The financing company industry in Indonesia operates under a complex regulatory framework designed to ensure financial stability, consumer protection, governance, and risk management. Regulations issued by the Financial Services Authority (OJK) govern various aspects, including anti-money laundering, business operations, reporting obligations, sustainable finance, consumer protection, and governance compliance. These regulations reflect the high level of risks within the financing industry, such as credit, liquidity, operational, and systemic risks. However, the main challenge lies not in the existence of regulations, but in the ability of companies to understand and internalize them strategically. Companies that treat regulations merely as administrative compliance may lose competitiveness compared to those that integrate regulations into their business strategies. Legal advisors also play an important role in helping companies and foreign investors interpret regulatory changes, assess legal implications, and ensure compliance. Ultimately, success in the financing industry depends not only on financing capabilities but also on the ability to strategically navigate and utilize regulatory frameworks in a rapidly changing environment.
In the financial services industry, regulation is not merely a limitation, but an architecture that shapes market behavior. In the financing sector, regulatory complexity reflects the high level of risk that must be managed: credit risk, liquidity risk, and even systemic risk that can have broad impacts on economic stability.
The Financial Services Authority (OJK) in Indonesia has established a regulatory framework that not only governs operations, but also ensures governance discipline, consumer protection, and the integrity of the financial system. These regulations are spread across various interconnected provisions, forming a comprehensive supervisory ecosystem.
However, the biggest challenge lies not in the existence of regulations, but in the ability of industry players to understand and internalize them. Without a thorough understanding, regulations risk becoming merely a compliance burden rather than a tool for building sustainable competitive advantage.
Below is the main regulatory framework for financing companies in Indonesia:
Anti-Money Laundering
Regulation of the Financial Services Authority Number 8 of 2023 on the Implementation of Anti-Money Laundering and Prevention of Terrorism and Proliferation of Weapons of Mass Destruction Funding Programs within the Financial Services Sector, Counter-Terrorism Financing, and Counter-Proliferation Financing of Weapons of Mass Destruction Programs in the Financial Services Sector
Regulation of the Financial Services Authority Number 23/POJK.01/2019 of 2019 on Amendment to Regulation of the Financial Services Authority Number
12/POJK.01/2017 on the Implementation of Anti-Money-Laundering and Prevention of
Terrorism Financing Programs within the Financial Services Sector
Regulation of the Financial Services Authority Number 12/POJK.01/2017 on the Implementation of Anti-Money Laundering and Prevention of Terrorism
Financing Programs Within the Financial Services Sector
Business Activities
Regulation of the Financial Services Authority Number 35 of 2025 on Amendment to Regulation of the Financial Services Authority Number 46 of 2024 on
Development and Strengthening of Financing Companies, Infrastructure Financing
Companies, and Venture Capital Companies
Regulation of the Financial Services Authority Number 32 of 2025 on the Organization of Buy Now Pay Later
Regulation of the Financial Services Authority Number 43 of 2024 on the Development of the Quality of Human Resources in Financing Institutions, Venture Capital Companies, Microfinance Institutions, and Other Financial Services Institutions
Regulation of the Financial Services Authority Number 46 of 2024 on the Development and Strengthening of Financing Companies, Infrastructure Financing Companies, and Venture Capital Companies
Regulation of the Financial Services Authority Number 49 of 2024 on Supervision, Determination of Supervisory Status, and Follow-up Actions for Financing Institutions, Venture Capital Companies, Microfinance Institutions, and Other Financial Services Institutions
Regulation of the Financial Services Authority Number 35/POJK.05/2018 of 2018 on the Operation of Financing Companies
Regulation of the Financial Services Authority Number 10/POJK.05/2019 of 2019 on the Operation of Sharia Financing Companies and Sharia Business Units of Financing Companies
Regulation of the Financial Services Authority Number 47/POJK.05/2020 of 2020 on Business Licensing and Institutional Aspects of Financing Companies and Sharia Financing Companies
