%

Rp

Whitepaper:
Understanding the role of
Payment Gateways in
Indonesia’s digital economy
Outline
Foreword

Introduction: A brief history of cashless payments in Indonesia

Indonesia is forging its own path towards a society that’s less dependent on cash. The evolution of cashless
payments systems in this country is unique because Indonesia is highly decentralized, traditionally has low credit
card ownership and has made a quick leap towards mobile internet adoption. However, cash, bank transfers
and over the counter transactions are still the dominant payment behaviors.

Chapter 2: What are Payment Gateways?

Most commonly associated with the ecommerce sector, Payment Gateways help online businesses collect
payments from shoppers by making it easy to connect with different banks and payment channels with one
software integration.

Chapter 3: The role of Payment Gateways in the digital economy

They are an accelerator to the digital economy and particularly relevant for young businesses. Payment Gateways
can quickly adapt to service new niches and new payments trends. They can evolve to offer more features like
fraud detection.
3.1 The role of Payment Gateways in ecommerce
Payment Gateways service a variety of ecommerce payment scenarios, like instant payments or subscription
payments. They are ideal to support micro, small and medium enterprises in their digitization.
3.2 The role of Payment Gateways in peer-to-peer lending
Peer-to-peer lending is a growing new sector that stands to benefit from working with PGs to simplify
payments collection from borrowers and pooling money from lenders.

Chapter 4: Different models of Payment Gateways in Indonesia

4.1 Aino
4.2 Cashlez
4.3 Midtrans
4.4 Xendit
4.5 Sepulsa

Chapter 5: How businesses work with Payment Gateways

5.1 Case Zalora
5.2 Case Investree

Chapter 6: The current state of regulation

Indonesia is entering a phase of tightening regulation for payments processing. The industry welcomes clarity
and oversight, but also fears a stifling of innovation. Especially new entrants and startups suffer from the long
and costly processes needed to achieve compliance.

Chapter 7: Regulation elsewhere

Indonesia’s regulations around payments processing are perhaps best comparable to India. However, there are
differences in approach, mostly in the way payments processing business models are described.

Chapter 8: The future of Payment Gateways

PGs are necessary in an effective digital economy and accelerate its growth. The PG model will continue to
diversify and find new niches and ways of servicing different types of payments needs and related services.

Pg. 1
Foreword

“ Indonesia’s
payments landscape is in a phase of rapid
Foreword
transformation and can be difficult to comprehend

for outsiders looking in. This paper was initiated

by the Indonesian Fintech Association (fintech.id)

to offer an overview of the cashless payments

landscape in Indonesia and the specific role of

Payment Gateways within it.

“
The insights are based on results from a workshop

held in Jakarta in July 2018 and in-depth interviews

conducted with financial technology companies

(fintechs), banks, and law experts.

Pg. 2
Introduction: A brief history of cashless
payments in Indonesia
Indonesia is undergoing a rapid transition from a predominantly cash-based society to one where cashless
transactions are becoming more common and more people are gaining access to banking and other financial
services.

Multiple stakeholders have an interest in making this transition happen: banks benefit from a growing customer
base. For the government, cashless transactions promise more transparency and ways to enforce tax collection and
fight corruption. For consumers, banking services and cashless transactions offer convenience, security, and new
ways to invest, or access credits and loans.

Overall, Indonesia is making progress as more and more people have access to the formal banking system.

In the World Bank’s last official account1, 48.9% of people 15 years old or above had bank accounts. This figure
has drastically improved since the 36.1% that were measured in 2014. Initiatives to extend the reach of bank
branches even to rural customers have had some effect. However, Indonesia still lags behind peers like Thailand,
Malaysia, and certainly Singapore when it comes to the distribution of cashless payments instruments, in particular
payments for goods and services purchased online.

Indonesia historically has had a low rate of credit card ownership, lower than most other countries in Southeast
Asia with an estimate of only 9 million unique credit card holders in the country. Debit cards on the other hand are
quite common, with an estimated 152.6 million currently in circulation2.

The caveat is that there’s a lack of acceptance points for debit and credit cards. While it’s possible to pay with cards
in established businesses and chain retail stores, small businesses often do not have that option. Debit cards are
also only very slowly finding acceptance as a means for online payments.

96%
81%
78%

35% 36%
31%
28%
20%
BANK BANK
6%
ACCOUNT CREDIT ACCOUNT CREDIT
BANK
ACCOUNT CREDIT BANK
2% BANK
2% BANK
3%
CARD CARD CARD ACCOUNT CREDIT
CARD
ACCOUNT CREDIT
CARD
ACCOUNT CREDIT
CARD

SINGAPORE MALAYSIA THAILAND INDONESIA VIETNAM PHILIPPINES

Credit Cards in South East Asia. Source: Global Findex Database 2017, World Bank.

