If you ask a fintech lender in Southeast Asia why they don't extend more credit to thin-file borrowers, the answer you get most often is "we don't have the data." What that answer usually means, on closer examination, is "we don't have bureau data." The data that exists for thin-file borrowers in Vietnam, Indonesia, the Philippines, and Japan is substantial. The problem is access, ownership, and the infrastructure for converting raw records into usable credit signals.
This piece is a structured overview of what credit-relevant data infrastructure actually exists in each of these four markets: who operates it, what it covers, what lenders can legally access, and where the structural gaps are. We've built against this infrastructure directly, so the gaps we identify are operational rather than theoretical.
Vietnam: Bureau Coverage and Its Edges
Vietnam's primary credit bureau infrastructure is operated by the National Credit Information Center (CIC), which is under the State Bank of Vietnam. CIC covers formal loan holders at licensed credit institutions: banks, finance companies, and regulated microfinance institutions. Coverage has improved significantly over the past decade. Adults who have had any formal loan product at a licensed institution are likely represented in CIC records.
The coverage gap is substantial, however. Adults who have borrowed only through informal channels, such as rotating savings and credit associations (ho/hui), informal moneylenders, or unregistered microfinance providers, have no CIC record. Urban gig economy workers who receive income via MoMo or ZaloPay and manage their finances primarily through mobile wallets may have no formal credit event to report. Rural households with agricultural income and no formal loan history are entirely outside the system.
What exists outside the bureau for these populations: MoMo had approximately 31 million registered users as of 2024, with transaction histories that can extend back several years for early adopters. ZaloPay and ViettelPay add significant coverage in different demographic segments. EVN (electricity) billing records are broadly accessible through consent-based digital channels. The data exists. The infrastructure for lenders to access it in a standardized, consent-governed way is still developing but is functional in specific partnership arrangements.
The State Bank of Vietnam has been increasing regulatory scrutiny of consumer lending, which creates a compliance context that any alternative data approach needs to navigate carefully. Lenders using alternative data for scoring decisions in Vietnam should ensure their disclosure obligations align with SBV consumer lending guidance. Panthera's output includes reason codes explicitly for this purpose.
Indonesia: OJK Ecosystem and Data Fragmentation
Indonesia has a more fragmented credit infrastructure than Vietnam. The Financial Information Services System (SLIK) operated by OJK (Otoritas Jasa Keuangan) covers formal credit events at OJK-regulated institutions. SLIK is accessible to licensed lenders and has broader coverage than Vietnam's CIC in urban areas, partly because Indonesia's formal lending market is larger and more developed relative to GDP.
The gap in Indonesia is the gig economy and rural segment. Indonesia's gig economy, centered on Gojek and Tokopedia/Goto ecosystem platform workers, represents tens of millions of working adults with consistent income but minimal formal credit history. Platform income is real, documented within the platform, and accessible via partner API in consent-governed flows. But it doesn't appear in SLIK.
Mobile payment infrastructure in Indonesia is more competitive than Vietnam: GoPay, OVO, Dana, ShopeePay, and LinkAja all have meaningful user bases with varying demographic concentrations. This fragmentation means a lender trying to assess a thin-file borrower may need to pull data from multiple sources to get adequate coverage. A borrower who uses OVO primarily for food delivery payments and GoPay for merchant payments has a split transaction history that no single platform fully represents.
PLN (national electricity) billing records are accessible and cover most urban and semi-urban households. PDAM (regional water utility) records are more fragmented due to PDAM's decentralized structure: coverage and digital access quality varies significantly by region. A data-access approach that works in Jakarta may not transfer to Makassar without additional integration work.
OJK has been active in regulating fintech lending since 2016 and has increasingly focused on alternative data use, consumer consent requirements, and responsible lending obligations. OJK's digital lending regulations require that lending decisions be explainable and that borrowers receive clear disclosure of the basis for credit decisions. This aligns the regulatory expectation in Indonesia with reason-code outputs.
Philippines: BSP Coverage and the OFW Structural Gap
The Philippines has the Credit Information Corporation (CIC) as the central credit bureau, established under the Credit Information System Act of 2008. CIC coverage has grown since 2016 when the full system launched, but remains below Vietnam and Indonesia in effective depth. A significant share of the adult population that has had formal financial products still lacks a CIC record due to lender under-reporting and the cooperative lending sector's partial integration with CIC.