Regulation of the Financial Services Authority Number 29/POJK.05/2020 of 2020 on Amendment to Regulation of the Financial Services Authority Number 30/POJK.05/2014 on Good Corporate Governance for Financing Companies
Regulation of the Financial Services Authority Number 9/POJK.05/2021 of 2021 on the Determination of Status and Follow-up Supervision of Non-Bank Financial Services Institutions
Regulation of the Financial Services Authority Number 7/POJK.05/2022 of 2022 on Amendment to Regulation of the Financial Services Authority Number 35/POJK.05/2018 on the Operation of Financing Companies
Circular of the Financial Services Authority Number 20/SEOJK.05/2015 of 2015 on Down Payment (Urbun) Requirements for Motor Vehicle Financing under Sharia Financing
Circular of the Financial Services Authority Number 15/SEOJK.05/2016 of 2016 on the Report on the Implementation of Good Corporate Governance for Financing Companies
Monthly Reporting
Regulation of the Financial Services Authority Number 3/POJK.05/2013 of 2013 on Monthly Reports of Non-Bank Financial Services Institutions
Regulation of the Financial Services Authority Number 42 of 2025 on Financial Reporting Integrity for Financing Institutions, Venture Capital Companies, Microfinance Institutions, and Other Financial Services Institutions
Regulation of Members of the Board of Commissioners of the Financial Services Authority Number 45/PADK.06/2025 of 2025 on Monthly Reports of Financing Companies and Sharia Financing Companies
Circular of the Financial Services Authority Number 26/SEOJK.05/2019 of 2019 on Amendment to Circular of the Financial Services Authority Number 3/SEOJK.05/2016 on
Monthly Reports of Financing Companies
Circular of the Financial Services Authority Number 27/SEOJK.05/2019 of 2019 on Amendment to Circular of the Financial Services Authority Number 4/SEOJK.05/2016 on Monthly Reports of Sharia Financing Companies and Sharia Business Units of Financing Companies
Regulatory Levies and Contributions
Regulation of the Financial Services Authority Number 2 of 2025 on Procedures for the Collection of Levies in the Financial Services Sector and Other Revenues
Regulation of the Financial Services Authority Number 39 of 2025 on Procedures for the Collection of Administrative Sanctions in the Form of Fines in the Financial Services Sector
Sustainable Finance
Regulation of the Financial Services Authority Number 51/POJK.03/2017 of 2017 on the Implementation of Sustainable Finance for Financial Services Institutions, Issuers, and Public Companies
Consumer Protection
Regulation of the Financial Services Authority Number 22 of 2023 on Consumer and Public Protection in the Financial Services Sector
Regulation of the Financial Services Authority Number 38 of 2025 on Lawsuits Filed by the Financial Services Authority for Consumer Protection in the Financial Services Sector
Regulation of Members of the Board of Commissioners of the Financial Services Authority Number 37/PADK.08/2025 of 2025 on the Provision and Delivery of Information for Marketing Financial Products and Services
Circular of the Financial Services Authority Number 20/SEOJK.08/2025 of 2025 on the Publication of Complaint Handling and Complaint Service Reports
Regulation of the Financial Services Authority Number 3 of 2023 on Enhancing Financial Literacy and Inclusion in the Financial Services Sector for Consumers and the Public
Regulation of the Financial Services Authority Number 61/POJK.07/2020 of 2020 on Alternative Dispute Resolution Institutions in the Financial Services Sector
Circular of the Financial Services Authority Number 2/SEOJK.07/2014 of 2014 on Consumer Complaint Services and Resolution by Financial Services Providers
Circular of the Financial Services Authority Number 13/SEOJK.07/2014 of 2014 on Standard Agreements
Circular of the Financial Services Authority Number 14/SEOJK.07/2014 of 2014 on Confidentiality and Security of Consumer Personal Data and/or Information
Circular of the Financial Services Authority Number 7/SEOJK.07/2015 of 2015 on Guidelines for the Assessment of Alternative Dispute Resolution Institutions in the Financial Services Sector
Circular of the Financial Services Authority Number 54/SEOJK.07/2016 of 2016 on Monitoring Alternative Dispute Resolution Institutions in the Financial Services Sector
Governance, Risk, and Compliance (GRC)
Regulation of the Financial Services Authority Number 48 of 2024 on Good Governance for Financing Institutions, Venture Capital Companies, Microfinance Institutions, and Other Financial Services Institutions
Regulation of the Financial Services Authority Number 42 of 2024 on Risk Management Implementation for Financing Institutions, Venture Capital Companies, Microfinance Institutions, and Other Financial Services Institutions
