Strengthening standards for Indonesia's P2P lending industry

A new Indonesian Financial Services Authority (OJK) regulation has introduced a more robust compliance framework for peer-to-peer (P2P) lending platforms to improve governance, operational flexibility, and transparency.

Key highlights include (i) detailed procedural and governance requirements for lender meetings, (ii) lender and borrower criteria, (iii) caps on loans to related borrowers, (iv) changes in economic benefits and the penalty calculation structure, (v) replacing the “Successful Payment Rate” (Tingkat Keberhasilan Bayar or TKB) system with a new five tier Funding Quality Level classification, and (vi) guidelines for transferring loan portfolios in case the P2P lending platforms face business activity restrictions or cannot be rehabilitated.

Legal Framework

Following the issuance of OJK Regulation No. 40 of 2024 (POJK 40/2024) on 24 December 2024, on 31 July 2025 OJK issued Circular Letter No. 19/SEOJK.06/2025 on the Provision of Information Technology-Based Joint Funding Services (LPBBTI) (SEOJK 19/2025), replacing a 2023 Circular Letter on the same topic (SEOJK 19/2023).

Key Provisions

1. Expansion of permitted activities 

Under POJK 40/2024, P2P lending platforms can now engage in a range of additional activities, including acting as distribution partners for government securities to support government programs, collaborating on information services, and conducting other activities as approved by OJK, subject to certain requirements.
SEOJK 19/2025 clarifies that the other activities which may be approved by OJK include:

• activities assigned by the government;
• developing funding services that will increase the risk exposure of the P2P lending platforms; and
• cooperation with other parties for business generation purposes.

These other activities must be related to the P2P lending platform’s business activities and must not conflict with other regulations.

2. IT outsourcing

SEOJK 19/2025 broadens the scope of activities that may be outsourced by P2P lending platforms.

Under SEOJK 19/2023, neither IT development nor IT operations could be outsourced. However, in line with POJK 40/2024, SEOJK 19/2025 now permits the outsourcing of IT development provided certain regulatory requirements are met. Outsourcing of IT operations continues to be prohibited, including the management of user access and databases.

3. General Meeting of Lenders (Rapat Umum Pemberi Dana)

The concept of a General Meeting of Lenders (Rapat Umum Pemberi Dana or RUPD) was first introduced by POJK 40/2024. P2P lending platforms must establish guidelines for conducting an RUPD, which is intended to facilitate decision-making, including in relation to amendments of Funding Agreements (Perjanjian Pendanaan). 

SEOJK 19/2025 details various other matters to be covered in the RUPD guidelines prepared by P2P lending platforms, such as the procedures for convening meetings, and documentation and fees. 

4. Lender and borrower requirements

Lenders

SEOJK 19/2025 distinguishes between professional and non-professional lenders, with funding limits based on their income:

1. professional lenders comprise (a) Indonesian citizens who are at least 18 years old or married, with annual gross income above IDR 500 million, who may lend up to 20% of their income per P2P lending platform; (b) foreign individuals, (c) Indonesian and non Indonesian legal entities, (d) Indonesian and non-Indonesian business entities, and (e) international institutions; and 
2. non-professional lenders comprise Indonesian citizens who are at least 18 years old or married, with annual gross income of no more than IDR 500 million, who may lend up to 10% of their income per P2P lending platform. 

P2P lending platforms must ensure that the total outstanding funding from non professional lenders does not exceed 20% of the platform’s total outstanding loans. 

Borrowers

SEOJK 19/2025 reiterates that all borrowers must be Indonesian citizens or Indonesian legal or business entities, all domiciled in Indonesia. Individual Indonesian borrowers must use their own devices in obtaining funding from P2P lending platforms, be at least 18 years old or married, and earn a minimum average gross income of IDR 3 million per month. 

5. Funding limits for related borrowers

In line with POJK 40/2024, SEOJK 19/2025 provides that the maximum funding limit for both consumptive and productive loans through P2P lending platforms is capped at IDR 2 billion per borrower, with flexibility to provide productive funding of up to IDR 5 billion provided certain conditions are met.

SEOJK 19/2025 explains that this funding limit also applies to multiple borrowers that are considered related, either because they share the same source of income or cash flow for repayment, or because they have an affiliate relationship as defined under SEOJK 19/2025.

6. Economic benefits and fees

SEOJK 19/2025 changes the structure for calculating maximum economic benefits and late payment penalties for P2P lending platforms, with economic benefits determined by the amount and tenor of the funding, as summarised in the accompanying table.

Under SEOJK 19/2025, the total combined amount of economic benefits and penalties charged to a borrower must not exceed 100% of the original funding amount.

7. Publishing fund performance

SEOJK 19/2025 replaces the previous TKB system with a new classification framework called “Funding Quality Level” (Tingkat Kualitas Pendanaan). This new system introduces five funding quality categories: Performing (Lancar), Under Special Attention (Dalam Perhatian Khusus), Substandard (Kurang Lancar), Doubtful (Diragukan), and Non Performing (Macet), replacing the TKB metrics (TKB0, TKB30, TKB60, and TKB90) under SEOJK 19/2023.

8. Portfolio transfers

SEOJK 19/2025 introduces a mechanism whereby P2P lending platforms that are subject to business activity restrictions and/or that cannot be rehabilitated may transfer their portfolios to another P2P lending platform or specially established institution.

The mechanism for transferring a portfolio must be stipulated in the agreement between the lender and borrower and must contain at least a requirement to notify users and require approval or rejection by the borrower of the portfolio transfer. If the borrower neither approves or rejects the portfolio transfer within the timeframe specified by the P2P lending platform, they will be deemed to have approved the transfer.

SEOJK 19/2025 requires that agreements executed prior to its issuance must be updated to include this portfolio transfer mechanism, and this must be done by 31 January 2026. 

9. Key deadlines

SEOJK 19/2025, which came into effect on 31 July 2025, has a phased implementation schedule:

• By 1 January 2026: P2P lending platforms must apply the new lender eligibility criteria. In assessing borrowers’ repayment capacity for consumptive funding, P2P platforms must ensure that the ratio of (i) funding amount and economic benefits to (ii) the borrower’s income is at most 30% (down from 40% in 2025). 
• By 31 January 2026: Loan agreements between lenders and borrowers must be updated to allow for portfolio transfers where the P2P lending platform faces restrictions on its business activity or cannot be rehabilitated.
• By 31 July 2026: Additional collateral must be provided for productive loan facilities exceeding IDR 2 billion. If additional collateral is not provided, lenders can ask the P2P lending platform for information on the prospective borrowers.
• By 1 January 2027: P2P lending platforms must ensure that outstanding funding from non-professional lenders does not exceed 20% of the P2P lending platform’s total outstanding funding.

Conclusion

SEOJK 19/2025 reflects OJK’s continuing efforts to improve transparency, governance and risk management in Indonesia’s P2P lending landscape. It introduces a comprehensive operational framework for P2P lending platforms to implement POJK 40/2024. The phased implementation timeline provides a structured transition period for P2P lending platforms to adapt, with the aim of ensuring a seamless transition towards full compliance.

(Associate Arya Tjahjono and trainee Regita Maritza assisted the authors in preparing this legal update.)