OJK POJK 10/2022, Indonesian Fintech Lending Regulation

OJK POJK 10/2022 is the Indonesian regulation governing licensed peer-to-peer lending and fintech lending platforms. Issued by Otoritas Jasa Keuangan (OJK), Indonesia’s financial services authority, it replaced the earlier POJK 77/2016 with substantially tighter rules on licensing thresholds, prudential capital, conduct of business, and consumer protection.

• Licensing: minimum paid-up capital increased; OJK approval required for ownership changes; foreign ownership capped per current OJK rules.
• Conduct of business: borrower onboarding through verified channels; disclosure of the effective interest rate; prohibition on hidden fees.
• Collection conduct: no threats or intimidation; no third-party contact about debt; restricted contact hours; mandatory identification at the start of every interaction; full audit logs retained.
• Risk management: credit-scoring methodology disclosure to OJK; concentration limits; mandatory NPL reporting.
• Data protection: alignment with UU PDP (Personal Data Protection Law); customer data localization preferences.
• Complaints handling: an accessible complaints channel; OJK-monitored resolution timelines.

POJK 10/2022 codifies the collection-conduct envelope that applies regardless of whether the contact is human or AI-driven:

• No threats or abusive language.
• No third-party contact about the debt (family, employer, references).
• Contact within reasonable hours: typically 8am to 8pm Jakarta time, respecting borrower preferences.
• Identification at the start: the caller identifies the lending operator and themselves; AI agents identify as automated when asked.
• Honest disclosure: the outstanding balance, applicable fees, and the calculation basis.
• Channel honoring: if the borrower requests SMS only, voice contact is disabled.
• Full audit logs: every interaction (time, channel, content, outcome) retained per the OJK audit window.
• Accessible complaints: borrowers can file complaints directly with OJK.

UU PDP (the Personal Data Protection Law, 2022) governs personal data collection, processing, and disclosure in Indonesia generally. POJK 10/2022 governs fintech lending conduct specifically. They overlap on data privacy rules, but POJK 10/2022 is sector-specific and broader, covering lending operations beyond data handling.

Bahasa Indonesia is the regulatory baseline for customer-facing interactions. Regional dialects (Javanese, Sundanese, Balinese, Minangkabau) are appreciated by users, but Bahasa Indonesia is the floor. AI agents must default to Bahasa Indonesia and switch to regional dialects only on confirmed customer preference.

Nova for Finance is built around the POJK 10/2022 conduct envelope from the call-flow design level:

• Time-window enforcement: calls only fire between 8am and 8pm Jakarta time, with respect for borrower-specified preferences.
• Identification script at the start: the agent identifies the lending operator and itself as automated.
• Opt-out detection: if the borrower says "berhenti menelepon" or the English equivalent, the agent ends the call and the system marks opt-out.
• Channel honoring: if the borrower says "SMS saja", voice contact is disabled.
• Transcript and outcome logs: every interaction recorded with a full transcript, timestamp, and resolution, retained per the OJK audit window.
• No third-party contact: the agent does not call references or the employer.
• Native Bahasa Indonesia: voice and SMS templates, with no Google-Translate localization.