1 https://globalfindex.worldbank.org/
2 https://www.bi.go.id/id/statistik/sistem-pembayaran/apmk/contents/jumlah%20apmk%20beredar.aspx

Pg. 3
 Digital Training for MSME by Ministry of Foreign Affair and Google. Photo Credit: Ministry of Foreign Affairs

When the internet first started taking hold in Indonesia, are more than an added convenience for Indonesia.
a system of online payments evolved that relied on They are tools that can significantly contribute to the
trust. Shoppers would pay in advance and send the country’s economic development.
seller a proof of payment, or the seller would send
the product and let the shopper pay in cash. Fairly Most importantly, Indonesia has to forge its own path
widespread was also a system of vouchers - where a when it comes to shaping and applying these tools in
shopper pays over the counter to receive a code that its move towards a cashless society.
can be redeemed for online purchases.
Models from other countries won’t fully apply here. In
These systems rely on manual labor and are error- the US for example the path to cashless payments was
prone. Even so, it still excluded many micro, small, and entirely different. The internet was widespread long
medium enterprises (MSME), which were operating before smartphones and the mobile internet came
offline and hadn’t adopted any digital systems for along, and almost every household has a credit card
bookkeeping or customer service. to use for cashless transactions. That made the need
for mobile financial services much less pressing.
By the government’s own acknowledgement, MSME
form the backbone of Indonesia’s economy. Official China could offer a model for mobile payments, but its
figures from 2016 claim that MSME contribute 60% highly centralized government, relatively homogenous
to Indonesia’s GDP and account for 107 million jobs, culture, and more advanced economy created a
although these are mostly informal workplaces and vastly different landscape compared with archipelagic
many of these enterprises do not pay taxes. Indonesia and its diverse languages and cultures.

Increasing the productivity of MSME, which includes Much of the existing literature, at least in English,
introducing them to banking services, cashless describes the evolution of cashless payments from a
payments, and digital tools to help them grow - and western-centric viewpoint, which has the effect that
eventually become tax-paying entities - constitutes a the common models and phrases used to discuss
long-term strategic government goal3. payments are based on a scenario in which credit card
payments are common.
With the advent of the mobile internet and a
broad acceptance of smartphones the pace of this In addition, the speed of change occurring for example
development has been immensely accelerated. in areas like mobile payments in emerging economies
is unprecedented, with innovations happening at once
Indonesia’s traditional banking sector, given the size and a regulatory environment that’s playing catch-up
and geography of the country, is limited in its ability to with what’s happening on the ground.
reach everyone.
While this is a potential tipping point in Indonesia’s
This means mobile banking and the alternative financial development, it also creates a degree of complexity that
services offered by non-bank financial companies can be confusing, especially for outsiders looking in.

This paper tries to take that into account as much

as possible and tries to provide local context where
3 http://www.ilo.org/jakarta/info/public/pr/WCMS_561816/lang-
-en/index.htm
necessary.

Pg. 4
What are Payment Gateways

In this paper, we are exploring the role of Payment

Gateways in Indonesia’s digital economy - a business
model that sits within the diverse landscape of entities
necessary to facilitate cashless payments.

As we have discussed, much of the accessible literature

on the history of cashless payments tends to take a
?
Western-centric viewpoint, and the same is true for
Payment Gateways (PG). In their most basic form, PGs would have been
optimized to help online merchants accept credit card
PGs are now most commonly associated with the payments - because that was the most convenient and
era of ecommerce. The page that lets you input your secure way to handle online payments in the US at the
credit card details or choose from a number of other time this model was popularized.
payment options when you want to complete an
online purchase is typically created by a PG. In a simplified way of putting it, the PG is integrated
into the merchant’s online shop. It receives and
It’s often a third-party application the online merchant transmits information from the online shopper
does not develop himself/herself, because payments and forwards it to a Processor, such as a credit card
processing requires high levels of security and reliability. institution. After the green light is given that the data
Hence, this process is outsourced to a third party PG checks out, the Processor forwards information to the
who specializes in this service. merchant’s bank and the shopper’s bank.

1
CONSUMER MERCHANT’S INTERNET
BUSINESS

ACQUIRER
OR
PAYMENT
MERCHANT’S GATEWAY
BANK
2
Rp 9
7

4 3

5 6
CUSTOMER’S CREDIT CREDIT CARD MERCHANT
CARD ISSUING BANK NETWORK BANK’S
PROCESSOR

Credit card payment transaction.

