Publication
Understanding The Specific Rule for Financial Services Aggregation Providers (Pahami Aturan Khusus Bagi Penyelenggara Agregasi Jasa Keuangan)
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To provide legal certainty and a clear regulatory framework for businesses in the Financial Services Aggregation Provider (PAJK) sector, the Financial Services Authority (OJK) officially enacted OJK Regulation Number 4 of 2025 concerning Financial Services Aggregation Providers (POJK 4/2025) on 26 February 2025. This was also welcomed positively by consumers who indeed need more accurate and reliable comparation and information amidst the proliferation of various investment and financial product offerings.
Previously, PAJK was part of the Financial Sector Technology Innovation (ITSK) regulated in OJK Regulation Number 3 of 2024 (POJK 3/2024). However, several aspects were not yet regulated in POJK 3/2024, including regulatory design, obligations, capital structure, and business models for certain PAJK. The issuance of POJK 4/2025 was also driven by Law Number 4 of 2023 concerning the Development and Strengthening of the Financial Sector (P2SK Law), which authorizes the OJK to regulate and supervise activities in the ITSK sector and digital financial assets, including crypto assets. Article 213 of the P2SK Law covers the scope of ITSK, including market enablers such as aggregators, financing agents, funding agents, and wealth tech.
POJK 4/2025 provides a clear and detailed definition of aggregation activities in the financial services sector. Aggregation, in this context, involves the activities of collecting, filtering, and comparing product and/or financial service information between Financial Services Institutions (“LJK”) and business actors in the sector. This definition aims to provide clear guidance for business actors so they can conduct business activities more directed and in accordance with applicable regulations.
In the implementation of aggregation activities by PAJK, there are various risks to be faced, such as personal data protection, cybersecurity, and consumer protection. These risks require a strong regulatory framework to ensure that the aggregation of product and/or financial service information is conducted safely and responsibly. POJK 4/2025 addresses these challenges by providing clear and comprehensive guidelines, thereby enhancing trust and security in this sector.
PAJK Business Activities
As stipulated in Article 3 of POJK 4/2025, the primary role of the Financial Services Authority (PAJK) is to display information on financial products and/or services and provide option to consumers. PAJK's services include forwarding information on potential consumers to Financial Services Institutions (LJK); distributing financial products and/or services to consumers; and/or administering documents related to financial products and/or services for the benefit of consumers and LJKs.
Aggregation activities are carried out through an Electronic System in the form of a website and/or device-based application that can be accessed by Consumers. Information displayed regarding financial products and/or services includes the name and type of product and/or service, the name of the issuer, main features, benefits, risks, requirements and procedures, fees, and additional information. Comparison of information on financial products and/or services must be carried out for the same type of product and/or service.
To provide accurate data and information, PAJK is required to collaborate with registered and verified financial services institutions (LJK) in accordance with OJK regulations. This collaboration includes connectivity between PAJK systems and LJK electronic systems. Article 32 of POJK 4/2025 explicitly prohibits PAJK from providing aggregation in the form of user-generated content platforms or copying content without official cooperation with LJK or other parties in the financial services sector.
Requirements on Capitalization and Board Composition of PAJK
Referring to Article 4 paragraph (3) of POJK 4/2025, PAJK must have a minimum paid-up capital of IDR 500,000,000 (five hundred million rupiah), which cannot originate from loans from banks, business entities, or other institutions. Meanwhile, the maximum share ownership by foreign citizens and/or foreign legal entities is 85% (eighty-five percent) of the company's total paid-up capital. An exception to this limitation applies only to PAJKs that are public companies whose shares are traded on a stock exchange.
Additionally, Article 6 paragraph (1) of POJK 4/2025 regulates that the management composition must meet the minimum requirements, namely 2 (two) members of the Board of Directors and 1 (one) member of the Board of Commissioners. At least 1 (one) member of the Board of Directors must have knowledge or experience in aggregation, information technology, or financial services institutions, proven through certification or work experience. Furthermore, under POJK 4/2025, the Board of Directors is prohibited from holding concurrent positions as members of the board of directors, board of commissioners, or executive officers in other companies, except for non-profit organizations.
Foreign workers can only occupy positions 1 (one) level below Directors and/or experts or consultants, with a maximum term of 3 (three) years per position. Foreign workers are prohibited from working in personnel and compliance fields. PAJK employing foreign workers must report to OJK no later than 5 (five) working days before they are employed. OJK will also conduct a fit and proper assessment of the competency of members of the board of directors and board of commissioners before taking office.
