Update on Peer-to-Peer Lending Industry – Amendment to UUP2SK

How does the UU No.4/2026 (Amendement to UUP2SK), affect the P2P industry? Our Rizki Dwianda, supported by associates Felisitas Anjani and Shafa Mirelda Hartadi, shared his perspective.

UU No. 4/2026 does not change the rules for LPBBTI (P2P lending). It changes the perimeter around them.

Articles 106 and 111–128 of the original UUP2SK stand, and POJK 40/2024 remains the technical reference. What moved sits around it — in three places.

First, Article 213(1) now folds raising and channelling funds into the scope of ITSK, the innovation regime built for payments, digital assets and market infrastructure. A lender touching crypto collateral, tokenised receivables or stablecoin settlement can end up inside two regimes, and two associations.

Second, Article 247 lets Satgas PASTI (the Financial Sector Task Force) reach licensed firms, not only unlicensed ones, where there’s an indication of breach in collection practice or data use. A licence is no longer a shield.

Third, Articles 278A–278O put OJK investigators alongside POLRI for financial-sector crimes. Findings that once closed with an administrative sanction can now escalate into a criminal referral.

The parameters for all three sit in implementing regulations that don’t exist yet.

That gap is where the discussion kept returning at this week’s Expert Lab with AFTECH (Asosiasi FinTech Indonesia) and Hukumonline (Hukumonline. com), 55 people from 28 companies, questions running to the end.

Thanks to the AFTECH policy team, Hukumonline, and HKHSK for the session.