The financial technology (fintech) landscape in Indonesia is rapidly evolving, driven by increasing digitalization and a growing demand for alternative financial solutions. As this sector continues to expand, regulatory bodies like the Otoritas Jasa .
Indonesia's P2P lending sector is subject to increasingly detailed capital and financial requirements. Under OJK Regulation No. 40 of 2024, providers must maintain minimum equity of Rp12.5 billion, alongside a separate minimum paid-up capital requirement of Rp25 billion. For businesses entering or operating in this sector, understanding the distinction is essential for regulatory planning.
The minimum equity requirement requires P2P lending providers, known in Indonesia as Layanan Pendanaan Bersama Berbasis Teknologi Informasi or LPBBTI providers, to maintain equity of at least Rp12.5 billion. This requirement was introduced under POJK 10/2022 and remains under the current POJK 40/2024 framework.
The requirement is designed to strengthen the financial resilience of providers and support sustainable operations. It also forms part of OJK's broader approach to governance, risk management, and consumer protection within the P2P lending sector.
Understanding the difference between paid-up capital and equity is important when assessing the capital needed to establish and operate a P2P lending business.
Under POJK 40/2024, a P2P lending provider must have minimum paid-up capital of Rp25 billion at establishment. The capital must be fully paid in cash and placed in a term deposit in the name of the P2P lending provider at an Indonesian commercial bank.
This requirement is separate from the minimum equity requirement. A business therefore should not treat Rp25 billion of paid-up capital as equivalent to maintaining Rp12.5 billion of equity throughout its operations.
Providers must maintain equity of at least Rp12.5 billion. For providers licensed before POJK 40/2024 came into effect, the requirement was implemented through transitional milestones, reaching Rp12.5 billion by 4 July 2025.
The distinction matters because losses can reduce a company's equity even when its original paid-up capital remains unchanged. Providers therefore need ongoing financial monitoring rather than treating the requirement as a one-time establishment condition.
Capital is only one part of the regulatory framework. POJK 40/2024 also requires providers to maintain an equity-to-paid-up-capital ratio of at least 50%, a liquidity ratio of at least 120%, and a maximum non-performing funding ratio of 5%.
These requirements mean that maintaining the minimum equity threshold alone does not guarantee continued compliance. Providers need adequate financial controls, funding-quality monitoring, liquidity management, and broader regulatory governance.
Higher capital and equity requirements can provide providers with greater financial resilience when operating in a risk-sensitive lending environment. They also create a stronger financial foundation for technology, governance, risk management, compliance, and day-to-day operations.
The regulatory approach is also intended to strengthen consumer protection and industry sustainability. OJK's P2P lending roadmap identifies capital requirements, governance, risk management, IT reliability, consumer protection, cybersecurity, and funding sources among the industry's key challenges.
The Rp12.5 billion requirement affects both prospective entrants and existing providers that need to maintain sufficient equity as their business develops.
A prospective provider needs to consider the Rp25 billion paid-up capital requirement alongside the minimum equity and other financial requirements. This means the financial planning for a P2P lending business needs to extend beyond incorporation costs and initial technology investment.
For investors, the regulatory capital requirements should therefore form part of the business model from the beginning. A funding plan that only covers initial establishment may be insufficient if operating losses later reduce equity below the required threshold.
Smaller providers can face greater pressure when losses, slower growth, or additional compliance costs affect their equity position. OJK's March 2026 update reported that 10 of 95 P2P lending providers had not yet met the Rp12.5 billion minimum equity requirement.
The affected providers had submitted action plans involving measures such as additional capital from existing shareholders and strategic investors. This shows that the equity requirement remains an active compliance issue for part of the industry rather than simply a historical regulatory change.
Capital requirements can also encourage consolidation when smaller providers cannot independently strengthen their financial position. OJK has identified capital injections, strategic investors, and mergers among the measures being pursued by providers that need to address minimum-equity shortfalls.
For investors and existing shareholders, this can make corporate restructuring an important strategic consideration. Any transaction involving ownership or control should, however, be assessed against the specific approval and reporting requirements under the applicable OJK framework.
Providers facing an equity shortfall need a structured plan that considers both the immediate capital gap and their longer-term financial position.
Existing shareholders may strengthen the provider's financial position by injecting additional capital where permitted and appropriately structured. This approach can preserve the existing ownership structure while addressing an immediate equity requirement.
However, the company should assess how the injection affects its capitalisation, shareholder position, financial statements, and compliance obligations. Capital planning should therefore be coordinated with corporate and regulatory requirements rather than treated as a standalone funding exercise.
Strategic investors can provide additional capital while potentially contributing industry expertise, technology, distribution capabilities, or access to a broader financial ecosystem. OJK has specifically identified strategic investors as one route being used by providers to address minimum-equity requirements.
Potential investors should nevertheless conduct regulatory and commercial due diligence before committing funds. Ownership restrictions, controlling shareholder requirements, source-of-funds rules, and OJK approval requirements can affect how an investment is structured.
Mergers and other restructuring strategies may become relevant where a provider cannot independently maintain the required financial position. OJK has reported mergers among the measures included in action plans submitted by providers with capital shortfalls.
These transactions require more than a commercial agreement between shareholders. The parties should assess ownership, control, licensing, regulatory approvals, corporate documentation, and the continuing ability of the resulting business to satisfy OJK requirements.
Foreign investors considering Indonesia's P2P lending sector need to assess both general corporate requirements and sector-specific financial regulations. Under the current transitional framework, foreign ownership in a P2P lending provider is generally capped at 85% of paid-up capital until further government regulations are issued, subject to the treatment of existing providers that already exceeded the threshold before POJK 40/2024.
Investors should therefore review the proposed ownership structure before incorporating or acquiring a provider. The analysis should cover foreign ownership, controlling shareholders, source of funds, capital requirements, OJK licensing, and any approval required for changes in ownership or control.
Establishing a P2P lending business requires more than registering an Indonesian company. Businesses should first confirm that their proposed activity fits the applicable P2P lending framework and then assess the corporate, capital, licensing, technology, governance, and compliance requirements that follow.
Before proceeding, businesses should review:
This assessment is particularly important for foreign investors because a structure that works for an ordinary Indonesian company may not be sufficient for a regulated financial services business.
The Rp12.5 billion minimum equity requirement is only one part of Indonesia's regulatory framework for P2P lending providers. Businesses must also consider paid-up capital, ownership, licensing, financial ratios, governance, technology requirements, and ongoing OJK supervision.
CPT Corporate can assist foreign investors and businesses with the Indonesian company registration and corporate structuring process. For a regulated fintech business, the appropriate structure and regulatory pathway should be assessed before incorporation so that the proposed business model aligns with Indonesia's applicable requirements.
Pemerintah bersama Dewan Perwakilan Rakyat (DPR) resmi mengesahkan Rancangan Undang-Undang tentang Pusat Finansial Internasional Indonesia (RUU PFII) pada 21 Juli 2026.
The Government together with the House of Representatives (DPR) officially passed the Bill on the Indonesia International Financial Center (IIFC Bill) on 21 July 2026.
When discussing Halal Product Guarantee in Indonesia, public attention usually goes straight to the halal certification obligation. Yet not all products are actually meant to be certified. There is a certain category of products made from non-halal (haram) ingredients that are in fact excluded from that obligation.
Tell us about your plan and our consultants will reach out to you to assist with your needs.
Client Login
Share on facebook
Share on X