Regulation of the Financial Services Authority Number 28 of 2024 on the Management of Track Record Information of Actors through the Actor Information System in the Financial Services Sector
Regulation of Members of the Board of Commissioners of the Financial Services Authority Number 48/PADK.06/2025 of 2025 on Risk Management Implementation
Circular of the Financial Services Authority Number 28/SEOJK.06/2025 of 2025 on Good Governance Reporting
Regulation of the Financial Services Authority Number 4/POJK.05/2021 of 2021 on Risk Management in the Use of Information Technology by Non-Bank Financial Services Institutions
Regulation of the Financial Services Authority Number 10/POJK.05/2014 of 2014 on Risk Rating of Non-Bank Financial Services Institutions
Regulation of the Financial Services Authority Number 28/POJK.05/2020 of 2020 on Health Assessment of Non-Bank Financial Services Institutions
Regulation of the Financial Services Authority Number 30/POJK.05/2020 of 2020 on the Second Amendment to Regulation Number 11/POJK.05/2014 on On-site Examination of Non-Bank Financial Services Institutions
Regulation of the Financial Services Authority Number 12 of 2024 on Anti-Fraud Strategy Implementation for Financial Services Institutions
Circular of the Financial Services Authority Number 22/SEOJK.05/2021 on IT Risk Management
Regulation of the Financial Services Authority Number 44/POJK.05/2020 of 2020 on Risk Management for Non-Bank Financial Services Institutions
Circular of the Financial Services Authority Number 11/SEOJK.05/2020 of 2020 on Health Assessment of Financing Companies
Circular of the Financial Services Authority Number 5/SEOJK.05/2015 of 2015 on Risk Assessment for Sharia Non-Bank Financial Institutions
Circular of the Financial Services Authority Number 2/SEOJK.05/2016 of 2016 on Financial Health of Sharia Financing
Financial Conglomerates
Regulation of the Financial Services Authority Number 17/POJK.03/2014 of 2014 on Integrated Risk Management for Financial Conglomerates
Regulation of the Financial Services Authority Number 26/POJK.03/2015 of 2015 on Integrated Minimum Capital Requirements for Financial Conglomerates
Regulation of the Financial Services Authority Number 18/POJK.03/2014 of 2014 on Integrated Governance for Financial Conglomerates
Regulation of the Financial Services Authority Number 51/POJK.03/2017 of 2017 on Sustainable Finance
Regulation of the Financial Services Authority Number 45/POJK.03/2020 of 2020 on Financial Conglomerates
Fit and Proper Test
Regulation of the Financial Services Authority Number 14/POJK.03/2021 of 2021 on Amendment to Regulation of the Financial Services Authority Number 34/POJK.03/2018 on Reassessment of Key Parties in Financial Services Institutions
Regulation of the Financial Services Authority Number 34/POJK.03/2018 of 2018 on Reassessment of Key Parties in Financial Services Institutions
Regulation of the Financial Services Authority Number 4/POJK.05/2013 of 2013 on Fit and Proper Test for Key Parties in Insurance Companies, Pension Funds, Financing Companies, and Guarantee Companies
Regulation of the Financial Services Authority Number 27/POJK.03/2016 of 2016 on Fit and Proper Test for Key Parties in Financial Services Institutions
Circular of the Financial Services Authority Number 31/SEOJK.05/2016 of 2016 on Fit and Proper Test for Key Parties in Non-Bank Financial Services Institutions
This regulatory framework shows that the financing company industry is not only governed from an operational perspective, but also in terms of behavior, governance, and social responsibility. This complexity reflects one key reality: risks in this industry cannot be managed partially.
However, regulatory complexity also brings consequences. Companies that focus solely on administrative compliance will fall behind those that are able to integrate regulation into their strategy. The same regulation can be a burden for one company, yet become an advantage for another.
The role of legal experts at SW Counselors at Law is to assist foreign investors in conducting regulatory research before entering the financing industry in Indonesia. In addition, our legal experts help map new regulations in the financing sector by comparing them with previous similar regulations and analyzing the potential legal implications of these new rules. This includes providing legal opinions on compliance and relevant legal treatment, as well as litigation assistance in legal disputes for cases faced by our clients.
Ultimately, excellence in the financing industry is not only determined by the ability to generate financing, but by the ability to read, understand, and strategically leverage the regulatory framework. In the face of increasingly rapid change, regulation is no longer merely a set of rules, but an instrument for survival and growth.
