The ongoing digitalization of Indonesia’s financial services sector has accelerated the emergence of platforms that aggregate financial products and services from multiple providers. These platforms enable consumers to access, compare, and manage a range of financial products through a single digital interface, thereby enhancing market accessibility and consumer convenience.
At the same time, the increasing use of financial aggregation services raises a number of regulatory concerns, particularly in relation to personal data protection, cybersecurity risks, and consumer protection. In response to these developments, the Financial Services Authority (Otoritas Jasa Keuangan – OJK) has introduced a regulatory framework governing financial aggregator businesses, known as Penyelenggara Agregasi Jasa Keuangan (PAJK), through OJK Regulation No. 4 of 2025 concerning Financial Services Aggregation Providers (“OJK Reg. 4/2025”).
This regulation forms part of Indonesia’s broader regulatory strategy to supervise technological innovation within the financial sector while preserving financial system integrity and safeguarding consumer interests. Following the conclusion of the transition period on 26 February 2026, businesses engaged in financial aggregation activities are expected to ensure full compliance with the requirements set out under OJK Reg. 4/2025.
Scope of Financial Aggregator Activities
PAJK operators function as technology based platforms that aggregate financial services information and facilitate connections between consumers and financial service providers. In practice, these platforms collect, organize, and present information relating to financial products offered by licensed financial institutions, enabling consumers to compare and access such products through digital channels.
The activities of PAJK operators include, among others:
- displaying and aggregating information on financial products;
- facilitating referrals of consumers to financial institutions; and
- supporting the digital distribution or marketing of financial products.
Through this framework, the OJK seeks to ensure that financial aggregation services operate in a transparent, accountable, and orderly manner, while remaining consistent with the regulatory standards applicable to Indonesia’s financial services sector.
Licensing and Corporate Requirements
Entities intending to operate as a PAJK must obtain prior approval from the Otoritas Jasa Keuangan. Under OJK Regulation No. 4 of 2025, a PAJK operator must be established in the form of an Indonesian limited liability company (Perseroan Terbatas or PT).
The regulation permits foreign ownership in PAJK operators, whether directly or indirectly, subject to certain limitations and provided that such participation does not involve nominee arrangements. This framework enables international fintech companies to enter the Indonesian market while remaining subject to Indonesia’s regulatory oversight.
PAJK operators are required to maintain a minimum paid-up capital, which must originate from legitimate sources and may not be derived from loans or from activities associated with money laundering, terrorism financing, or the proliferation of weapons of mass destruction.
As part of the licensing process, applicants must demonstrate adequate technological readiness, effective risk management systems, and sound corporate governance arrangements. These requirements reflect the OJK’s emphasis on ensuring that financial aggregation platforms maintain operational resilience and implement appropriate safeguards for consumers.
Prospective investors and market participants should therefore carefully evaluate the appropriate corporate structure, licensing process, and applicable regulatory obligations before establishing or acquiring interests in PAJK operators.
Governance and Regulatory Oversight
PAJK operators are subject to ongoing regulatory supervision by the Otoritas Jasa Keuangan. The regulatory framework requires operators to establish appropriate governance structures, including the appointment of directors and commissioners responsible for overseeing business operations and ensuring compliance with applicable laws and regulations.
In addition, PAJK operators must implement internal control mechanisms, robust data protection policies, and effective consumer protection procedures in line with the broader regulatory standards applicable to financial technology providers in Indonesia.
These obligations are intended to promote responsible innovation within the financial sector while mitigating risks associated with digital financial services.
Compliance Obligations and Regulatory Enforcement
PAJK operators are required to comply with a range of operational, governance, and reporting obligations prescribed by the Otoritas Jasa Keuangan. Non-compliance with these regulatory requirements may result in administrative sanctions imposed by the regulator.
Such sanctions may include written warnings, restrictions on certain business activities, suspension of operations, or ultimately the revocation of the operator’s license.
These enforcement mechanisms demonstrate the OJK’s commitment to maintaining a secure, transparent, and well regulated digital financial ecosystem in Indonesia.
Closing Remarks
The introduction of OJK Reg. 4/2025 represents an important regulatory development in Indonesia’s rapidly evolving fintech landscape. As financial aggregation platforms continue to play a growing role in connecting consumers with financial institutions, regulatory compliance and sound corporate structuring will be critical considerations for market participants.
Businesses seeking to establish or invest in PAJK operations should carefully assess the applicable regulatory framework and licensing requirements. In this context, obtaining appropriate legal and regulatory advice may be essential to ensure that business operations remain aligned with Indonesia’s evolving fintech regulatory environment.
If you, a prospective client, have further inquiries about the topic discussed above, Schinder Law Firm is one of many corporate law firms in Indonesia that has handled numerous similar matters, with many experienced and professional corporate and civil lawyers in its arsenal, making it one of the top consulting firms in Indonesia. Feel free to contact us at info@schinderlawfirm.com for further consultation.
Author:
Budhi Satya Makmur