Source: https://www.secureclub.net/Help/acm/UG/ug_Ccard_gateway.htm

Pg. 5
There are some differences when it comes to how PGs handle merchant accounts. Some collect merchants under
one account before linking up with the banks - this is the so-called aggregator model. There are PGs that connect
each merchant directly with the banks - these are called facilitators.

The PG becomes more useful the more payment methods it accepts. This can cover different types of credit cards
and debit cards from different networks, or online banking where you log in with username and a password to
complete the transaction. But this can also expand to entirely different payments instruments, for example mobile
money.

It depends on what types of payments are popular in a specific market. In the case of Indonesia, PGs have evolved
to accept bank transfers from multiple banks and even so called online-to-offline or over-the-counter transactions,
where the interface instructs the shopper to go to a physical store to make the payment in cash, or via an ATM,
after which the online transaction is completed.

Checkout pages with an overwhelming amount of payment options are common sight in Indonesia.

The payment options on Tokopedia, a popular online marketplace in Indonesia

PGs, in short, make payments collection for merchants

and shoppers more convenient and safer. Instead of From the perspective of banks, PGs are a way to
negotiation the terms of collaboration with each bank mitigate risk. Instead of working with millions of
and payment channel by themselves, merchants get individual merchants and letting them connect to
access to all of them in one go. That’s particularly their systems directly, banks can work with trusted PG
relevant for MSME who don’t have the size and the and let them work out how to target merchants in
resources to establish individual relationships with different niches.
banks.

Pg. 6
A broader view on Payment Gateways
After this general introduction of PGs, it’s important to mention that companies who do not first and foremost
facilitate online shopping transactions may also act as PG.

Technology companies that facilitate cashless payments offline also fall into this bucket. In Indonesia, an example
would be companies that create the terminals you tap a prepaid card on to deduct the fare as you pass through a
toll road gate. These are also PGs, but they operate in a different ecosystem.

Furthermore, as the cashless payments landscape consists of many entities and each payment passes through
different steps, each of those steps can also be seen as a “gate,” and the companies facilitating them could be
considered a PG or self-classify as a PG.

Here’s an overview of companies that self-classify as PGs in Indonesia, from data provided by the Indonesian
Fintech Association. They all deal with cashless payments to some degree, but might not fit into the narrow,
ecommerce-optimized definition of PGs as we have described them in the beginning of this chapter.

Companies registered as Payment Gateways with the Indonesian Fintech Association

There’s an additional element of confusion in the terminology in Indonesia, where regulators are currently working
on the implementation of a so-called “National Payment Gateway” (locally known as Gerbang Pembayaran
Nasional, or GPN).

The GPN refers to an infrastructure for cashless payments that sits below the consumer-facing side of payments
transactions. Its aim is to increase interoperability between banks in the country, and to keep payments processing
within national borders instead routing them across international payments processors. Although the GPN, once
fully implemented, will affect the way PGs connect with the GPN infrastructure, the GPN itself is not subject of
this paper.

Pg. 7
The role of Payment Gateways
in the digital economy
As we have seen in the previous chapter, with a In contrast to the government projection which does
broad definition, PGs sit pretty much everywhere in not offer a more detailed breakdown of the numbers,
the cashless payments ecosystem, whether for online the Temasek/Google report more narrowly defines the
payments, prepaid, or credit card payments. digital economy as covering ecommerce, online travel,
ride-hailing, and digital advertising.
Even if we narrow it down to PGs in the context of
online shopping, there are still a variety of different
applications and business models to consider, and Ecommerce

their impact on the digital economy is immense.

Travel
PGs help online merchants speed up the process of
collecting payments, and they serve banks by helping
them mitigate risk and capture a much larger pool of Rides
merchants.

There are different projections for the development of Ads

Indonesia’s digital economy:

The government’s own estimate sees the collective (US$ billion)

0 5 10 15 20 25 30 35 45 50
worth of Indonesia’s online transactions grow from 2015 2025
about US$12 billion in 2014 to US$130 billion by
20204. Google/Temasek estimate of the size
of Indonesia’s e-economy sectors (from 2016)

2020
140 In both scenarios, the projected figures are unlikely
to be achieved if there’s no push towards further
120
adoption of cashless payments in Indonesia, and if it
weren’t for PGs to speed up the process.
100

80 Consider the thousands informal sellers who use

(US$ billion)

social media like Instagram or Facebook to reach

60 customers. One one hand, they have proven that they
can manage transactions purely based on trust. If you
40
2016
like an item you see on an Instagram shop, you would
2014
chat with the merchant, ask for payment details, make
20 a transfer, send the merchant a proof of transfer, and
hope the merchant lives up to their end of the bargain
0
and sends the item.
Government estimate of e-commerce transaction volume in Indonesia

An estimate from a 2016 study conducted by Temasek

and Google says Indonesia’s digital economy was
worth under US$10 billion at that time, and projected
it to grow to US$80 billion by 20255.

