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Card and bank billing

Indonesia — OJK consumer protection regulation and LAPS SJK

NationalIDDerived or secondary source

Indonesia

Rule id
billing.id-ojk
Version
1.0.0
In force from
December 18, 2023
Last read against its sources
August 5, 2026
Countries bound
Indonesia

In plain language

What this regime says.

Indonesia gives a consumer a hard internal deadline: the financial services business must resolve a complaint within twenty working days, extendable once. After that the dispute goes to the consolidated ADR body LAPS SJK or to OJK.

Who is covered

Consumers of financial services businesses supervised by OJK.

What you get

A time-bound internal investigation, then mediation or adjudication at LAPS SJK.

Where claims go wrong

  • Not dating the complaint, which is what starts the twenty-working-day clock.
  • Going to OJK before the internal period has run. It will be sent back.

Authority

Every citation,
with its pinpoint.

A claim that cites “EU law” gets filed. A claim that cites Article 7(1)(c) gets answered. These are the exact coordinates this entry rests on.
  1. POJK No. 22 Tahun 2023 tentang Pelindungan Konsumen dan Masyarakat di Sektor Jasa KeuanganPeraturan Otoritas Jasa Keuangan (OJK Regulation) No. 22 of 2023 on Consumer and Public Protection in the Financial Services Sectorconsumer complaint handling by financial services businesses, and the internal complaint-resolution period
  2. Undang-Undang No. 4 Tahun 2023 (P2SK)Law No. 4 of 2023 on the Development and Strengthening of the Financial Sector, Republic of Indonesia

Sources

Where a figure is indexed, converted or published by a regulator rather than fixed in the instrument, the provenance is recorded separately. Anything marked as a modelled estimate is exactly that — a model, not a statutory number.

What it imposes

Clocks, defences and the ladder.

A rule module builds these while it evaluates, because a limitation period depends on which forum is open to you. What follows is the structure this regime produces — deliberately with no dates and no figures, because those belong to your facts rather than to the law.

The clocks it starts

  • The financial services business must resolve your complaint within 20 working daysOJK's consumer-protection regulation requires a financial services business to receive, examine and resolve a consumer complaint within twenty working days of receipt, extendable by a further twenty working days where the regulation's conditions for an extension are met and the consumer is notified. When that period expires without a resolution, the dispute may be taken to LAPS SJK or to OJK. The clock runs from the date the institution receives your complaint, so send it by a method that dates it and keep the proof. (Period: 20 business days. We need the start date to work out your exact deadline.)POJK No. 22/2023, complaint-handling provisionsResponse due
  • Card scheme dispute window (commonly 120 days)The scheme window is short and it is the one that closes first. It runs from the transaction or, for undelivered goods and interrupted services, from the date delivery or performance was due. The domestic routes below run much longer, so a closed scheme window is a reason to hurry, not a reason to stop.Filing window

What it entitles you to, beyond money

  • A reasoned written decision from the institutionA decision naming the clause or rule relied on is the thing that unlocks everything above it, and it is an obligation rather than a favour in every regime in this file.consumer complaint handling by financial services businesses, and the internal complaint-resolution period
  • Reversal or refund of the disputed amount where the claim succeedsWhat that is worth depends on the route: a scheme dispute reverses the transaction, a conduct regulator can require the institution to put you back in the position you would have been in, and a court or ombudsman can go further and cover consequential loss.
  • Blocking further payments to the same merchantAsk for this in the same letter. Recovering what has gone does not stop what is coming, and a recurring authority survives a successful dispute unless you cancel it separately.

What the other side will say

Each of these is a refusal this regime lets a counterparty attempt, paired with the answer to it. Reading them before you write is worth more than any amount of polish on the letter itself.

"The merchant is abroad, so there is nothing we can do"

high likelihood

The institution treats a cross-border transaction as outside its reach and refers you to the merchant's own country.

What answers it

Your counterparty is the institution that debited your account, and it is regulated where you are. The card schemes operate cross-border disputes as a matter of routine — that is most of what the scheme rules are for. Ask the institution to state, in writing, which rule it says prevents it from raising a cross-border dispute.

"The transaction was authenticated with your OTP/PIN, so you authorised it"

high likelihood

The institution treats a one-time password or a PIN entry as conclusive proof that the cardholder consented.

What answers it

Authentication proves that a credential was used, not that you consented to that particular payment. Ask for the authentication log, the device and channel used, and the merchant identifier. Where the credential was obtained by deception, or where the institution ignored its own fraud-monitoring signals, the analysis changes — and in several regimes here the burden of proving authorisation sits on the institution, not on you.

POJK No. 22 Tahun 2023 tentang Pelindungan Konsumen dan Masyarakat di Sektor Jasa Keuangan — consumer complaint handling by financial services businesses, and the internal complaint-resolution period

Silence, indefinitely

high likelihood

The complaint is acknowledged and then simply never answered, which in practice defeats more claims in this region than any substantive argument.

