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Non Cash Payment Transaction Processing in Indonesia 184

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(1)

Non-Cash Payment Transactions

Processing in Indonesia

(2)

Through

ATM

&

EDC/Physical Reader

Using Credit Card, ATM

Card, Electronic Money

Chip Based

Through

Internet

Payment

Gateway (Virtual EDC)

Using CBP, Electronic

Money Server

Through Platform E-Payment

Using Proprietary Channel (SMS, USSD,

STK, web, mobile, e- wallet).

Using Electronic Money

Server Based.

(3)

E-money

Elements of e-money:

- Issued based on the value of the money deposited to the issuer

- The value of the money is stored electronically in a media server or chip

- Used as the payment instrument to merchants who are not the issuers of such e-money

- The value of such e-money managed by the issuer shall not be in the form of savings

Payment System Providers are prohibited to process payment transaction with a virtual currency obtained through mining, purchase or rewards, e.g. Bitcoin, Blackcoin, Dash, Dogecoin, Litecoin.

Electronic service to store data of instrument for payment among others CBP (card based payment) and/or electronic money, which can also store money, to conduct payment.

Types of e-money

- Non-registered : value up to IDR 1million - Registered : value up to IDR 10million

Monthly maximum transactions up to IDR20 million License will be required if the

active user has reached at least 300,000 user.

Maximum fund that can be stored in E-wallet IDR 10million.

Payment gateway enables merchants to process payment transaction process with payment tools that utilize cards, electronic money and/or proprietary channel.

Payment gateway provider:

a. Transmits data on payment transaction from merchant to Acquirer or Issuer (facilitator); or

b. Transmits data on payment transaction from merchant to Acquirer or Issuer and payment settlement from Acquirer to Issuer to merchant (merchant aggregator).

E-money is distinct from “stored value “ which stands for a non cash payment instrument, the value of which is stored in one media yet partially or wholly not fulfilling the elements of e-money .

E.g. Starbucks cards which can only be used to enter into transactions at Starbucks.

Credit Card

Debit/ATM

Card

(4)

Bank Indonesia (“BI”) Regulation No.18/40/PBI/2016 regarding Provision of Payment Transaction

Processing

BI Circular Letter No.18/41/DKSP regarding Provision of Payment Transaction Processing

Payment Transaction Processing

BI Regulation No.11/11/PBI/2009 regarding Provision of Card Based Payment (“CBP”) Instrument

and its amendments

BI Circular No. 11/10/DASP regarding Provision of Card Based Payment Instrument and its

amendments

Card Based Payment Instrument

BI Regulation No. 16/8/PBI/2014 regarding E-money and its amendments

E-Money

Law No. 3 of 2011 regarding Fund Transfer

BI Regulation No. 14/23/PBI/2009 regarding Fund Transfer

BI Circular Letter No. 15/23/DASP regarding Provisions of Fund Transfer

Fund

Transfer

BI Regulation No.19/8/PBI/2017 regarding National Payment Gateway

National Payment Gateway

(5)

Payment System Service Provider

Bank or other Non Bank Institutions that provide payment system service processing

Pre-transaction

Authorization

Clearing

Settlement

Post Transaction

Initial transaction

process to start the

payment

transaction process

inter alia printing of

cards,

personalization of

cards and supplying

of infrastructure.

Approval on Payment

Transaction

Exchanging or

assimilating data

and/or information in

terms of calculation

of rights and

obligations between

parties.

Settlement activity

that is final and

binding on financial

rights and obligations

on each implicated

parties.

Activities after the final

settlement of a payment

transaction has been

conducted.

Supporting Provider of Payment Transaction Processing

Parties that support the implementation of transaction payment processing

(6)

Payment System Service Providers

PAYMENT SYSTEM SERVICE PROVIDER

PROCESSING

Bank

Non-Bank Institution

Issuer

Principal

Acquirer

Settlement Provider

Clearing

Fund Transfer Provider

Payment Gateway

E-Wallet

Switching

Printing & Personalization of cards, Safety Features

Providers,

ATM/EDC

Terminal

Providers,

Data

Center/Data Recovery Center Providers, etc.

(7)

Payment System Service Providers

Issuer

Banks or non-bank institutions which issue the CBP instrument

or e-money. The non-bank institutions that can issue a credit

card must be a financing company that obtained license from

the OJK to issue credit card. The non-bank institutions that can

issue a debit card and ATM card must have the authority to

collect public funds.

Principal

Banks or non-bank institutions carrying out the principal CBP

instrument s or e-money, i.e. management of system and/or

network of its members (issuers and/or acquirers).

Clearing Provider

Banks or non-bank institutions carrying out the calculation of

financial rights and obligation of each of the Issuer and/or

Acquirer in CBP instruments or e-money.

