The Policy on the Determination of Top-Up Fee of E-Money

Abstract

Introduction to The Problem : Bank Indonesia (BI) has determined the top-up fee of e-money in the Board Governor Member Regulation Number 19/8/PADG/2017 on the National Payment Gateway. This regulation is contrary to article 2 paragraphs 2, article 23 paragraph 1, article 33 paragraph 2 Law Number 7 of 2011 concerning Currency expressly regulates that every person is prohibited from refusing to accept rupiah. Aside from that, the regulation has the potential to cause injustice and discrimination for consumers. Purpose/Objective Study : This research aims to analyze whether Bank Indonesia’s actions determine the top-up fee in the form of the Board Governor Member Regulation Number 19/8/PADG/2017 on the National Payment Gateway are in line with its duties and authorities. Design/Methodology/Approach : This research uses the normative legal research type with the statute approach to research the Legislation that regulates Bank Indonesia’s authority regarding the policy on a top-up fee issued by Bank Indonesia supervision on implementing its policy. Findings : The research concluded that there is an inconsistency authority between Bank Indonesia and Financial Service Authority. Bank Indonesia is authorized to regulate the top-up fee of e-money to ensure consumer protection and the payment system’s smoothness. Moreover, the supervision regarding the e-money top-up fee was in the hand of Bank Indonesia. However, when the consumer suffered loss because of the e-money organizer’s fault, the Financial Service Authority could take the lead to facilitate the customer’s complaint. Paper Type : Research Article.