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OJK draft would require online lending platforms to fund a lender reserve and a liquidation fund

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Key points

Implications for lenders

Banks and other institutional funders of pindar platforms may gain some protection against operator failure, but the at least 5% reserve does not cover borrower default, so credit assessment of the platform's loans remains essential. Platforms planning funding lines may need to budget for a liquidation fund rising to IDR 2.5 bn and for lower net fee income once the rule applies.

Implications

ExecutivesPlatform operators should model the reserve as a cost on net fees and the liquidation fund as capital locked in deposits or government bonds from 2027.
InvestorsExpect weaker platforms below minimum equity to face added funding needs, which may speed consolidation if the draft is issued as described.
OperatorsInstitutional lenders funding pindar loans should track how the reserve is triggered and how fast funds are released in a wind-down.

Facts

Lender reserve: in written statements reported on 9 October, Agusman, OJK's chief executive for the supervision of finance companies, venture capital, microfinance and other non-bank institutions, said the draft amendment to POJK 40/2024 on technology-based joint funding would add Article 149A. Platforms would set aside at least at least 5% of the net platform fee from each funding disbursement 1 into a reserve that covers lender losses caused by the operator's errors or negligence. The money would sit in time deposits at commercial or Islamic banks and/or government securities; withdrawals would need OJK approval, and interest or coupons could fund operations. OJK said the aim is to strengthen lender protection.

Liquidation fund: draft Article 129A would require a liquidation preparation fund of at least at least 20% of the platform's required minimum equity. 2 It would start at IDR 500 m from fiscal year 2027 3 and rise to at least IDR 2.5 bn 4 within up to three years. 5 It could be used only for liquidation, with OJK approval; draft Article 129B lists sanctions from written warnings to fines. OJK targets issuing the amendment in 2026.

Other elements: the same draft would treat funding as bad only when it is more than 180 calendar days late, against more than 90 days today, 6 group platforms into four tiers by financial health, SME lending ratio and complaint record, and allow credit insurance or guarantees, whose design OJK is still discussing. In one liquidation now in its final stage, receivables of about IDR 3.04 bn are being assigned to 6 lenders to settle obligations. 7

Analysis

Time series: the industry TWP90 ratio, the share of pindar funding more than ninety days past due, was 4.73% in August (up from 4.32% in July), 8 up from 4.26% in June (chart). 16 platforms were above the 5% threshold, 9 and 10 of 94 platforms were below minimum equity in August. 10 The draft shifts part of the cost of platform failure from lenders to platforms before failure happens.

Scale: the target fund of IDR 2.5 bn equals at least 20% of the IDR 12.5 bn minimum equity. 11 Against outstanding pindar funding of IDR 106.94 trn, 12 the fund is sized to pay for an orderly wind-down, not to absorb credit losses; the lender reserve, funded from fees, would grow with each platform's disbursement volume.

Online lending TWP90 (90+ day arrears) (%)
02464.622026-044.422026-054.262026-064.322026-074.732026-08
Online lending TWP90 (90+ day arrears) (%)
2026-044.62
2026-054.42
2026-064.26
2026-074.32
2026-084.73

Industry-wide share of licensed P2P (pindar) loans more than 90 days past due (OJK TWP90), month-end · Source: OJK monthly Board of Commissioners press releases (RDKB) (2026-04, 2026-05, 2026-06, 2026-07, 2026-08)

Counterpoints and uncertainties

This is a draft; percentages, timelines and the tier rules may change before issuance, and OJK has not published a final date. The reserve covers losses from operator error or negligence, not ordinary borrower default, so lenders still bear credit risk. A longer bad-loan cut-off could also make reported bad-funding ratios look lower without any change in repayment behaviour.