4 https://in.reuters.com/article/indonesia-retail-idINKCN0WA0D4
5 https://www.techinasia.com/google-temasek-ecommerce-data-
indonesia

Pg. 8
 Typical payment process on Instagram. Bank details and proof of payment are sent via chat

It’s estimated that about a third percent of ecommerce transactions happen this way6. While this is effective and
easy for sales at a very small scale, the system is prone to fraud, and becomes difficult to maintain for higher priced
items and once order volumes grow.

There’s an additional caveat in Indonesia. The country has over 100 commercial banks, and transferring money
from one to the other can result in high fees. That means if your customer’s account is at a different bank than
yours, he or she may balk at the transaction fees and you lose an order. Operating this way limits the growth
potential of these budding businesses.

At the other end of the spectrum sit merchants who are selling online at a very high volume, and know their
market and their customers’ payment habits well.

At that stage, it might make sense for them to work on their own bank integrations instead of funneling transactions
through a PG. However, this is costly and requires being able to develop applications that adhere to global security
standards. This approach also requires putting resources into it continually, because payment habits change and
new payment channels must be added so serve customers - especially in Indonesia, where payment habits are
changing rapidly.

The role of Payment Gateways in ecommerce

We have already discussed the role of PGs in online shopping transactions, as this is the most common use case.

We can break it down further into different online shopping scenarios. Let’s get back to the micro merchants who
sell informally through social media.

If you’ve done online shopping in Indonesia, you’ll notice that sellers switch fluidly from one platform to another.
Some prefer finding customers on Instagram, and direct them to Tokopedia to complete the purchase. In effect,
they are using Tokopedia as a PG.

It also happens the other way round: Sellers run a shop on a marketplace like Bukalapak or Tokopedia, but then
invite interested customers to their Instagram channel to discuss and complete the purchase manually.

6 https://www.techinasia.com/indonesia-ecommerce-online-shopping-2014

Pg. 9
 Seller redirecting potential customer from an online marketplace to their Instagram to complete a purchase

This goes to show that both social engagement and a more trustworthy payment mechanism are important to
sellers, and they cleverly arrange their sales process in a way that works best for their business.

As a next step beyond social selling or online marketplaces like Tokopedia, where there are few options to customise
the appearance or the user experience, merchants could try using ready-made software like Shopify or Jarvis Store
to create an online store. This type of software is typically cloud hosted and already comes with the necessary
features an online shop needs, including a checkout and payments process, but is designed so that you can alter
the appearance and make the whole shop more suited to your brand.

Jarvis Store for example, developed by an Indonesian tech startup, lets customers choose their online store layout
from a variety of templates that can be further customized. It includes multiple payment options (here, Jarvis
Store offers plugins created by various third party PGs), and other online merchant features like sales statistics and
reports.

Jarvis Store, an Indonesian company that offers ready to use web templates brands can customize to start selling online

Pg. 10
If merchants want an even more customized experience and are willing to invest, they can develop their own
branded online shop, which is then completely self-managed. But this requires technical skills, and merchants
would still need to make a decision about how to handle payments and most likely work with a third party PG to
solve that problem.

As online shopping scenarios continue to evolve diversify, so do PGs.

Consider merchants who want to offer subscription-based services and other recurring payments. This requires a
different kind of user interface, and must guarantee safe storage of the shoppers’ payment information.

PGs can also extend their services to facilitate the reverse of incoming payments, for example in the case of
refunds, where a payment made by a shopper eventually has to find its way into the shoppers’ bank account.
These cases, if handled by an online seller manually, are extremely time consuming, error prone and can result in
a negative experience for the online shopper who then might not return for future purchases - a lost opportunity
for the online seller.

To address specific payment needs, lets say accepting international credit cards versus highly localized forms of
payment, like over-the-counter at partner stores, one online shop can work with multiple Payment Gateways. The
different gateways are then integrated into a unified user experience. This is not uncommon, especially for larger
ecommerce platforms.

