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In brief

On the country’s 76th Independence Day, Bank Indonesia announced its collaboration with the Bank of Thailand, Thailand’s central bank, for a trial of a cross-border QR payment linkage (“Cross Border QR Payment Linkage“) that is targeted to go live in Q1 2022. This is expected to become the first of many more collaborations to come with other central banks, in anticipation of the time cross-border travels would again be possible and to accommodate the rapid rise in e-commerce trading that spans across national borders. With the launch of the Cross Border QR Payment Linkage, consumers and merchants in both countries will be able to make and accept instant cross-border QR payments for goods and services. The announcement of this initiative coincides with the government of Indonesia’s recent ratification of the ASEAN Agreement on Electronic Commerce, which provides a set of policies, principles and rules to govern cross-border e-commerce in the ASEAN. The facilitation and easing of cross-border payments is one of the pillars that will support the implementation of the cross-border electronic trading objectives encompassed in the ASEAN agreement.


  1. Bank Indonesia’s 2025 blueprint
  2. What’s new under the standardization
  3. Open API Payment verification
  4. Publication
  5. Pilot project: Cross Border QR Payment Linkage
  6. Key takeaways

Bank Indonesia has also recently launched the National Standard for Open Application Programming Interface (API) in Payments (SNAP), a set of protocols and instructions that facilitate open interconnection between applications in payment transaction processing. The two initiatives convey Bank Indonesia’s commitments to further accelerate the digitization of the payment system as outlined in Bank Indonesia’s 2025 Blueprint. With this in mind, Bank Indonesia issued the following:

  1. Bank Indonesia Regulation No. 23/11/PBI/2021 on National Payment System Standard (Standar Nasional Sistem Pembayaran) (“National Standard Regulation“)
  2. Regulation of the Board of Governors of Bank Indonesia No. 23/15/PADG/2021 on the Implementation of the National Standard for Open Application Programming Interface in Payments (Implementasi Standar Nasional Open Application Programming Interface Pembayaran) (“SNAP Regulation“)

Bank Indonesia’s 2025 blueprint

As a refresher to our previous client alert, the issuance of the 2025 Payment System blueprint covers five initiatives:

  1. Open banking
  2. Retail payment system
  3. Market infrastructure
  4. Data
  5. Regulatory

Open banking as the first initiative seeks to improve the implementation of Open APIs so that it would be standardized. Fast-forward to 2021, here we are with the launch of the National Standard Regulation and SNAP — a stepping stone in accelerating open banking in payment system services. SNAP is expected to create integration, interconnection and interoperability among API providers to push the efficiency of the payment system.

What’s new under the standardization

Under the National Standard Regulation, Bank Indonesia applies a national standard for the implementation of payment system, which covers governance, risk management, safety standards and interoperability in data processing or payment transaction processing. With a backdrop of operationalizing the principles embodied in the National Standard Regulation, Bank Indonesia has also issued the SNAP Regulation as an implementing regulation, specifically for Open API in payments.

With the issuance of SNAP, two documents will be issued:

  • Technical and security standard, data standards, and SNAP technical specifications (“SNAP Technical Standards“): This covers, among other things, standards on communication protocols, types of API architectures, data structures and formats, authentication, authorization and encryption methods, API access governance requirements, as well as data structures request and data structures response.
  • SNAP governance guidelines (“SNAP Governance Guidelines“): This covers guidelines on consumer protection, data protection, prudential requirements for service providers and service users, and contracts among users and providers of API services.

Open API Payment verification

Under the SNAP Regulation, an Open Payment API Service Provider (“Service Provider“) is a Payment Service Operator (PJP) that provides Open API Payment services based on SNAP. Meanwhile, an Open Payment API Service User (“Service User“) is a PJP or another party other than a PJP who uses Open API Payment services based on SNAP for the benefit of its consumers or themselves. 

The SNAP Regulation requires that verifications for Open API Payments be conducted for Service Providers, Service Users and developers of Open API Payment systems to comply with the SNAP Technical Standards. This is done by registering through SNAP’s Developer Site, after which they must undergo a functionality test, including but not limited to, a security system testing.


The SNAP Regulation stipulates that the SNAP Technical Standards will be published in SNAP’s Developer Site. On the other hand, SNAP Governance Guidelines will be published in SNAP’s Governance Site. However, the first issuance of the SNAP Governance Guidelines will be uploaded through Bank Indonesia’s website, so make sure to keep an eye on this.

