ISO 27001 as a Strategy to Meet TIKMI Requirements under PBI 10/2025 and PADG 32/2025

Executive Summary

For Payment System Providers (PSPs) in Indonesia, compliance with TIKMI requirements under PBI 10/2025 and PADG 32/2025 is becoming a critical governance and regulatory priority. One practical strategy for approaching this requirement is to use ISO 27001 as the foundational management system for building, documenting, and evidencing information security controls.

While ISO 27001 does not automatically guarantee compliance with Bank Indonesia regulations, it can provide a structured and efficient framework for mapping mandatory controls, identifying regulatory gaps, and building a defensible compliance roadmap.

Why ISO 27001 Matters for TIKMI

TIKMI obligations under PBI 10/2025 and PADG 32/2025 require PSPs to show that information-technology risk and security controls are implemented in a robust and auditable manner. ISO 27001 is relevant because it offers a recognized management-system approach for governing information security through risk assessment, control selection, documentation, internal review, and continuous improvement.

For regulated entities, this can reduce compliance fragmentation. Instead of treating each regulatory clause as a stand-alone checklist item, organizations can use ISO 27001 as the operational backbone for organizing governance, risk, and control evidence.

What Companies Should Do

1. Map TIKMI requirements against ISO 27001 controls to identify where current regulatory obligations are already covered and where specific local requirements create additional compliance needs.
2. Conduct a structured gap analysis to determine whether existing policies, processes, technical safeguards, and governance artifacts are sufficient for both certification logic and Bank Indonesia expectations.
3. Build an implementation roadmap that prioritizes high-impact control gaps, assigns ownership, and sets realistic remediation timelines.
4. Prepare evidence and governance documentation so the organization can demonstrate not only policy adoption, but also actual implementation and oversight.
5. Use a GRC platform to centralize obligations, controls, risks, testing, and audit trails in one compliance workflow.

Bitlion View

From Bitlion’s perspective, ISO 27001 is best understood not as a shortcut to local regulatory compliance, but as a strategic control architecture. For PSPs facing TIKMI obligations, the value of ISO 27001 lies in its ability to create structure, traceability, and accountability across compliance workstreams.

This is especially important where organizations need to coordinate legal, compliance, security, technology, and internal audit teams under a single framework. A well-managed control environment can make regulatory response faster, more consistent, and easier to defend.

Closing Note

Meeting TIKMI requirements under PBI 10/2025 and PADG 32/2025 requires more than policy drafting. It requires a control environment that is operational, evidence-based, and aligned with regulatory expectations. ISO 27001 can be a strong strategic foundation for that effort—provided it is paired with local regulatory mapping, gap analysis, and disciplined implementation.

Bitlion supports this process through structured GRC workflows for control mapping, remediation tracking, and audit-ready compliance evidence.