Key figures

  1. Draft lender-protection reserve (pindar): at least 5%. Minimum share of the net platform fee from each funding disbursement to be set aside for lender losses caused by operator error, under draft POJK 40/2024 amendment. Licensed online lending (pindar) platforms, draft rule. Basis date: 9 Oct 2026. Source: Katadata: OJK Akan Wajibkan Pinjaman Daring Sisihkan 5% Fee untuk Dana Perlindungan Lender (2026-10-09)
  2. Draft liquidation fund (pindar), share of minimum equity: at least 20%. Minimum liquidation preparation fund as a share of the platform's required minimum equity, under draft POJK 40/2024 amendment. Licensed online lending (pindar) platforms, draft rule. Basis date: 8 Oct 2026. Source: Kontan: Aturan Baru Fintech Lending Bakal Diwajibkan Bentuk Dana Persiapan Likuidasi (2026-10-09)
  3. Draft liquidation fund (pindar), initial amount: IDR 500 m. Minimum initial liquidation preparation fund, to be formed from fiscal year 2027. Licensed online lending (pindar) platforms, draft rule. Basis date: 8 Oct 2026. Source: Kontan: Aturan Baru Fintech Lending Bakal Diwajibkan Bentuk Dana Persiapan Likuidasi (2026-10-09)
  4. Draft liquidation fund (pindar), target amount: IDR 2.5 bn. Minimum liquidation preparation fund to be reached gradually after the initial amount. Licensed online lending (pindar) platforms, draft rule. Basis date: 8 Oct 2026. Source: Kontan: Aturan Baru Fintech Lending Bakal Diwajibkan Bentuk Dana Persiapan Likuidasi (2026-10-09)
  5. Draft liquidation fund (pindar), build-up period: up to three years. Period within which the liquidation fund must grow from the initial amount to the target. Licensed online lending (pindar) platforms, draft rule. Basis date: 8 Oct 2026. Source: Kontan: Aturan Baru Fintech Lending Bakal Diwajibkan Bentuk Dana Persiapan Likuidasi (2026-10-09)
  6. Bad-funding cut-off for online lending (OJK draft): more than 180 calendar days (proposed; currently more than 90 days)
    Draft; no effective date published. OJK said the change aligns pindar collectibility with bank rules.
    . Days past due after which pindar funding would be classed as bad under OJK's draft amendment to POJK 40/2024. Licensed online lending (pindar / P2P) platforms. Basis date: 8 Oct 2026. Source: CNBC Indonesia: OJK Mau Perpanjang Batas Kredit Macet Pinjaman Online Jadi 180 Hari (2026-10-08)
  7. Receivables assigned to lenders in a pindar liquidation: about IDR 3.04 bn. Receivables assigned to lenders to settle obligations of one pindar platform in the final stage of liquidation, per OJK. One licensed pindar platform in liquidation. Basis date: 13 Oct 2026. Source: CNBC Indonesia: Banyak Pinjol Bangkrut, OJK Siapkan Aturan Baru Lindungi Lender (2026-10-13)
  8. Online lending TWP90 (90+ day arrears): 4.73% (up from 4.32% in July). Share of outstanding loans more than ninety days past due, industry-wide (OJK TWP90). Licensed online lending (pindar / P2P) platforms. Basis date: 31 Aug 2026. Source: OJK: Siaran Pers RDKB September 2026 (SP 185/OJK/DKPU/X/2026, 2026-10-05)
  9. Platforms with TWP90 above threshold: 16 (unchanged from July). Number of pindar platforms with TWP90 above 5%. Licensed online lending (pindar / P2P) platforms. Basis date: 31 Aug 2026. Source: CNBC Indonesia: OJK Mau Perpanjang Batas Kredit Macet Pinjaman Online Jadi 180 Hari (2026-10-08)
  10. Online lenders below minimum equity: 10 of 94 (up from 7 in July)
    The July count is from OJK's September 2026 board press release (RDKB August 2026).
    . Licensed P2P platforms with equity below the IDR 12.5 bn minimum. Licensed online lending (pindar / P2P) platforms. Basis date: 31 Aug 2026. Source: Infobanknews: OJK catat pembiayaan pindar Rp106,94 T pada Agustus 2026 (2026-10-05)
  11. Online lending minimum capital: IDR 12.5 bn. Minimum equity required of pindar platforms. Licensed online lending (pindar / P2P) platforms. Basis date: 31 Jul 2026. Source: Okezone: Warga RI Terlilit Utang Pinjol Rp105,6 Triliun (2026-09-08)
  12. Online lending (pindar) outstanding: IDR 106.94 trn (up from IDR 105.63 trn at end-July). Outstanding loans of licensed peer-to-peer lending platforms. Licensed online lending (pindar / P2P) platforms. Basis date: 31 Aug 2026. Source: Infobanknews: OJK catat pembiayaan pindar Rp106,94 T pada Agustus 2026 (2026-10-05)

Sources

  1. Kontan: Aturan Baru Fintech Lending Bakal Diwajibkan Bentuk Dana Persiapan Likuidasi (2026-10-09)
  2. Katadata: OJK Akan Wajibkan Pinjaman Daring Sisihkan 5% Fee untuk Dana Perlindungan Lender (2026-10-09)
  3. CNBC Indonesia: Banyak Pinjol Bangkrut, OJK Siapkan Aturan Baru Lindungi Lender (2026-10-13)
  4. OJK: Peraturan OJK Nomor 40 Tahun 2024 (POJK 40/2024)primary
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Reports are for information only and are not investment advice.

A Japanese version of this article is available: 日本語版

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