Final Settlement Provider

Banks or non-bank institutions carrying out final settlement of

the financial rights and obligations of each of the Issuer and/or

Acquirer in CBP instrument or e-money transactions based on

the calculation of the Clearing Provider.

Acquirer

Banks or non-bank institutions cooperating with merchants

which can process the CBP instruments or e-money data issued

by other parties.

Fund TransferProvider

Banks or non-bank institutions carrying out fund transfer

activities.

Switching Provider

Bank or non-bank institutions providing infrastructures that

function as the center and/or connector of data for payment

transaction processing through network that utilize payment

method such as card, electronic card and/or fund transfer.

Payment Gateway Provider

Bank or non-bank institutions providing electronic service

that enables merchants to process payment transaction

process with payment tools that uses cards, electronic money

and/or proprietary channel.

Electronic Wallet Provider

(8)

Licensing requirements

Every party that acts as Payment System Service

Provider is obligated to obtain a prior license from

(9)

In the payment transaction process, Payment

System Service Providers can cooperate with

Supporting Provider in order to support the

implementation of payment transaction

processing.

Supporting Providers are among others:

Provider of card Printing;

Provider of personalization of payment;

Provider of

data center

and/or

disaster

recovery center

;

Provider of terminal among ATM, EDC,

and/or

reader

;

Provider of safety features of payment

instrument and/or payment process;

Provider of supporting technology for

contactless

support;

Provider of routing and supporting data

for payment transaction process.

Payment System Service Provider may engage

Supporting Providers in all steps of payment

transaction processing.

(10)

Parties that apply for a principal license for switching, clearing, and final settlement

must be in the form of a Limited Liability Company and whose shares are at least 80%

owned by:

1. Indonesian citizens; and/or

2. Indonesian legal entity.

Then the calculation for foreign ownership includes:

1. Direct ownership: counted based on 1 level of share ownership above prospective

Principal, Switching, Clearing and Final Settlement.

2. Indirect ownership: counted based on 2 level share ownership above prospective

for Principal, Switching, Clearing and Final Settlement.

The calculation of foreign ownership for public companies is only conducted for share

ownership with a percentage of 5% or more.

BI conducts supervision over the fulfillment of share ownership percentage.

(11)

Parties

Banks and non banks institution functioning as: - Issuers;

- Acquires;

- Payment gateway providers; - Other parties stipulated by BI

Service Institution:

- Has the duty to ensure the security of payment transactions and the confidentiality of customer data; carry out reconciliation, clearing and settlement, and developing systems for fraud prevention, risk management and risk mitigation; managing life cycle over secure access module (SAM) and mobile apps; handling disputes over payment transactions in the framework of consumer protection

- Its shares must be jointly owned by Switching Institution and Commercial Bank based on Business Activity (BUKU) 4 (four) in which the majority of its shares are owned by Indonesian citizens and/or Indonesia legal entities

Parties connected to the NPG must be members of at least 2 (two) Switching Institutions, except for instruments that can be interoperable without going through a Switching Institution.

Parties connected with NPG shall comply with and implement the Standards established by BI and managed by the Standards Institution and shall also comply with the conditions set by the Services Institution.

Switching institution:

- Has the duty and function to process the payment transaction data domestically for

interconnection and interoperability.

- Must previously obtained a license as switching provider from BI;

- Must have a minimum paid up capital of IDR50billion

Standard Institution:

- Has the functions of preparing, developing, and managing the Standards (the formalized technical and operational specifications) for the interconnection and

interoperability of payment instruments, payment channels, and Switching, as well as security. - Must be an Indonesian legal entity

that obtain a stipulation from BI as the Standard Institution

(12)

NPG

shall be systems which consist of

standards, switchings, and

services which are constructed

through a set of regulations and

mechanisms (arrangements) to

integrate various payment

instruments and channels

nationally.

c. the

interoperability of payment instruments in

the forms of ATM cards and/or debit cards, credit

cards, electronic money, and other payment

instruments NPG covers domestic

payment transactions which comprise:

A. interconnection

of Switching;

b. the

interconnection and interoperability of payment channels in the forms of ATM, electronic data captured (EDC),

agents, payment gateways, and other payment channels; and

(13)

Foreign ownership limitation.

Approval for the development of payment system business activity.

Domestic processing requirements for payment transactions using instruments issued by the issuers in Indonesia and

conducted in the territory of Indonesia.

Mandatory use of Rupiah.

De facto requirement to establish data center in Indonesia; unclear provision in the prevailing laws and regulation and

unclear enforcement.

With the issuance of NPG regulation, it creates uncertainty with regard to the role of a principal, clearing provider and

final settlement provider in the chain of payment transaction process.

Vague implementation of the recently-enacted NPG regulation in the absence of an implementing regulation.

(14)

Phone 62 21 2953 2000, 5212038

Fax 62 21 5212039

Email ssek@ssek.com

Mayapada Tower 14

th

Floor

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