Back in 2020, Bank Indonesia (“BI”) issued Regulation No. 22/23/PBI/2020 on Payment Systems (“Regulation 23/2020”), which is currently governing Indonesia’s Payment System (Sistem Pembayaran – “SP”) industry and helping to address the various challenges that are associated with digital innovation and complex business models. In this regard, Regulation 23/2020 was introduced in response to the rapid pace of digital innovation and the increasingly complex business models that characterize the SP industry and set out strict definitions for various SP components, specifically various mechanisms and types of infrastructure and institutions, as well as the management of funding sources and access to funds.[1]
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