The OFW (Overseas Filipino Worker) structure creates a structural gap that's unique to the Philippines. Approximately 10% of the Philippine population works overseas at any given time, and their households receive remittances through formal channels. GCash, which integrates with remittance services, has very broad penetration and is a primary payment platform for OFW families. But OFW households, despite receiving consistent, documented income over years, often have no formal credit product in their name and therefore no CIC record.
The Bangko Sentral ng Pilipinas (BSP) has published guidance on responsible lending and financial inclusion that acknowledges alternative data's potential role. BSP's framework for digital lending includes consumer protection provisions that require transparent credit decision-making. GCash transaction history and Bayad Center payment records (bills payment hub for electric, water, and telco bills) are accessible in consent flows and are the primary alternative data sources for Philippine thin-file borrowers.
The cooperative lending sector in the Philippines is large relative to other Southeast Asian markets. Agricultural cooperatives, credit cooperatives, and rural bank cooperative structures collectively serve a significant rural population. Cooperative lending records are not systematically reported to CIC. A rural borrower with years of consistent cooperative loan repayment history has no formal credit record reflecting that history. This is a specific data gap with no near-term infrastructure solution.
Japan: Strong Infrastructure, Specific Exclusions
Japan's credit bureau landscape is the most developed in the four markets we cover. Three bureau systems operate in complementary coverage: JICC (Japan Credit Information Reference Center) covers consumer finance; CIC covers installment credit and credit cards; and the National Banking Association's (ZGK) system covers bank loans and overdrafts. Together, these systems provide broad coverage of formal credit behavior for the majority of Japan's adult population who have had any formal credit product.
The coverage gaps are structural rather than systemic. The first gap is the sole proprietor and freelancer segment. Kojin jigyo-nushi (sole proprietors) often have minimal formal consumer credit history and access bureau records only through consumer products they hold personally. Business income verification uses kakutei shinkoku (tax return) data, but the process is not integrated with the bureau systems in real time, and the 12-18 month lag in tax filing versus current income creates a persistent verification gap.
The second gap is the foreign resident population. Japan's foreign resident population exceeded 3 million by 2024. Many foreign residents avoid formal consumer credit for reasons of visa uncertainty, preference for cash-based financial management, or simply lack of access to credit products that don't require a Japanese guarantor. Bureau records for this population are frequently absent despite stable income and consistent bill-payment behavior.
PayPay (SoftBank / Yahoo Japan) achieved broad merchant payment penetration across Japan and is the primary accessible alternative data source for thin-file borrowers outside the bureau-covered population. Line Pay, Rakuten Pay, and IC card (Suica, Pasmo) transaction data add complementary coverage. NHK, NTT, and electric/gas utility payment records are accessible through digital billing platforms and provide reliable regularity signals. Japan's My Number system provides a digital identity infrastructure that can support consent-governed data access flows, though the consumer-facing implementation is still developing.
Cross-Market Structural Observations
Several patterns emerge from this review that apply across all four markets.
First, the bureau coverage gaps are not random. They map consistently onto identifiable population segments: gig workers, rural households, cooperative sector borrowers, foreign residents, and self-employed. Lenders who want to serve these segments need data infrastructure specifically designed for them, not adaptations of bureau-dependent models.
Second, mobile payment platforms have become the most practically accessible source of alternative data in all four markets. The regulatory frameworks in each market include some form of consent-based data sharing provision. The infrastructure for executing that consent flow and extracting structured credit features from raw transaction data is the bottleneck, not the data itself.
Third, regulatory requirements around explainability are converging across all four markets, though at different rates and with different specific requirements. OJK in Indonesia and BSP in the Philippines have been most active in publishing guidance. Japan's FSA framework is more established but has been adapting to digital lending contexts. Vietnam's SBV is developing its framework. This convergence means that investing in explainable scoring infrastructure is not just a product quality decision; it's a regulatory positioning decision for lenders planning to operate across multiple Asian markets.
The "patchwork" in our title is not a criticism of these markets' regulatory bodies or infrastructure operators. It's a description of the state of development of data infrastructure in markets that have grown their digital economies very rapidly and are building out the supporting infrastructure in parallel. The gaps are real and significant, but they are also addressable with purpose-built alternative data approaches. That's the work we're focused on.