What answers it

Treat silence as a refusal and escalate on that basis. Write once more, state the date of your complaint and the reference, say that you are treating the absence of a decision as a refusal, and copy the regulator or redress body named in this result. A file that has gone to the regulator gets answered.

Where to take it next

  1. Written complaint to the institution that debited youAddress it to the complaints or consumer-protection unit, not to a branch. Ask for a reference number and a written decision with reasons, and say what outcome you want in one sentence.Claim directtypically 28 days
  2. Scheme chargeback, in parallelAsk the issuer to raise a dispute under the card scheme reason code that fits the facts. It is faster than any regulatory route, it costs nothing to run alongside, and a refusal decides nothing about your legal rights.Claim directtypically 45 days
  3. LAPS Sektor Jasa Keuangan (the integrated financial-sector ADR body)Binding on themIndonesia consolidated its six sectoral financial ADR bodies into a single institution, LAPS SJK. It offers mediation, adjudication and arbitration for disputes the internal process did not resolve, and financial services businesses are required to be members. Mediation is the normal starting point and is designed to be low-cost to the consumer.Ombudsmantypically 90 daysofficial page
  4. Otoritas Jasa Keuangan (OJK) — Kontak OJK 157OJK supervises banks, card issuers and fintech lenders and takes consumer complaints directly through Kontak OJK 157 and its online portal. It expects the internal route to have been used first, so attach the complaint and the date. This body will look at your individual case, so file it as a case: dates, amount, reference numbers, and one sentence saying what you want done.Regulatortypically 60 daysofficial page
  5. Civil or small-claims proceedings against the merchant or the institutionThe last rung, and in several countries here the cheapest one — consumer courts and small-claims procedures in this region are frequently free or nearly so and do not need a lawyer. Use it when the sum is worth it and the regulator route has produced nothing.Small claimstypically 180 days

Documents

What this regime can produce.

Every one of these is a document you send yourself, in your own name. Duesday never writes to anybody on your behalf and is never anyone’s agent.

The same claim type elsewhere

Card scheme chargeback rules (Visa, Mastercard, American Express, Discover)SCHEMESupranational — party states varyVisa Core Rules and Visa Product and Service RulesConfidence: mediumPSD2 — unauthorised transactions and direct-debit refunds (Directive (EU) 2015/2366)EUSupranational — 30 countriesDirective (EU) 2015/2366 (PSD2)Confidence: highNorway — Financial Contracts Act 2020 and FinansklagenemndaNONational — NorwayLov om finansavtaler (finansavtaleloven), LOV-2020-12-18-146Confidence: mediumRussia — Federal Law 161-FZ on the National Payment System and the financial ombudsmanRUNational — RussiaФедеральный закон от 27.06.2011 № 161-ФЗ «О национальной платежной системе», ст. 9Confidence: mediumSwitzerland — Financial Services Act ombudsman affiliation and the Swiss Banking OmbudsmanCHNational — SwitzerlandFinancial Services Act (FinSA / FIDLEG), SR 950.1Confidence: mediumTürkiye — Bank Cards and Credit Cards Law No. 5464 and the Consumer Arbitration CommitteesTRNational — TürkiyeBanka Kartları ve Kredi Kartları Kanunu No. 5464Confidence: mediumConsumer Credit Act 1974 s.75 (and s.75A) — creditor joint and several liabilityGBNational — United KingdomConsumer Credit Act 1974, s.75Confidence: highCanada — payment card codes of conduct, provincial consumer protection and OBSICANational — CanadaCode of Conduct for the Payment Card Industry in CanadaConfidence: medium

Other rights in the same countries

Indonesia — Consumer Protection Law and the electronic trading regulationsIDNational — IndonesiaUndang-Undang No. 8 Tahun 1999 tentang Perlindungan KonsumenConfidence: lowIndonesia — KAI passenger service standards under the Ministry of Transport minimum service standardsIDNational — IndonesiaMinister of Transportation Regulation on minimum service standards for railway passenger transport, and Law No. 23 of 2007 on RailwaysConfidence: lowIndonesia — Personal Data Protection Law 27/2022IDNational — IndonesiaUndang-Undang No. 27 Tahun 2022 tentang Pelindungan Data PribadiConfidence: mediumIndonesia — PM 77/2011 carrier liability and PM 89/2015 delay managementIDNational — IndonesiaPeraturan Menteri Perhubungan Nomor PM 77 Tahun 2011, Pasal 9Confidence: mediumIndonesia — rental deposit (Kitab Undang-Undang Hukum Perdata (Civil Code), sewa-menyewa, and Undang-Undang No. 1 Tahun 2011 on housing and settlement areas)IDNational — IndonesiaKitab Undang-Undang Hukum Perdata (Civil Code), sewa-menyewa, and Undang-Undang No. 1 Tahun 2011 on housing and settlement areasConfidence: low

Does this one reach your facts?

The engine runs every regime that could apply at once and reconciles them, rather than making you guess which page to read.

Run your factsBack to the catalogue

Not a law firm. Not legal advice. You send it yourself. This page describes a law; it is not advice about your situation and no outcome is promised.