Canada    FinTech Guide    Chapter 4    Indonesia

4. Trading Platforms / Social Trading Platforms / Signal Following
Indonesia  Indonesia

There is no clear information with regard to the social and political climate towards trading, social trading or signaling platforms in Indonesia. However following the issuance of the recent BI Regulations on Fintech near the end of 2017, it indicates that the regulator is starting to allow the growth of financial technology in the field of trading platforms or online market places for investment opportunities through some assessment and certain procedures (as explained in “Legal affairs” section).

Legal Affairs

Under the BI Regulations on Fintech, any financial technology operator that fulfills the category as “Financial Technology” shall be required to have itself registered to BI pursuant to BI Regulations on Financial Technology. The activity of financial technology operator includes, among others, other financial service, which shall means other financial service other than (i) payment system, (ii) market supporter, (iii) investment management and risk management, (iv) loan, financing and capital provision.

It is less clear whether the activity describes under the scope of trading, social trad-ing or signaling platforms described in this section can be considered as “financial technology operator” under BI Regulations on Fintech. However by considering the procedures as stated in BI Regulations on Fintech and should the business player deems its business model can be considered as “Financial Technology”, it is possible for them to firstly register to BI as financial technology operator and follow the determined procedures i.e. registration and Regulatory Sandbox.

Following the end of Regulatory Sandbox period, BI will determine the trial result, and if it is found that the product, service, technology and/or business model constitutes as financial technology other than the payment system category, then BI will submit the trial result to the relevant authority (e.g. OJK), then the licensing process will follow the rules of other relevant authority.

Please see detailed explanation on Part “1. Payment Service / Mobile Payment”, particularly on “Legal Affairs” part.

On a separate note and specifically with regard to the online market place, there is a requirement under Indonesian law that set a foreign shareholding limitation for any company conducting the said business. Therefore, in terms there is an Indonesian company having a foreign shareholders, such company needs to (i) comply with the foreign shareholding limitation and further apply for business license from Indonesian Investment Coordinating Board (Badan Koordinasi Penanaman Modal Indonesia - BKPM). The requirements for having the business license, among others, shall be the company’s corporate documents (.e.g deed of establishment, articles of asso-ciation), power of attorney, information on the investment plan, corporate approvals (as relevant).

Furthermore, under Minister of Communication and Informatics Regulation No. 36 of 2014 regarding Procedure of Electronic System Procurement Registration, any electronic system providers which are conducting their business through an electronic system shall register their business in Ministry of Communication and Informatics as public service provider.

Economic Conditions

In general, market for consulting and adjacent services are relatively high. Therefore the Indonesian citizens will need platforms that can provide comparison or explana-tion on the various products offered in Indonesia. As far as we know, there is only a few of fintech companies that provide the platform for investment products, such as Bareksa (specifically for mutual fund).

However, the development of trading, social trading or signaling platforms for bank-ing products, such as provision of credit facility, provision of credit facility without collateral or insurance, deposit or savings tends to grow more. This progress is sup-ported by many of the websites offering this service. These platforms provide infor-mation and comparison between one facility with the other one, and if there is any facility that may be suitable with the customer, the customer may apply for facility from these platforms.


Business of trading, social trading or signaling platforms, currently trading, social trading or signaling platforms are growing relatively high. Therefore, this type of business needs to be regulated and supervised under Indonesian authority.

Contributing Authors

Armand Yapsunto Muharamsyah & Partners (AYMP)

Arie Armand
Jakarta, Indonesia

Richard Yapsunto
Jakarta, Indonesia

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Chapter Index:

1. Payment Services / Mobile Payment

2. Asset and Portfolio Management

3. Consulting and Broking Services / Robo-advisory / Auto-trading

4. Trading Platforms / Social Trading Platforms / Signal Following

5. Crowdfunding / Crowdinvesting / Crowdlending

6. Virtual Currency - Bitcoin

7. Loan Services / Factoring / Loan Broking / Finetrading

8. Online Banking Services

9. Analytics and Research / Data Management / Risk Management

10. Accounting

11. Identification

12. Online-pawning

13. InsurTech

14. RegTech

15. Initial Coin Offerings (ICOs)

The information in this guide provides a general overview at the time of publication and is not intended to be a comprehensive review of all legal developments nor should it be taken as opinion or legal advice on the matters covered. It is for general information purposes only and readers should take legal advice from a Multilaw member firm.

Publication Date: 1 May 2018