Canada    FinTech Guide    Chapter 8    Indonesia

8. Online Banking Services
Indonesia  Indonesia

Bank Indonesia has an ambition to create a system that integrates all utilization of electronic money and payment systems from various banks or issuers.

Legal Affairs

If a fintech company wants to provide payment services whereby it can offer solutions to easily integrate several payment services in online shops, it shall obtain the license as the payment gateway operator as regulated under PBI No. 18/2016 and its implementing regulations.

To be able to do so, the fintech company shall fulfill the eligible aspects by obtaining special documents. Please see detailed explanation on Part “1. Payment Service / Mobile Payment”, particularly on “Legal Affairs” part, regarding the registration, Regulatory Sandbox and licensing stage.

Nevertheless in conducting traditional banking services in a modern way, usually through online services, the fintech company is required to obtain banking license as the usual banks in Indonesia.

Under Law No. 7 Year 1992 concerning Banking as amended by Law No. 10 Year 1998, any collection of funds in Indonesia in the form of demand deposit, time deposit, certificate of deposit and/or other similar form requires banking business license from OJK.

Economic Conditions

With the total e-commerce transactions reaching almost more than 130 trillion Rupiah in 2014, the market for payment services in Indonesia has also grown dramatically. To the best of our knowledge, the biggest payment service provider according to the market shares in Indonesia is Doku. Currently DOKU provides digital payment services for over 20,000 merchants with direct connection to 15 major banks in Indonesia.


Currently, online trading business and use of technology grows dramatically in Indonesia. This development increases a demand to have a well-established and flexible payment processing system. Therefore, many start-up businesses aim to establish payment getaway systems in Indonesia.

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