The role of Payment Gateways

in peer-to-peer lending
While ecommerce makes up the most visible part In P2P lending, funds are collected from those willing
of the digital economy, the rising sector of online to lend money and disbursed to borrowers, like small
lending factors into it, too. business. Borrowers typically pay back in installments,
and these eventually reach the lenders bank account.
In so-called peer-to-peer (P2P) lending, people can
lend each other money through an online platform. P2P platforms would want to make payment as easy
For borrowers it’s an opportunity to get cash when as possible for borrowers, and keep transaction fees
it’s needed, for example to expand a business or pay low no matter what bank or channel lenders and
a hospital bill. For lenders, it’s an investment. They borrowers prefer. This complex transaction system can
expect to be paid back with interest on top. be supported by PGs.

P2P lending, while still in its infancy, is expected to In an environment where integration with multiple
grow in relevance in the coming years. Again, it’s to banks could take substantial amount of time, many
fill a gap that should be beneficial mostly to micro-and P2P platforms prefer working with PGs so that they
small businesses who might be too small to be eligible don’t have to establish individual link ups with banks
for a loan from a bank. and can focus on other aspects of their business.

The Asian Development Bank estimates there’s a Working with PGs can also benefit P2P lending by
US$67 billion credit deficit in the country, creating the types of cash management products that
meaning the national demand for credit is outpacing are required by lending regulators - such as virtual
banks’ ability to provide it. The World Bank and IFC accounts and escrow accounts.
went even further by estimating a US$ 166 billion SME
lending gap in Indonesia, which is as much as 19% of However, P2P lending is not regulated by the Central
the country’s GDP.7 Bank and falls under the purview of a different
regulator, namely the Financial Services Authority of
Regulators are keeping a close watch on this space Indonesia (OJK).
to prevent fraudulent players from taking root.
Meanwhile, some of the pioneering P2P lenders that OJK’s regulations do not explicitly reflect the role of
have complied with regulations are beginning to see PGs in lending. The existing regulatory environment
traction, like Investree and Modalku. hence hasn’t yet fully leveraged PG to facilitate P2P
lending transactions -- a topic we’ll explore further in
Chapter 6
7 http://documents.worldbank.org/curated/
en/653831510568517947/MSME-finance-gap-assessment-of-the-
shortfalls-and-opportunities-in-financing-micro-small-and-medium-
enterprises-in-emerging-markets

Pg. 11
Different models of Payment
Gateways in Indonesia

PGs are already important enablers for ecommerce, and they are finding a new niche in the rising sector of
P2P lending. And there are other types of PGs serving individual payments ecosystems - they may not even be
considered PGs if a very narrow description is applied.

Here’s a look at some of the different types of companies in Indonesia that are PGs and/or offer PG-like functions.

Example: Aino
a PG for micro-payments on the road

Aino has its origin in the Indonesian university town Yogyakarta

and specializes in creating acceptance terminals for prepaid
cards in public transportation and toll roads.

These are cards customers can pre-load with a certain amount

and then spend by tapping it onto these card terminals. The
process doesn’t require any internet connection and is done
within seconds, which makes it particularly suited to micro
transactions on the go, such as public transport fares.

The cards are mostly issued by big banks. Mandiri E-Cash and
BCA’s Flazz are the most prominent examples of this in In
Indonesia.

Aino can be seen as a PG because it aggregates and integrates

multiple cards on its reader devices therefore acting as a
“gateway” between issuer and cardholder.

Pg. 12
Example: Cashlez
enabling cashless payments in small shops

Cashlez is similar to Aino in the sense that it is an interface

with shoppers in the real world. But it’s not optimized for micro-
payments from prepaid cards for public transport fares, its card
reader device is built to accept different types of debit cards and
credits cards for payments in restaurants, shops, or hotels.

It caters to businesses that are too small or are otherwise outside

of the reach of the bank’s networks that normally distribute and
manage card reader devices.

Cashlez device is easier to install and mobile, which means it

can also be carried by people who are selling or collecting fees
on the go, for example at warehouses, or for down payments
in real estate.

Pg. 13
Example: Midtrans
one of Indonesia top PG players in ecommerce

Midtrans is one of the major PGs that specialize in ecommerce

transactions. It’s now a part of Indonesian tech company Go-
Jek after it was acquired in 2017, along with another payments
company, Kartuku, making Go-Jek one of the local companies
that can offer a variety of payments schemes based on different
licenses it now combines under one roof.

