
The Financial Services Authority (OJK) has introduced a comprehensive new regulation addressing paylater services, including critical provisions for debt collection and granting the authority to set limits on installment interest rates. This significant directive, known as OJK Regulation (POJK) Number 32 of 2025 concerning the Provision of Buy Now Pay Later (BNPL), officially took effect upon its enactment on December 15.
Comprising 17 articles, POJK 32/2025 specifically empowers the OJK to determine the maximum economic benefit, or installment interest, that can be charged by providers. Article 15 explicitly states, “Provisions regarding the determination of the maximum economic benefit shall be set by the OJK,” as quoted directly from the regulation on Sunday, December 31.
According to Ismail Riyadi, Head of OJK’s Department of Literacy, Financial Inclusion, and Communication, in a press statement on December 24, the process of setting these interest rate caps will meticulously consider the public interest, the stability of the financial system, and the promotion of healthy business competition within the sector. This strategic approach underscores OJK’s commitment to balanced growth and consumer welfare.
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POJK 32/2025 unequivocally stipulates that BNPL services can only be offered by specific financial service institutions, ensuring a regulated and secure ecosystem. These eligible entities include:
Commercial Banks
- May provide BNPL services in accordance with existing banking sector laws and regulations.
- Are mandated to align their internal policies with robust prudential principles and effective risk management frameworks.
Financing Companies
- Must secure prior approval from the OJK before commencing BNPL operations.
- Are required to meet stringent governance, capital adequacy, and information technology system standards as prescribed by the OJK.
Both Commercial Banks and Financing Companies are permitted to establish specific policies for assessing the eligibility of prospective paylater customers. Furthermore, these companies are obliged to provide clear and comprehensive information to potential customers, which includes:
- The source of financing funds, especially if the financing involves joint financing cooperation, channeling, and/or has been transferred to other parties.
- The total number and frequency of installments.
- Any other relevant information as determined by the OJK.
- Non-compliance with these provisions by Commercial Banks or Financing Companies will result in administrative sanctions, which may include:
- A written warning.
- Restriction of products and/or services and/or business activities, either partially or entirely.
- Suspension of products and/or services and/or business activities, either partially or entirely.
- Dismissal of management.
- An administrative fine.
- Revocation of product and/or service licenses.
- Revocation of business licenses.
It is important to note that administrative sanctions from points 2 to 7 can be imposed with or without a preceding written warning. The maximum administrative fine that can be levied is IDR 15 billion.
Beyond these specific provisions, paylater providers are also required to rigorously adhere to prudential principles, uphold consumer protection standards, and safeguard the personal data of customers/debtors, all in accordance with prevailing laws and regulations. This holistic approach aims to foster trust and security within the digital financial landscape.
Regarding debt collection practices, the new regulation aligns with POJK 22 of 2023, which focuses on consumer and public protection within the financial services sector. In cases where a company undertakes collection efforts against consumers who default on their payments, the following procedures must be observed:
- The company must issue a warning letter within the timeframe specified in the agreement.
- This warning letter must contain at least the following crucial information:
- The due date as stipulated in the agreement.
- The number of days the payment obligation has been delayed.
- The outstanding principal amount owed.
- The economic benefit of the funding or installment interest.
- Any accrued fines and/or compensation owed.
Failure by a company to comply with these debt collection provisions will similarly result in administrative sanctions, which are consistent with those for BNPL provider violations, including:
- A written warning.
- Restriction of products and/or services and/or business activities, either partially or entirely.
- Suspension of products and/or services and/or business activities, either partially or entirely.
- Dismissal of management.
- An administrative fine.
- Revocation of product and/or service licenses, and/or
- Revocation of business licenses.
Again, sanctions from points 2 to 7 may be imposed with or without an initial written warning, with a maximum administrative fine of IDR 15 billion.
The OJK emphasizes that the introduction of these paylater regulations is a proactive measure designed to mitigate significant risks. These include the potential for widespread defaults, information asymmetry between providers and consumers, and the inherent operational and systemic risks associated with the increasing adoption of digital technology in financial services.
Ultimately, this comprehensive paylater regulation aims to provide robust legal certainty, fortify risk management practices, and safeguard the stability of the financial services sector. By doing so, it seeks to ensure the healthy and sustainable growth of the industry, align with the broader digital transformation goals of the financial services sector, and significantly contribute to enhancing national financial inclusion.
