Introduction

In recent years, the use of electronic money (“E-Money”) has become increasingly integrated into daily Indonesian life. In fact, many merchants now only accept payments which are made using E-Money, including toll-road gates, private parking services, etc. According to KataData figures, in 2017, E-Money transactions increased by 60% over the 2016 figure, topping a total of IDR 8.77 trillion.[1]

In light of this rapid growth in E-Money transactions, Bank Indonesia (“BI”) recently established a new set of rules for players operating within this sector through the issuance of Regulation of BI No. 20/6/PBI/2018 on Electronic Money (“Regulation 20/2018”). This regulation repeals and replaces the first-ever BI regulation to address E-Money, which was issued in 2009, specifically Regulation of BI No. 11/12/PBI/2009 on Electronic Money, as amended several times, most recently through the issuance of Regulation of BI No. 18/17/PBI/2016 (“Regulation 11/2009”).[2]