Midtrans offers merchants a software package that is easy to

integrate into their online store and sets them up them with
multiple collection options, such as through credit cards, bank
transfers, or “over the counter,” which refers to the payment
method described in Chapter 1, where customers can pay in
cash at a partner store. Midtrans has also evolved to allow
merchants to integrate mobile wallets such as Go-Pay into their
range of payments options.

In addition to this standard PG functionality for collecting

payments, Midtrans offers additional services like fraud detection
and a separate software package called Iris that simplifies the
way merchants settle their own outstanding payments, for
example for refund management.

It allows you to disburse payments to any bank accounts in

Indonesia and comes in two business schemes. Partners can
either have a deposit account at Midtrans that can be topped
up from time to time using various channels. Any payout/
disbursement will be done from this deposit account as the
source of fund. This makes makes for faster onboarding process.

The other option lets merchants use their own bank account
as the source of funds for disbursements through a direct link
with the other banks’ APIs. This, however, requires a more
complicated onboarding and account registration process for
the merchant.

Pg. 14
Example: Doku
another top ecommerce PG in Indonesia

Looking back on a long history of cashless payments in

ecommerce, Doku, along with Midtrans, is one of the most
established players in this arena.

Like Midtrans, Doku offers services that help online merchants

collect payments from customers, but has a separate package
for disbursement.

Next to small-and-medium businesses, Doku also has many

large corporate clients. It’s the local partner for Adyen, one of
the big international payment service providers.

Example: Xendit
a PG servicing the P2P industry

Xendit is in many ways a traditional PG ike Midtrans and Doku,

though it launched in Indonesia a little later than those two. It
picked its niche in servicing P2P lending platforms, but works
with ecommerce companies as well. Xendit addresses a variety
of specific payments needs, such as subscriptions and loan
repayments.

Pg. 15
Example: Sepulsa
a PG specializing in bill payments

Sepulsa grew out of a specific niche, which was to help mobile

phone users top up their phone credit. An overwhelming
majority mobile phones in Indonesia are prepaid8. This means
their owners are not on monthly plans, but fill up their phone
credit and purchase data packages whenever they run low.

In the past, you would have to go to one of your carrier’s partner

stores to get your top up and pay in cash. Sepulsa developed
an app where you enter your phone number. Once it has
recognized your carrier, you choose the phone minutes and/or
data plan your need, and pick a payment option. Sepulsa offers
payment by credit card, debit card, and banks transfers - which
makes it akin to a PG.

Sepulsa has since diversified and now also allow bill payments
for electricity, warter, health insurance, and other recurring
costs.

8 http://www.analysysmason.com/Research/Content/Comments/Postpaid-
migration-EMAP-RDRP0/

Pg. 16
How businesses work with
Payment Gateways

Case Study: Zalora

Zalora specializes in fashion ecommerce and operates
across Southeast Asia. It was established in 2012

Zalora only started working with a PG at the end of

last year. Before that, it had relied on a manual process
for accepting and verifying bank transfers and offered
a cash-on-delivery option, where the shopper pays
once the package arrives.

Zalora’s approach has been to take on new payment

methods slowly and cautiously, waiting for them to
find mainstream adoption first before integrating
them. The ecommerce company has mostly a middle-
class urban clientele, and fashion products are not
necessarily bought at high frequency - that puts Zalora
in a position where it does not have to cater to every
possible payment option possible.

Case Study: Investree

Investree is one of the firms active in the budding P2P
lending sector. It offers a variety of lending models
for individuals and small businesses, but the basic
concept is the same for all: A lender pays the amount
to Investree, and Investree forwards the loan to the
borrower who repays in installments with interest rate
on top.

Investree collaborates with PGs in different ways. It

needs a PG to assist with the collection process, so
that it’s made as simple as possible for borrowers to
return their installment when it’s due.

Investree also works with a PG on the lenders side.

Lenders all have different bank accounts, and in this
case the PG aggregates those accounts. This means
Investree does not have to connect with those lenders
directly, but does this via the PG.

Pg. 17
The current state of regulation

Financial technology and payments service providers, besides those that have co-existed alongside the traditional
banking ecosystem for decades, are still fairly new in Indonesia.

A fintech boom has begun to take place ever since mobile internet became mainstream. The boom also has to do
with an influx of venture capital, especially into the ecommerce sector.

Hence, attempts to regulate the space are also still in their infancy. The main regulators involved are Indonesia’s
Central Bank (Bank Indonesia (BI)) and the Financial Services Authority (OJK). BI governs everything that has to do
with payments instruments and the underlying payments infrastructure. OJK regulates financial services like loans.

