The Financial Services Authority (Otoritas Jasa Keuangan "OJK") has now permitted financing companies and sharia financing companies (collectively referred to as "Companies") to organize digital sharia financing services, including so-called Buy Now Pay Later ("BNPL") services. In this regard, financing companies utilize BNPL for multipurpose financing, while sharia financing companies utilize it for sale and purchase financing.

Regulation of the Financial Services Authority (Otoritas Jasa Keuangan "OJK") No. 3 of 2025 on the Implementation of Professional Certification Institutions Within the Financial Services Sector ("Regulation 3/2025") strengthens the governance of Professional Certification Institutions (Lembaga Sertifikasi Profesi "LSP") that deal with finance. This new framework requires LSP to bring their various certification schemes into line with Indonesian National Work Competency Standards (Standar Kompetensi Kerja Nasional Indonesia SKKNI) and the Indonesian National Qualifications Framework (Kerangka Kualifikasi Nasional Indonesia KKNI), requiring them to be updated within six months of any changes being introduced.

The Financial Services Authority (Otoritas Jasa Keuangan/OJK) is currently drawing up a Draft Circular ("Draft Circular") which, when it ultimately comes into force, will serve as an implementing Regulation on the organization of information technology-based joint funding services (layanan pendanaan bersama berbasis teknologi informasi "P2P Lending") within Indonesia. Among the various provisions set out therein, the Draft Circular specifies that P2P lending funders and recipients of funds must be at least 18 years of age or legally married. In addition, P2P Lending organizers must adhere to the maximum prescribed economic benefits rate when facilitating any funding, which encompasses interest, margin, profit sharing and other applicable fees and charges.

The new framework now stipulates that registration statement for a public offering becomes effective on the 20th business day after its complete submission or earlier if the OJK declares its effectiveness sooner. After the registration statement becomes effective, the Initial Offering Period must be last at least three business days and no longer than 20 business days. This period may commence after OJK grants approval for the Issuer to proceed with the Initial Offering and after the Issuer has completed the necessary upload and announcement of relevant documents.

The Financial Services Authority (Otoritas Jasa Keuangan "OJK") has now officially assumed responsibility for the regulation and supervision of financial derivatives through the enactment of Regulation No. 1 of 2025 on Financial Derivatives with Underlying Assets in the Form of Securities ("Regulation 1/2025"). This move marks a significant shift away from the Commodity Futures Trading Supervisory Agency (Badan Pengawas Perdagangan Berjangka Komoditi "Bappebti"), which was previously responsible for this area. Ushering in a two-year transition period for relevant parties to bring their operations into line with the so-called same activity, same risk, same regulation principle, participants in the derivatives market must seek OJK approvals prior to May 2025 and may be subject to the imposition of penalties for any failure to meet relevant deadlines or if they engage in any unauthorized contracts.

Transitional provisions should ensure continuity as authority shifts from the Commodity Futures Trading Regulatory Agency (Badan Pengawas Perdagangan Berjangka Komoditi "Bappebti") to the Financial Services Authority (Otoritas Jasa Keuangan "OJK"). All existing licenses, approvals and registrations issued by Bappebti will remain valid, while pending applications will continue to be processed by the OJK. Moreover, organizers must secure OJK approvals for any previously unapproved activities within one month of enforcement of the new framework. It should be noted that the existing traded asset lists and anti-money laundering, combating the financing of terrorism and counter-proliferation ("AML, CFT and CPF") programs will also remain in effect until the new OJK Regulation is fully implemented, hopefully ensuring a seamless transition and regulatory alignment.

The scope of permissible business activities for commercial banks and sharia banks has broadened significantly under the new regulations, specifically in terms of equity investments. Said banks are now allowed to participate in equity in any company or institution that supports the banking sector, including: 1) Companies that use information technology (IT) in order to produce financial products; 2) Companies that primarily support banking business operations; 3) Companies with business characteristics that support the banking industry; 4) Companies located outside Indonesia.

The Draft Regulation has now expanded the list of supporting professions that are permitted to operate within the financial sector ("Supporting Professionals"). Said professions will soon include: 1) Practicing accountants; 2) Sharia financial services experts ("Sharia Experts"); and 3) Other professions, which will be further determined by the OJK. Furthermore, the Draft Regulation has now revised and compiled the obligations that must be met by Supporting Professionals into a unified list of professional obligations that will apply to all types of Supporting Professionals.

Business actors operating within the financial services sector (Pelaku Usaha Jasa Keuangan "PUJK") are required to draft and submit self-assessment reports to the Financial Services Authority (Otoritas Jasa Keuangan "OJK") on their compliance with various consumer and public protection obligations ("Self-Assessments"). Said Self-Assessments should be drafted by filling out information in working papers that relate to nine specific aspects that include: 1) Consumer data and information protection; 2) Offered products and/or services; and 3) Complaints and dispute resolution mechanism for the relevant products and services.

The various types of business activities that Organizers of Aggregations of Financial Services (Penyelenggara Agregasi Jasa Keuangan "PAJK") may engage in include the following, among others: 1) Comparisons of product information and/or financial services for consumers; 2) Forwarding (penerusan) of potential consumer references to financial services institutions (Lembaga Jasa Keuangan "LJK") and/or parties that engage in activities within the financial services sector; 3) Provision of supporting services to LJK and/or parties that engage in activities within the financial services sector that relate to the distribution of financial products and/or services to consumers.