Member of the Board of Governors Regulation Number 3 of 2026 Expands Non-Bank Access and Introduces FICT Services in BI-FAST

Introduction

On March 2, 2026, Bank Indonesia issued Member of the Board of Governors Regulation Number 3 of 2026 on the Third Amendment to Member of the Board of Governors Regulation Number 17 of 2023 on the Implementation of Bank Indonesia-Fast Payment (“PADG 3/2026”), which will take effect on March 31, 2026. PADG 3/2026 expands the participation of Bank Indonesia-Fast Payment (“BI-FAST”) by enabling non-bank institutions to participate, introduces an inter-institutional liquidity transfer scheme, and sets technological capability and security standards for participants.

PADG 3/2026 re-regulates the scope of BI-FAST implementation, including provisions on participation, types of transaction services, and technological standards that participants must meet. In its considerations, Bank Indonesia states that these provisions are necessary to support the development of the digital payment system and the integration of the digital economy and finance, as directed in the Indonesia Payment System Blueprint. Bank Indonesia also considers that the implementation of payment systems requires adequate risk management, operational reliability, and information technology infrastructure capable of supporting fast, easy, and secure payment transactions.

Comparison

PADG 3/2026 amends several provisions in Member of the Board of Governors Regulation Number 17 of 2023 on the Implementation of Bank Indonesia-Fast Payment (“PADG 17/2023”) as last amended by Member of the Board of Governors Regulation Number 14 of 2025 on the Second Amendment to Member of the Board of Governors Regulation Number 17 of 2023 on the Implementation of Bank Indonesia-Fast Payment (“PADG 14/2025”). The following is a comparison between PADG 3/2026 and PADG 17/2023 and PADG 14/2025:

Key Provisions

Expansion of BI-FAST Participant Categories to Non-Bank Institutions

Under Article 7 paragraph (2) and Article 8 paragraph (2), this regulation governs the parties eligible to become BI-FAST Participants. In addition to Commercial Banks, Payment System Infrastructure Providers act as Direct Participants (Peserta Langsung, “PL”), while Payment Service Providers in the form of Non-Bank Institutions act as Indirect Participants (Peserta Tidak Langsung, “PTL”). This provision enables e-wallet and payment gateway providers to connect to BI-FAST without the need to use a bank as an intermediary.

Inter-Participant FICT Services

Based on Article 3 paragraph (3) letter a and Article 103A, PADG 3/2026 regulates the Financial Institution Credit Transfer (FICT) service in addition to inter-customer transaction services within BI-FAST, which include ICT, RFP, BCT, and DDT. The FICT service is utilized for fund transfers between Participants or for the settlement of Payment System Infrastructure Provider transactions through the BI-FAST system in real time.

TIKMI Compliance Criteria

Article 17 paragraph (1a) stipulates the obligation of Participants to fulfill the criteria of Transactions, Interconnection, Competence, Risk Management, and Information Technology Infrastructure (Transaksi, Interkoneksi, Kompetensi, Manajemen Risiko, dan Infrastruktur Teknologi Informasi, “TIKMI”). This provision requires Participants to ensure the readiness of their information technology systems and infrastructure so that they remain secure, reliable, and compliant with the provisions set forth by Bank Indonesia, including in the management of systems and technology used in the implementation of BI-FAST services.

Transaction Nominal Limits and Pricing Schemes

In accordance with Article 4 letter g, Bank Indonesia establishes policies regarding transaction nominal limits and BI-FAST service pricing schemes. This provision grants Bank Indonesia the authority to set and adjust the transaction nominal limits and pricing schemes for BI-FAST services through announcements or technical provisions issued by Bank Indonesia.

Payment System Business Plan

Referring to Article 10 paragraph (3) letter b, Participants from the Non-Bank Institution Payment Service Provider element must possess a strategic business plan for BI-FAST development. Furthermore, under Article 30 paragraph (3a), any Participant intending to submit a voluntary participation closure is required to have included the closure plan in the Payment System Business Plan (Rencana Bisnis Sistem Pembayaran, “RBSP”) approved by Bank Indonesia.

Handling Mechanisms for Abnormal or Emergency Conditions

The definition of abnormal conditions is set forth in Article 1 number 28 of PADG 3/2026. Additionally, the annex contains procedures for handling disruptions to the implementation of BI-FAST. Under certain conditions, Bank Indonesia provides the BI-FAST Portal facility, which can be used as a contingency mechanism by the sponsor bank in the event of a disruption to the Participant's system or location. This facility allows the operational processes of the service to continue through an alternative mechanism in accordance with procedures established by Bank Indonesia.

Administrative Sanctions and Status Downgrades

Administrative sanctions are stipulated in, among others, Article 17 paragraph (3), Article 40B paragraph (4), and Article 103C. These provisions encompass the issuance of written warnings, the imposition of payment obligations, and the downgrading of participation status. The downgrading of participation status from Direct Participant to Indirect Participant may affect the transaction processing and liquidity management mechanisms conducted by the Participant in the implementation of BI-FAST services.

Closing

PADG 3/2026 introduces several changes to the implementation of BI-FAST, including provisions regarding Participant categories encompassing banks as well as Payment System Infrastructure Providers and Payment Service Providers from the Non-Bank Institution element, the introduction of the Financial Institution Credit Transfer (FICT) service for inter-Participant fund transfers, and the obligation to fulfill TIKMI criteria. Furthermore, provisions regarding the payment system business plan, operational disruption handling mechanisms, and the imposition of administrative sanctions are also part of the regulations in the implementation of BI-FAST services. Participants from the Payment Service Provider element originating from Non-Bank Institutions are also required to meet the minimum paid-up capital requirements in accordance with the participation provisions. These amendments must be noted by both banks and non-bank institutions participating in BI-FAST, particularly in ensuring system readiness, fulfilling operational and information technology requirements, and executing administrative obligations upon the effective date of PADG 3/2026 on March 31, 2026.