Here’s a timeline of the important recent regulations that affect the different entities within the payments landscape:

OJK regulates P2P lending

No. 77/pojk.01/2016

BI regulates
“financial technology”
company
National Cashless No.19/12/PBI/2017
Society Movement

2014 2016 2017 2018

BI regulates Payment
Transaction Processors (which BI issues new e-money
includes Payment Gateways) regulation, revoking previous
No. 18/40/PBI/2016 regulation from 2009 and its
amendements
No. 20/6/PBI/2018

Overall, firms in financial technology can expect to operate in an increasingly stricter environment, as regulators
and banks are adopting a cautious approach and are starting to enforce the regulations they laid out. BI recently
had a change in leadership, but its new chief is expected to stay on the course set by his predecessor.

As mentioned in Chapter 2, Indonesia has established a National Payment Gateway (GPN), a multi-tiered plan
that requires banks and non-bank payment institutions to cooperate more closely, for example by sharing ATM
infrastructure, electronic data capture (EDC), and ensuring interconnection and interoperability of payment
channels. In the long term, PGs will be required to link up with the GPN, but it’s an integration that doesn’t
necessarily affect merchants and online shoppers directly. It may shift fee structures, so that inter-bank transfers
within the country become cheaper. The GPN also requires all domestic electronic transactions to be processed
through the GPN in order to ensure that more transactions are processed within Indonesia.

Pg. 18
Payment Gateways models recognized
by Indonesia’s Central Bank
The rules for PG companies are mostly defined in the Indonesian Central Bank regulation on Payments Transaction
Processors from 2016 (No.18/40/PBI/2016).

It introduces PGs with a general definition: “Payment Gateways are an electronic service that enable merchants to
process payments transactions using payments instruments by using cards, electronic money, and/or Proprietary
Channels.” In the footnotes, it describes two distinct models: Aggregator PGs and Facilitator PGs. As briefly
described in Chapter 2, the main difference between these models lies in where the merchant data sits.

In the aggregator model, the PG takes an active role as a mediator of the transaction. It collects the relevant
payments data from its merchants and then sends it to the bank from its own account. The bank only has a
relationship with the aggregator, not all individual merchants the aggregator has signed up.

The facilitator PG is slightly different. It helps set up individual accounts for each merchant with the banks. In this
case, the PG facilitates the payment transaction from the merchant to the bank, but the bank also has a direct
relationship with the merchant.

Under OJK’s P2P regulation, direct connections with the bank are mandatory, which means PG in this space should
operate only with the facilitator model.

This relatively narrow description of PGs makes them similar to an already existing model that dates back to the
pre-ecommerce era: that of a so-called merchant acquirer. These are entities that took up the role of helping
merchants get set up with merchant accounts at banks long before more technically sophisticated PGs came along.

definition for the scope of services PGs can offer, limits

Some challenges their competitiveness. If, for example, PGs also want
to service merchants needs for settling refunds, which
for Payment Gateways requires transferring money back to shoppers instead
of collecting it from them, it would require a different
The Indonesian Central Bank (BI) regulation that covers license.
PGs (see above) was introduced in 2016.
Another challenge is the fact that several regulations
Companies who have operated PGs prior to this have in financial technology and financial services are now
been doing so in a fairly unregulated environment and coming into effect at once, sometimes one overtaking
now find themselves in the position of having to adapt the other in terms how they are enforced. If, for
to achieve compliance. example, the OJK’s regulation on P2P lenders stipulates
lending platforms can only work with licensed PGs,
To this date, mid-2018, BI has only issued seven licenses but the licensing process is still lagging behind, this
specific to the PG model9, which is a subcategory of creates a situation in which companies suddenly find
entities classified as Payments Processors. Several more themselves in a legal grey area.
entities are in the application process.
With the barrier to entry becoming higher for new
What’s been a challenge to some payments companies entrants, BI suggests the best way is start out by
is the response speed to applications. The process registering for a “financial technology company”
to get appointments and document approvals can license, which is more broadly defined and lets startups
take weeks to months, which is a significant setback operate with a higher degree of freedom. After that,
for companies, especially new entrants. For larger BI will guide them and help decide which licenses are
companies that have a history in other payments- necessary, depending on the business model.
related services, for example those that already have a
merchant acquirer license, this process is faster. Overall, industry players support the regulator’s
approach to achieve more oversight in the rapidly
Among the industry, there’s also the fear that the evolving field of cashless payments, but some fear that
current regulation, which creates a fairly tight a high degree of standardisation, and an increasingly
high barrier to entry for young companies with novel
ideas for how to attract and serve customers, especially
those in the MSME segment, might limit innovation
9 https://www.bi.go.id/id/sistem-pembayaran/informasi-perizinan/
ptp/penyelenggara-berizin/Contents/default.aspx
and growth potential.

