The Indonesian legal system is a civil law system based on the Roman-Dutch model and influenced by customary law.
DFS Model Type2
The DFS model is non-bank-based in which banks, MNOs, and third party providers can issue, acquire, clear and settle e-money. However, if an e-money issuer wants to use agents to offer cash-out services, the agent must be licensed as a money remitter by Bank Indonesia. Bank Indonesia (BI) first launched e-money regulations with Regulation No. 11/12/PBI/2009. In 2014, BI amended the 2009 regulations with Regulation No. 16/8/PBI/2014, in which only Book IV banks are allowed to partner with unregistered entities.
Interoperability is not mandated. However, in 2013 Indonesia’s three major mobile operators Telkomsel, Indosat, and XL enabled their DFS customers to send and receive money across each other’s networks.
Isolation of Funds Arrangement4
If the issuer is an institution other than a bank, managed float funds must be placed with a commercial bank in the form of a deposit account consisting of savings account, current account, and/or time deposit account.
 CIA (2017) Pakistan, available at https://goo.gl/3f97M2
 Jakarta Post (2014) New Rule Means More Players in E-Money, available at https://goo.gl/7Iag5V
 GSMA (2013) Implementing Mobile Money Interoperability in Indonesia, available at https://goo.gl/l1HqAd
 CGAP (2010) Nonbank E-Money Issuers, available at https://goo.gl/dccZVP