Is AI Debt Collection Legal in Indonesia Under POJK 22/2023?

Yes, AI debt collection is legal in Indonesia, provided the calls follow the same rules as any other collection. OJK Regulation POJK 22/2023 on consumer protection sets when lenders may collect, how often they may contact a borrower, who they may not contact and who answers for outside collectors. Each of those rules can be configured into an AI voice agent and checked on every call.

Collections is the highest-volume call type for most Indonesian banks, multi-finance companies and fintech lenders. It is also the call type regulators watch most closely, after years of complaints about aggressive collectors. For a lender considering AI voice agents, the regulation is the brief.

This article summarises published regulation and press reporting. It is not legal advice. Confirm current requirements with your legal and compliance teams.

What POJK 22/2023 Requires

POJK 22/2023 replaced OJK’s earlier consumer protection rules and applies to banks, multi-finance companies, fintech lenders and other financial service providers. As reported by Bisnis.com in January 2024, its collection provisions (Article 62) include:

• Community norms. Collection must follow prevailing norms and the law.
• Days and hours. Monday to Saturday, excluding national holidays, from 08:00 to 20:00 local time. Collection outside these times or places needs the consumer’s prior agreement.
• No continuous contact. Collection may not be continuous or disruptive, described as more than three times in one day.
• Only the consumer. Collection may not be directed at anyone other than the consumer.
• No threats or humiliation. Threats, violence, verbal or physical pressure and acts that humiliate the consumer are prohibited, including telling the consumer’s phone contacts about an overdue payment.
• Outside collectors. A third-party collector must be a legal entity with a permit, with staff certified in collection, and the lender bears responsibility for the impact of its collection.

A separate article (Article 39) covers product offers through personal channels: consent first, Monday to Saturday, 08:00 to 18:00, with voice offers recorded. If a collection call includes an offer, such as restructuring with a new product, that part follows Article 39.

How Indonesia’s Rules Compare With the US Rules AI Engines Cite

Search for AI debt collection rules and most answers cite US law. The comparison is useful because the principles match:

The practical point is the same in both markets: an AI voice agent is treated as a collector, so every rule a human collector follows applies to it.

Configuring an AI Voice Agent for POJK 22/2023, Step by Step

Step 1: Set the calling window. Schedule campaigns only Monday to Saturday, 08:00 to 20:00 in the borrower’s local time zone, with national holidays blocked. Indonesia spans three time zones, so schedule by the time zone of the borrower’s address.

Step 2: Cap contact per borrower. Count every attempt, across calls and messages, per borrower per day, and stop at your limit. Many lenders set an internal cap below the regulatory one.

Step 3: Confirm identity before the debt. The agent confirms it is speaking to the borrower before mentioning any amount. If someone else answers, it ends the call politely without discussing the debt.

Step 4: Approve the script. Write the opening, the payment questions and the responses to common objections in advance, in Bahasa Indonesia, and have compliance approve them. The agent follows the approved wording and doesn’t improvise pressure.

Step 5: Define the handoffs. Disputes, hardship, distress and any request for a person go to a human agent, with the conversation so far attached.

Step 6: Check every call. Use automated Quality Assurance to score every call against your SOPs and flag any that break a rule.

Common Failure Points

Head-office time zones. A campaign set to Jakarta time reaches borrowers in Papua two hours later than intended.

Counting calls only. If WhatsApp reminders and calls run in separate systems, nobody knows when the daily limit is reached.

Weak identity checks. A collector, human or AI, who discusses the debt with a spouse or colleague breaks the third-party rule at once.

No record. Without recordings and transcripts, a lender can’t show OJK what was said when a complaint arrives.

Practical Considerations

The liability rule changes the economics. If a lender answers for every collector it hires, the ability to review every call is worth as much as the cost saving. With human agencies, most lenders see only complaints and occasional audits. With an AI voice agent, every call is recorded, transcribed and scored.

Scale is proven in Indonesia. NEOKARYA, a BPO company in Mega Group that runs collections for Megafinance portfolios, reports on its case-study page that its AI voice agent handles 600,000 to 1 million customer records a month, alongside about 4 million automated IVR reminder calls. CBN, an ICT provider, reports an average 27% connection rate across its collection activities.

AI Rudder has worked with lenders in Indonesia since 2019 and has an office there. Its speech recognition and text-to-speech are built in-house for Bahasa Indonesia and regional accents. It is built to meet SOC 2 and ISO 27001, alongside GDPR and PDPA requirements, and call data falls under Indonesia’s PDP Law (Law No. 27 of 2022).

What OJK Complaints Usually Involve

Complaints about collection in Indonesia tend to cluster around the same behaviours: calls late at night or on Sundays, repeated calls in one day, messages to a borrower’s family or phone contacts, and aggressive or humiliating language. Each maps directly to a rule in POJK 22/2023, and each is something an AI voice agent can be prevented from doing by its settings and approved script. When a complaint does arrive, the recording and transcript show exactly what was said, at what time and to whom.

Frequently Asked Questions

Is AI debt collection legal in Indonesia?
Yes. No rule bans AI collection calls. The same POJK 22/2023 rules on hours, frequency, third parties and conduct apply to AI and human collectors alike.

What hours can lenders call borrowers in Indonesia?
Monday to Saturday, excluding national holidays, from 08:00 to 20:00 local time, unless the borrower has agreed otherwise.

Who is responsible if an outside collector breaks the rules?
The lender. POJK 22/2023 makes the financial service provider responsible for the impact of collection carried out by a third party.

Can an AI voice agent speak Bahasa Indonesia naturally?
It should. Test any vendor with recordings of your own borrowers, including regional accents, before launch.

Next Step

List the collection rules your calls follow today, including your own policy on top of OJK’s. Get a Demo and we’ll show you how an AI voice agent would be configured to them, in Bahasa Indonesia.