THE POLICY ON THE DETERMINATION OF TOP UP FEE OF EMONEY
Abstract
The top-up fee of e-money has been determined by Bank Indonesia which is loaded
in the Board Governor Member Regulation Number 19/8/PADG/2017 on the
National Payment Gateway. The price scheme was set into two kinds depending on
where the transaction channel was made whether the transaction channel was
through the or different from the issuer payment channel. This research aimed to
analyze whether the actions of Bank Indonesia in determining the top-up fee in the
form of the Board Governor Member Regulation Number 19/8/PADG/2017 on the
National Payment Gateway is in line with its duties and authorities. This research
uses the normative legal research type with the statute approach to research the
legislation which regulate the authority of Bank Indonesia regarding the policy on
top-up fee which has been issued by Bank Indonesia and the supervision on the
implementation of that such policy. The research concluded that Bank Indonesia is
authorized to regulate the top-up fee of e-money to ensure the consumer protection
and the smoothness of the payment system. Moreover, the supervision regarding to
the e-money top up fee was in the hand of Bank Indonesia. But in case that the
consumer suffered loss because of the fault of the e-money organizer, the Financial
Service Authority could take lead to facilitate the complaint of the customer.