Analyzing PBI No. 10 of 2025: A New Regulatory Framework for Indonesia’s Payment System Industry

Executive Summary

PBI No. 10 of 2025 on the Regulation of the Payment System Industry is an umbrella regulation that fundamentally reshapes the legal architecture of Indonesia’s payment system sector. Rather than introducing only incremental changes, the regulation consolidates and replaces multiple prior Bank Indonesia regulations, including the full revocation of PBI 22/23/PBI/2020 on the Payment System.

For payment-industry participants, this is a major regulatory development. It signals a more integrated supervisory approach and a broader restructuring of obligations, governance expectations, and market organization within Indonesia’s payment ecosystem.

What Has Changed

The most important shift is structural. PBI 10/2025 is designed as an umbrella regulation, meaning it does not operate as a narrow thematic rule. Instead, it becomes the overarching legal framework for the payment system industry, replacing and consolidating several earlier rules into a more unified approach.

This kind of regulatory consolidation often reflects a maturing market and a regulator’s desire to reduce fragmentation, align industry oversight, and create a clearer foundation for future policy development.

Why This Matters

This matters because regulatory architecture influences how institutions interpret obligations, design governance structures, allocate compliance resources, and plan strategic adaptation. When an umbrella regulation replaces multiple prior rules, the impact can extend well beyond legal citation changes.

• First, compliance interpretation must be reassessed. Organizations should not assume that prior mappings remain valid without review, even where similar topics continue to appear under the new framework.
• Second, governance and control structures may need adjustment. A consolidated regulatory model often changes how institutions document accountability, oversight, and implementation logic.
• Third, strategic planning becomes more important. Because umbrella regulations usually set the direction for future regulatory development, businesses should read them not only as current obligations but also as signals of where the sector is heading.

Bitlion View

From Bitlion’s perspective, PBI 10/2025 should be read as more than a regulatory update. It is a re-foundation of how Indonesia’s payment system industry is governed. That means legal review alone is not enough. Institutions need structured regulatory mapping, impact analysis, and cross-functional implementation planning to respond effectively.

Entities that treat the new framework strategically will be better positioned to align policies, controls, evidence, and business planning with the next phase of Bank Indonesia supervision.

What Companies Should Do Next

1. Map replaced regulations to the new framework so the organization can identify where obligations have shifted, merged, or changed in meaning.
2. Review governance and compliance documentation to ensure internal materials reflect the updated legal basis.
3. Conduct impact analysis across licensing, reporting, operations, risk management, and technology oversight areas.
4. Coordinate legal, compliance, risk, and business teams so interpretation and implementation remain aligned.
5. Build a forward-looking roadmap that treats PBI 10/2025 as a strategic regulatory platform, not merely a static compliance update.

Closing Note

PBI No. 10 of 2025 represents a fundamental shift in Indonesia’s payment system regulation. As an umbrella rule, it changes more than the numbering of obligations—it reshapes the compliance logic of the industry itself. For regulated entities, the real challenge is not simply reading the rule, but translating it into updated governance, control, and operational frameworks.

Bitlion supports this process through structured regulatory mapping, control analysis, and GRC implementation workflows.