Business License and Corporate Actions
PAJK licensing applications are submitted by prospective PAJKs to the OJK through the OJK licensing system, attaching supporting documents as stipulated in Appendix POJK 4/2025. The OJK conducts an inspection within 20 (twenty) days of receiving complete documents. Furthermore, PAJKs are also required to obtain a registration certificate as an Electronic System Provider no later than 60 (sixty) days after the issuance of the business license from the OJK.
Meanwhile, for aggregator providers, financing agents, funding agents, and wealth tech registered with OJK are given a period of up to 12 months from the enactment of POJK 4/2025 to apply for a business license or maximum of 25 February 2026. For providers in the registration process but not yet registered when this POJK comes into effect, they continue the registration process according to existing procedures. This process does not reduce the time frame for applying for a business license, which must still be met within 12 months from the enactment of this POJK. Thus, OJK ensures that all providers in this sector have ample time to meet licensing requirements while maintaining integrity and compliance with applicable regulations.
Compliance Aspect
PAJK is required to submit their annual business plans to the OJK no later than November 10th before the start of the year in which the annual business plan begins. Changes to the business plan may be made once, no later than 30 (thirty) working days prior to the implementation of the annual business plan amendment, accompanied by a written justification for the change.
Periodic reports that must be submitted to the OJK include Semester Reports, which consist of financial data, annual business plan implementation reports, and risk management and prudential principles, submitted no later than 31 July of the current year and 31 January of the following year. Meanwhile, the Annual Report contains annual financial statements audited by a public accountant registered with the Financial Services Authority and a Governance report, submitted no later than April 30 of the following year.
During the course of business activities, in the case of PAJK carrying out corporate actions, it is mandatory to obtain OJK approval in advance to carry out changes in ownership that result in changes in control, carry out mergers, carry out amalgamations or be taken over by other PAJK.
In addition, reporting to the Financial Services Authority (OJK) is mandatory if a PAJK undertakes the following corporate actions:
a. increases in paid-up capital;
b. changes in ownership composition;
c. changes in the business group structure down to the ultimate owner and controller;
d. appointment of members of the Board of Directors and/or members of the Board of Commissioners that have received approval from the Financial Services Authority; and
e. implementation of mergers, consolidations, or takeovers.
In addition to compliance with the Financial Services Authority (OJK) as a supervisory body, PAJK is also required to implement consumer protection principles, personal data protection, and anti-fraud strategies effectively.
Click DOWNLOAD PDF to read the Indonesian version of this Article
To provide legal certainty and a clear regulatory framework for businesses in the Financial Services Aggregation Provider (PAJK) sector, the Financial Services Authority (OJK) officially enacted OJK Regulation Number 4 of 2025 concerning Financial Services Aggregation Providers (POJK 4/2025) on 26 February 2025. This was also welcomed positively by consumers who indeed need more accurate and reliable comparation and information amidst the proliferation of various investment and financial product offerings.
Previously, PAJK was part of the Financial Sector Technology Innovation (ITSK) regulated in OJK Regulation Number 3 of 2024 (POJK 3/2024). However, several aspects were not yet regulated in POJK 3/2024, including regulatory design, obligations, capital structure, and business models for certain PAJK. The issuance of POJK 4/2025 was also driven by Law Number 4 of 2023 concerning the Development and Strengthening of the Financial Sector (P2SK Law), which authorizes the OJK to regulate and supervise activities in the ITSK sector and digital financial assets, including crypto assets. Article 213 of the P2SK Law covers the scope of ITSK, including market enablers such as aggregators, financing agents, funding agents, and wealth tech.
POJK 4/2025 provides a clear and detailed definition of aggregation activities in the financial services sector. Aggregation, in this context, involves the activities of collecting, filtering, and comparing product and/or financial service information between Financial Services Institutions (“LJK”) and business actors in the sector. This definition aims to provide clear guidance for business actors so they can conduct business activities more directed and in accordance with applicable regulations.
In the implementation of aggregation activities by PAJK, there are various risks to be faced, such as personal data protection, cybersecurity, and consumer protection. These risks require a strong regulatory framework to ensure that the aggregation of product and/or financial service information is conducted safely and responsibly. POJK 4/2025 addresses these challenges by providing clear and comprehensive guidelines, thereby enhancing trust and security in this sector.
PAJK Business Activities
As stipulated in Article 3 of POJK 4/2025, the primary role of the Financial Services Authority (PAJK) is to display information on financial products and/or services and provide option to consumers. PAJK's services include forwarding information on potential consumers to Financial Services Institutions (LJK); distributing financial products and/or services to consumers; and/or administering documents related to financial products and/or services for the benefit of consumers and LJKs.