Pg. 19
Regulation elsewhere

As previously discussed, comparing one country’s

payments landscape to another has its limitations. It
depends on the evolution of the banking and internet
infrastructure, legacy payments habits, and the
regulatory environment of each country.

When it comes to Indonesia, India might offer the best

backdrop for comparison on the evolution of cashless
payments instruments and their regulation. Similar to India, Singapore is trying to shift away from
a “definition-based” approach to payments service
Regulations in this space fall under the responsibility providers to a more “activity-based” one.
of the Reserve Bank of India.
The rapidly evolving payment services landscape have
Currently, India does not spell out a specific definition given rise to new risks, including new digital payment
of PGs within its regulation. They fall under the business models that are more prone to cyber attacks
Payment and Settlement Systems Act, which covers and have significant implications to money laundering
a broad category called Payments System Providers compliance. In response to these challenges, the
without further breakdown. Monetary Authority of Singapore (MAS) has begun
to work out an activity-based payments framework
India’s Payment and Settlement Systems Act requires (”PPF”) in August 2016.
all Payments System Providers to get an authorization
from the Reserve Bank of India, and obliges all In it, MAS suggests to streamline the existing licensing
Payments System Providers to follow security and framework for payment services into a new single and
reporting standards defined in the Act. The Reserve modular one which will regulate both innovative and
Bank of India has the right to revoke the authorization brick-and-mortar service models, according to the risk
if the Payments System Providers fails to comply with level. The PPF introduces seven activities licensable
the rules elaborated in the Act, or if it operates the under MAS, and this will be proposed to find its way
payment system in a different way than the conditions into the Payment Services Bill (PSB), which is still under
under which had received the authorisation. discussion at this moment.

On the other hand, Indonesia’s comparable regulation

on Payments Transaction Processors from 2016 (No.
18/40/PBI/2016) includes a high level of particularity,
differentiating between PGs and Digital Wallets,
Acquiring Services, and Switching Services, among
others. Potential overlap of definitions among these
type of business models have led to potential payment
service providers spending substantial amount of
time understanding which licensing category their
businesses fall into. This has led to some of the
challenges described in Chapter 6.2.

Pg. 20
The future of Payment Gateways

As we have seen, PGs are an accelerator for digital economy growth.

They serve individual merchants as well as tech platforms like ecommerce marketplaces and P2P lenders and are
especially necessary to address the diverse payments needs of MSMEs.

PGs can better serve these niches than banks because they can focus on creating a seamless user experience that’s
easy to use on the merchant’s side as well as for the end customer. PGs can also quickly react to trends and test
new payment channels.

Without PGs who serve MSMEs, the government goal for reaching US$130 billion in ecommerce transaction
volume by 2020 could not be achieved, but the potential contribution is even larger if we factor in the role of PGs
in P2P lending.

60.0 56.4

50.0
41.4
40.0
(US$ million)

28.9
30.0
20.0 19.0

11.6
10.0 6.5
3.3
0.0
2016 2017 2018 2019 2020 2021 2022

Estimated transaction value growth of P2P/marketplace lending in Indonesia

The online lending sector, which is only just getting started in Indonesia has the potential to fund and accelerate
the growth of MSME, who then in turns will have the means to upgrade and digitize their operations, including
the way they collect payments and file taxes.

This can create a virtuous cycle that benefits not just the digital economy, but Indonesia’s economy overall.

In more advanced digital economies, PGs have grown to offer a multitude of additional services including fraud
detection and software to simplify billing and financial reports. Without companies like Stripe, Braintree, and Adyen
accelerating their growth, the massive platforms that define today’s digital landscape, like Facebook, Airbnb, and
Grab would not have been possible.

Pg. 21
Key takeaways

“
1
P
ayment Gateways accelerate
digital economy growth
because they can quickly
adapt to serve new and emerging

2
technology and
“
business models based on the
latest
experience design principles.
user

“
B
anks benefit from
existence of PGs because
the

they help onboard merchants

operating in the ever-changing

3
“
digital landscape into the banking
system. Banks do not have the

“
bandwidth to address these
particular needs.

P
ayment Gateways serve a
unique purpose in Indonesia
where payments channels
are very fragmented, a barrier to
“
entry for small businesses who
would otherwise get left behind.

Pg. 22