Pilot project: Cross Border QR Payment Linkage

With the launch of the Cross Border QR Payment Linkage, consumers and merchants in Indonesia and in Thailand will be able to make and accept instant cross-border QR payments for goods and services. Users from Indonesia can use their mobile payment applications to scan Thai QR Codes to make payments to merchants in Thailand. Likewise, users from Thailand can use their mobile payment applications to scan QRIS (the Indonesia Standard for Quick Response Codes) to pay merchants in Indonesia for goods and services.

The project is a collaboration between the Indonesian Payment System Association (ASPI); the Thai Bankers’ Association; 13 QRIS providers; Indonesian switching operators Rintis, Artajasa, Jalin and Alto (RAJA); and Thai payment system operator National ITMX. The transactions will use direct FX quotations provided by Appointed Cross Currency Dealer (ACCD) banks under the Local Currency Settlement (LCS) Framework. The ACCD banks as of now include the following:

  • Indonesian banks: PT Bank Central Asia Tbk, PT Bank Negara Indonesia (Persero) Tbk and Bank Rakyat Indonesia (Persero) Tbk
  • Thailand banks: Bangkok Bank, Bank of Ayudhya and CIMB Thai Bank

Bank Indonesia cooperating with the Bank of Thailand seeks to ensure smooth interconnection for merchants, customers and operators for a full commercial launch in Q1 2022.

Key takeaways

Service providers in the Indonesian payment system industry would need to take a look into the SNAP Regulation and keep an eye on the developments that will come up as a result of the regulation’s implementation, with the aim of ensuring that the implementation of Open API in payments complies with the standards set by Bank Indonesia and ASPI as the self-regulatory organization in the Indonesian payment system space.

As synergizing innovations in digitalization becomes more imperative, the means to reform the digital landscape for Indonesia are becoming clearer. The National Standard and SNAP will reduce industry fragmentation, whereas the Cross Border QR Payment Linkage will encourage the acceleration of economic and financial digitization in Indonesia. In the midst of uncertainty due to the COVID-19 pandemic, we appreciate Bank Indonesia’s efforts in providing a push for economic recovery. Slowly but surely, Indonesia is taking a step toward a sustainable economic development.

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This client alert was issued by HHP Law Firm (Hadiputranto, Hadinoto & Partners), a member firm of Baker McKenzie International, a global law firm with member law firms around the world. In accordance with the common terminology used in professional service organizations, reference to a “partner” means a person who is a partner or equivalent in such a law firm. Similarly, reference to an “office” means an office of any such law firm. This may qualify as “Attorney Advertising” requiring notice in some jurisdictions. Prior results do not guarantee a similar outcome.” 


Erwandi Hendarta is a senior partner and the Head of Finance & Projects Practice Group in Hadiputranto, Hadinoto & Partners. Erwandi has extensive experience working in the business and financial sectors. Erwandi has had multiple careers, having worked as a central banker at Bank Indonesia (the Central Bank of Indonesia) handling Government’s projects with multilateral agencies (IBRD/the World Bank, OECF, ADB) and as an investment banker doing corporate finance with Schroders Indonesia (an investment banking arm of Schroders Plc., London) before becoming a lawyer with HHP. In addition to his Indonesian legal degree, Erwandi has an LL.M. from Cornell University, USA, and an MBA from Boston University, USA. He was a recipient of prestigious graduate scholarships from the Fulbright, USA and the World Bank. Erwandi has been a regular contributor to Doing Business publications by the World Bank and the IFC.


Mahardikha K. Sardjana is a partner in the Finance & Projects Practice Group of Hadiputranto, Hadinoto & Partners. He has been specializing in banking and finance matters for more than nine years. Mr. Sardjana has been leading the group's M&A projects on financial institutions for the past eight years. He has been involved in several projects relating to derivatives, commission sharing, securitization, loan syndications, mergers and acquisitions of banks and general banking and finance transactions. Mr. Sardjana has also assisted due diligence projects for acquisitions, mergers, rights issues, companies going private, bond transactions, and in the drafting of the legal due diligence reports for the transactions.


Eddie Dewanda is an Associate Partner in Baker McKenzie Jakarta office.


Johan Kurnia is an Associate in Baker McKenzie Jakarta office.


Nadya Andyrasari Mulya is an associate in HHP Law Firm (Hadiputranto, Hadinoto & Partners), a member firm of Baker McKenzie International.

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