Aggregation activities are carried out through an Electronic System in the form of a website and/or device-based application that can be accessed by Consumers. Information displayed regarding financial products and/or services includes the name and type of product and/or service, the name of the issuer, main features, benefits, risks, requirements and procedures, fees, and additional information. Comparison of information on financial products and/or services must be carried out for the same type of product and/or service.
To provide accurate data and information, PAJK is required to collaborate with registered and verified financial services institutions (LJK) in accordance with OJK regulations. This collaboration includes connectivity between PAJK systems and LJK electronic systems. Article 32 of POJK 4/2025 explicitly prohibits PAJK from providing aggregation in the form of user-generated content platforms or copying content without official cooperation with LJK or other parties in the financial services sector.
Requirements on Capitalization and Board Composition of PAJK
Referring to Article 4 paragraph (3) of POJK 4/2025, PAJK must have a minimum paid-up capital of IDR 500,000,000 (five hundred million rupiah), which cannot originate from loans from banks, business entities, or other institutions. Meanwhile, the maximum share ownership by foreign citizens and/or foreign legal entities is 85% (eighty-five percent) of the company's total paid-up capital. An exception to this limitation applies only to PAJKs that are public companies whose shares are traded on a stock exchange.
Additionally, Article 6 paragraph (1) of POJK 4/2025 regulates that the management composition must meet the minimum requirements, namely 2 (two) members of the Board of Directors and 1 (one) member of the Board of Commissioners. At least 1 (one) member of the Board of Directors must have knowledge or experience in aggregation, information technology, or financial services institutions, proven through certification or work experience. Furthermore, under POJK 4/2025, the Board of Directors is prohibited from holding concurrent positions as members of the board of directors, board of commissioners, or executive officers in other companies, except for non-profit organizations.
Foreign workers can only occupy positions 1 (one) level below Directors and/or experts or consultants, with a maximum term of 3 (three) years per position. Foreign workers are prohibited from working in personnel and compliance fields. PAJK employing foreign workers must report to OJK no later than 5 (five) working days before they are employed. OJK will also conduct a fit and proper assessment of the competency of members of the board of directors and board of commissioners before taking office.
Business License and Corporate Actions
PAJK licensing applications are submitted by prospective PAJKs to the OJK through the OJK licensing system, attaching supporting documents as stipulated in Appendix POJK 4/2025. The OJK conducts an inspection within 20 (twenty) days of receiving complete documents. Furthermore, PAJKs are also required to obtain a registration certificate as an Electronic System Provider no later than 60 (sixty) days after the issuance of the business license from the OJK.
Meanwhile, for aggregator providers, financing agents, funding agents, and wealth tech registered with OJK are given a period of up to 12 months from the enactment of POJK 4/2025 to apply for a business license or maximum of 25 February 2026. For providers in the registration process but not yet registered when this POJK comes into effect, they continue the registration process according to existing procedures. This process does not reduce the time frame for applying for a business license, which must still be met within 12 months from the enactment of this POJK. Thus, OJK ensures that all providers in this sector have ample time to meet licensing requirements while maintaining integrity and compliance with applicable regulations.
Compliance Aspect
PAJK is required to submit their annual business plans to the OJK no later than November 10th before the start of the year in which the annual business plan begins. Changes to the business plan may be made once, no later than 30 (thirty) working days prior to the implementation of the annual business plan amendment, accompanied by a written justification for the change.
Periodic reports that must be submitted to the OJK include Semester Reports, which consist of financial data, annual business plan implementation reports, and risk management and prudential principles, submitted no later than 31 July of the current year and 31 January of the following year. Meanwhile, the Annual Report contains annual financial statements audited by a public accountant registered with the Financial Services Authority and a Governance report, submitted no later than April 30 of the following year.
During the course of business activities, in the case of PAJK carrying out corporate actions, it is mandatory to obtain OJK approval in advance to carry out changes in ownership that result in changes in control, carry out mergers, carry out amalgamations or be taken over by other PAJK.
In addition, reporting to the Financial Services Authority (OJK) is mandatory if a PAJK undertakes the following corporate actions:
a. increases in paid-up capital;
b. changes in ownership composition;
c. changes in the business group structure down to the ultimate owner and controller;
d. appointment of members of the Board of Directors and/or members of the Board of Commissioners that have received approval from the Financial Services Authority; and
e. implementation of mergers, consolidations, or takeovers.
In addition to compliance with the Financial Services Authority (OJK) as a supervisory body, PAJK is also required to implement consumer protection principles, personal data protection, and anti-fraud strategies effectively.
Click DOWNLOAD PDF to read the Indonesian version of this Article
