provider’s business; and

·         Committed to taking necessary measures should the Provider experience financial difficulties.

Financial reputation

·         No history of bad credit and/or financing;

·         Never having been declared bankrupt; and

·         Not having been a shareholder, director, or commissioner found guilty of causing a company to be declared bankrupt within the five years prior to nomination.

Competence

·         Knowledge and/or experience in fields relevant to the position; and

·         Ability to strategically manage and develop the Provider.


Providers must obtain OJK’s approval for prospective Key Stakeholders before any appointment. Applications must be submitted electronically via https://sprint.ojk.go.id and be accompanied by the required administrative documents, including a copy of the individual’s identity card and curriculum vitae or, in the case of legal entities, constitutional documents and the latest financial statements.

Where a Provider is applying for a business licence, the application for OJK approval must be submitted by its prospective owner, founder, or director. For Providers that have already obtained a business licence, the application must be submitted by a director.

Prospective Key Stakeholders may not be nominated for the fit and proper assessment process where:

  • they are currently undergoing legal proceedings;
  • a fit and proper assessment is already underway at OJK; and/or
  • a reassessment relating to integrity, financial viability, financial reputation, and/or competence is in progress.

OJK will provide the results of its assessment within 30 working days of receiving the complete application documents.

Reassessment process

OJK may conduct a reassessment of Key Stakeholders, including those who no longer own, manage, supervise, or otherwise exercise influence over Providers. The reassessment may be carried out online and/or offline, depending on OJK’s considerations.

A reassessment is conducted where a Key Stakeholder has been proven to have committed a criminal offence by a legally binding court decision. The same applies where the individual has a record of non-performing credit or financing with a financial services institution, or has been declared bankrupt. This provision also extends to shareholders, directors, or commissioners who have been found guilty of causing a company to be declared bankrupt or to have its business licence revoked.

OJK conducts a reassessment based on information obtained through supervision or from other sources. Key Stakeholders may be required to provide clarification on information as part of the reassessment process.

OJK determines the outcome of the reassessment by issuing a pass or fail rating, together with written notification to key controlling stakeholders, Providers, and the reassessed Key Stakeholders. OJK will further stipulate the detailed procedures and requirements governing the reassessment results.

Transitional policies

Fit and proper assessment or reassessment results issued by OJK or the supervisory agency for digital financial asset platforms before 1 October 2025 remain valid. Applications that were submitted but had not yet received a result by that date will be processed by OJK in accordance with the requirements set out in Regulation 16 of 2025.