Payment Institution Licensing in Southeast Asia 2026: Thailand, Indonesia, Philippines Compared

Southeast Asia's three largest payment markets are moving in different directions at the same time. Thailand maintains some of the region's steepest capital requirements. Indonesia is replacing its activity-based licensing model with a bundled framework that takes effect March 31, 2026. The Philippines reopened the door to new e-money issuers after a two-year freeze. For firms planning a multi-market payment strategy, the differences in cost, ownership rules, and regulatory philosophy are larger than they appear on paper.

Thailand: expensive entry, tight foreign ownership rules

The Bank of Thailand regulates payment services under the Payment Systems Act and a series of ministerial notifications. Capital requirements vary by activity type and sit at the top of the regional range. E-money issuance requires THB 100 million (approximately USD 2.98 million). Payment facilitating services require THB 50 million (approximately USD 1.49 million). Electronic money transfer services require THB 25 million (approximately USD 745,000).

These are not nominal thresholds that regulators wink at. The Bank of Thailand expects applicants to demonstrate the full capital commitment before license approval, with ongoing maintenance requirements.

Foreign ownership adds another constraint. Any entity with more than 49% foreign ownership must obtain a Foreign Business License under the Foreign Business Act, a process that involves the Ministry of Commerce and can take six months or more. At least one director must be a Thai national. The practical effect: most foreign payment firms enter Thailand through joint ventures with local partners, which dilutes control and complicates governance.

A significant development in mid-2025 was the Bank of Thailand's approval of three virtual bank licenses, signaling openness to digital-first financial services. But virtual banking and payment licensing remain separate tracks, and the high capital thresholds for payment activities have not changed.

Indonesia: the PBI 10/2025 overhaul

Indonesia's payment licensing regime is undergoing its most significant structural change in years. Bank Indonesia issued PBI 10/2025, effective March 31, 2026, replacing the existing activity-based licensing model with three predefined license bundles. This is not a tweak. It is a reclassification of how payment service providers (Penyelenggara Jasa Pembayaran, or PJP) are categorized and supervised.

Under the outgoing regime, PJP licenses fell into three categories based on activities performed. Category 1 (full-service providers including e-money issuance, fund transfers, and acquiring) required IDR 15 billion in capital (approximately USD 937,000). Category 2 (more limited scope) required IDR 5 billion (approximately USD 312,000). Category 3 (basic services) required IDR 500 million to IDR 1 billion (approximately USD 31,000 to USD 62,000).

PBI 10/2025 replaces these categories with three predefined bundles. The specifics of which activities fall into which bundle are still being digested by the industry, but the key change is philosophical: instead of firms picking individual activities a la carte and Bank Indonesia assigning a category, firms will choose from fixed packages of permitted activities. The intent is to simplify supervision and reduce regulatory arbitrage where firms structured their applications to qualify for lower capital tiers while effectively operating as full-service providers.

New capital adequacy requirements

Beyond the bundle restructuring, PBI 10/2025 introduces a capital adequacy ratio: 10% of risk-weighted transactions, plus a surcharge of 1.5% to 2.5% depending on systemic importance. This is a meaningful shift from flat capital minimums to risk-based capital requirements, bringing payment institution supervision closer to how banks are regulated.

Existing licensees have three years to comply with the new framework. For firms already operating in Indonesia, the transition period is generous. For new applicants, the question is whether to apply now under the old rules (which remain in effect until March 31, 2026) or wait for the new bundles. Applying now and converting later avoids the uncertainty of being a first-mover under untested rules, but it means navigating a transition that may involve capital adjustments and operational restructuring.

Foreign ownership is capped at 49% of voting shares, though at least 15% of total shares must be held by Indonesian citizens or entities. These ownership restrictions are strictly enforced and apply at the beneficial ownership level, not just the registered shareholder level.

Philippines: moratorium lifted, market reopened

The Bangko Sentral ng Pilipinas (BSP) lifted its moratorium on new Electronic Money Issuer (EMI) applications in December 2024, after a roughly two-year freeze that halted new entrants while the regulator assessed the crowded market. As of September 2024, the Philippines had 42 EMI-NBFIs (non-bank financial institutions) and 27 EMI-Banks, making it one of the most competitive e-money markets in the region.

Capital requirements are tiered by scale. Large-scale EMIs must maintain PhP 200 million (approximately USD 3.5 million). Small-scale EMIs require PhP 100 million (approximately USD 1.75 million). All EMIs must be incorporated as stock corporations under Philippine law.

A strict operational deadline applies: licensed EMIs must commence operations within six months of BSP approval. This rule prevents firms from sitting on licenses without serving customers, a practice that plagued earlier licensing rounds.

The moratorium lift creates a window for new entrants, but the market is already dense. With 69 licensed EMIs (banks and non-banks combined), new applicants need a clear differentiation story. The BSP is unlikely to approve applications that simply replicate existing services without demonstrating unique value, whether in underserved geographic markets, specialized use cases, or superior technology.

How the three markets compare

On capital requirements, the Philippines is the most expensive for large-scale e-money issuance at approximately USD 3.5 million, followed closely by Thailand at USD 2.98 million for the equivalent license. Indonesia's outgoing Category 1 at USD 937,000 is dramatically cheaper, though the new PBI 10/2025 risk-based capital requirements may push effective capital needs higher for large-volume operators.

On foreign ownership, Thailand and Indonesia both cap foreign voting control at 49%, while the Philippines requires domestic incorporation as a stock corporation but does not impose an explicit foreign ownership ceiling for EMI-NBFIs (though BSP retains discretion to assess the suitability of foreign shareholders). Thailand's additional requirement for a Foreign Business License above 49% adds cost and delay. Indonesia's requirement that at least 15% of shares be held by Indonesian nationals is an extra structural constraint.

On regulatory trajectory, Indonesia is the most dynamic of the three. PBI 10/2025 represents a fundamental rethinking of how payment providers are licensed and supervised. Thailand is stable but expensive, with no major structural reforms on the horizon beyond the virtual banking initiative. The Philippines is in a reopening phase, absorbing new applications after the moratorium while managing an already crowded market.

Practical considerations for multi-market entry

Firms planning to operate across all three markets should budget USD 5 million to USD 8 million in combined capital requirements alone, before accounting for legal fees, local staffing, office space, and compliance infrastructure. The foreign ownership restrictions in Thailand and Indonesia essentially mandate local partners, which adds negotiation time and governance complexity.

Indonesia's PBI 10/2025 transition is the immediate action item. The regulation takes effect March 31, 2026, and existing operators have three years to comply. New applicants filing after that date will apply directly under the bundled framework. Firms that want to understand the old system before it disappears should file now. Firms that prefer regulatory certainty should wait until Bank Indonesia publishes implementation guidance for the new bundles.

Thailand rewards patience and capital. The high thresholds filter out underfunded competitors, which means firms that do obtain licenses face less competition than in the Philippines, where 69 EMIs compete for a population of 115 million. The Philippines rewards speed: the moratorium is lifted, the BSP is processing applications, and the six-month operational deadline means early movers can establish market position before the next wave of approvals.

No single market is obviously "best." Indonesia offers the largest addressable population (280 million) at the lowest entry cost but the most regulatory uncertainty. Thailand offers stability at a premium. The Philippines offers an open door into a market where most of the seats are already taken. The right sequence depends entirely on where your customers are.