🧠 Food for thought

Implications, context, and why it matters.

Sparse cross-border results from the 2018 MoU keep the renewal’s impact unclear

• The 2018 MoU promised information sharing plus joint innovation and set up a framework to help fintechs navigate each regime while lowering entry barriers 1. Public releases do not list outcomes like cross-jurisdiction sandbox referrals or joint pilots from that deal.
• The market moved from nascent peer-to-peer (P2P) lending to 97 licensed P2P firms and 427 payment providers by 2025 2. Domestic rules plus tooling drove that shift, including OJK Regulation 40/2024 with regulatory sandbox regimes, which are supervised test environments for new financial services 3.
• Renewed MoU mentions joint pilots with knowledge sharing across sandboxes, digital financial assets, and AI, echoing the 2018 agreement 41. OJK now focuses on AI ethics guidance plus crypto-asset licensing 25, so cross-border execution under the renewal merits close tracking.

Regulatory technology (regtech) vendors can tackle cross-border compliance gaps in sandbox coordination and AI governance

• Eight participants sit in OJK’s sandbox 5. Vendors can build tools that guide fintech firms through both jurisdictions’ processes as OJK reviews ten more crypto-asset trader licences 5.
• Indonesia released a Code of Ethics for Responsible AI in fintech 2. Licensed players, including 97 P2P lenders and 427 payment providers 2, need tools that map Indonesian guidance against Singapore’s standards.
• OJK set a 12-month licensing deadline for existing aggregators (comparison or distribution platforms) under Regulation 4/2025 6, while the Bappebti-OJK working group (Badan Pengawas Perdagangan Berjangka Komoditi, Indonesia’s commodity futures regulator) runs until January 2026 5.