Bank Indonesia’s Sweeping Payment System Overhaul Takes Effect March 31 As Industry Faces First Compliance Deadlines

Spotlight

Bank Indonesia’s most comprehensive restructuring of the country’s payment system regulatory framework in years takes effect on March 31, 2026, requiring all payment system service providers operating in Indonesia to operate under a new licensing, classification, and assessment architecture. The regulation introduces mandatory business planning submissions, a new performance assessment framework, and a simplified provider classification structure that collectively redefine how the central bank supervises and approves payment system activity across the country.

Key Facts At A Glance

  • Bank Indonesia Regulation No. 10 of 2025 (PBI 10/2025) takes effect March 31, 2026
  • Companion rule Members of the Board of Governors Regulation No. 32 of 2025 (PADG 32/2025) takes effect on the same date
  • New TIKMI framework assesses providers across five dimensions: Transaction, Interconnection, Competence, Risk Management, and IT Infrastructure
  • All payment system service providers must submit their first Payment System Business Plan (RBSP) and Strategic Business Plan (SBP) to Bank Indonesia by April 30, 2026
  • PSP classification simplified from three tiers (Systemic, Critical, General) to two: Primary and Non-Primary
  • Bank Indonesia will communicate initial TIKMI classification results to providers within one year of the effective date, by April 1, 2027
  • Providers not yet meeting requirements have up to three years from the effective date — until March 31, 2029 — to achieve compliance, with a possible two-year extension at Bank Indonesia’s discretion
  • Existing licenses are grandfathered under the new framework, provided there is no change in foreign ownership composition

Bank Indonesia’s Payment System Overhaul: What Changes On March 31

In December 2025, Bank Indonesia issued PBI 10/2025 alongside its implementing regulation PADG 32/2025, creating a single consolidated framework that brings together Indonesia’s entire payment ecosystem, covering service providers, infrastructure operators, and supporting partners, under one regulatory roof.

The regulation revokes Bank Indonesia Regulation No. 22/23/PBI/2020 on Payment Systems and amends provisions of Bank Indonesia Regulation No. 23/6/PBI/2021 on Payment Service Providers and Bank Indonesia Regulation No. 23/7/PBI/2021 on Payment Infrastructure Providers. Certain provisions of those earlier regulations remain in force to the extent they do not conflict with the new framework.

The previous regulatory landscape had been fragmented, with compliance requirements dispersed across multiple Bank Indonesia regulations. For providers operating across more than one payment function, this created overlapping ruleset challenges that the new framework is designed to eliminate.

The TIKMI Framework

Central to PBI 10/2025 is the introduction of TIKMI — an acronym for Transaksi (Transaction), Interkoneksi (Interconnection), Kompetensi (Competence), Manajemen Risiko (Risk Management), and Infrastruktur Teknologi Informasi (IT Infrastructure). TIKMI replaces the previous risk-categorisation model and functions as Bank Indonesia’s primary tool for evaluating the readiness and resilience of payment system service providers.

Under the new framework, providers classified as Primary Payment System Service Providers are assessed under TIKMI every six months, while Non-Primary providers are assessed annually. Bank Indonesia retains the authority to override any provider’s TIKMI self-assessment and issue its own determination. Providers are required to submit TIKMI self-assessments to Bank Indonesia on February 1 and August 1 of each year, beginning from 2027, with Bank Indonesia issuing final TIKMI classifications in March and September of each year from 2027 onward.

The TIKMI result directly informs licensing and authorisation decisions, provider classification, Payment System Business Plan review and approval, and Bank Indonesia’s assessment of proposed products, activities, and cooperation arrangements.

New Classification And Business Planning Requirements

PBI 10/2025 replaces the previous three-tier classification structure — Systemic, Critical, and General, with a two-tier model. Primary Payment System Service Providers are those whose size, interconnection level, and operational complexity are significant enough that disruption to their services could affect the broader payment or financial system. All other providers fall under the Non-Primary category.

All providers must now prepare and submit both an RBSP, a short-term business and development plan, and a Strategic Business Plan covering medium-term strategic direction in the payment system sector. The first submission deadline is April 30, 2026. The RBSP is not merely a planning document: under the new framework, it functions as the primary channel through which planned cooperation arrangements and business developments are presented to and approved by Bank Indonesia.

Under the prior framework, development activities and cooperation arrangements were assessed as low, medium, or high risk, with medium and high-risk actions requiring prior Bank Indonesia approval. The new framework requires planned cooperation to be incorporated into the RBSP before it can proceed, shifting the approval process into the business planning cycle.

Foreign Partnerships And Transitional Provisions

Foreign payment system providers are not directly subject to Indonesia’s licensing regime under PBI 10/2025. However, Indonesian-licensed providers seeking to partner with foreign counterparts must now conduct more rigorous TIKMI assessments and enhanced due diligence, with detailed contractual requirements relating to data access, system reliability, and support for anti-money laundering and counter-financing of terrorism compliance.

Existing license holders are preserved under a grandfathering clause, provided that the composition of foreign ownership in the licensed entity does not change. Bank Indonesia will evaluate all current Payment Service Provider and Payment Infrastructure Provider licenses to determine how their activities map to the new bundling structure and whether they fall under the Primary or Non-Primary classification, with results to be communicated within one year of March 31, 2026.

Providers and supporting entities that have not yet met the new requirements have up to three years from the effective date, until March 31, 2029, to achieve compliance. Bank Indonesia may grant an additional two-year extension at its discretion. Bank Indonesia’s own dissemination materials consistently reference certain one-year deadlines as falling on April 1 rather than March 31, a distinction the central bank has formalised in its official communications.

PBI 10/2025 also introduces new sanctioning powers, including the authority for Bank Indonesia to issue orders or recommendations for the dismissal or replacement of members of a provider’s board of directors, board of commissioners, shareholders, or executive officers in cases of non-compliance.

EDITORIAL RESEARCH NOTE
This report synthesises recent reporting and publicly available financial and regulatory information. The perspectives presented reflect neutral newsroom-style reporting.
SOURCES: bi.go.id, ahp.id, bakermckenzie.com, ssek.com, arma-law.com
PHOTO CREDIT: AI-Generated