Analisis Kebijakan Publik atas Pinjaman Daring Ilegal dan Buy Now Pay Later

Abstract

The growth of digital financial services in Indonesia has expanded financial inclusion while simultaneously generating new consumer protection risks, particularly in illegal online lending and buy now pay later (BNPL) products. This article analyzes digital financial consumer protection in Indonesia from a public policy perspective using a descriptive qualitative method and documentary policy analysis. The study examines official regulations, OJK releases, SNLIK 2025 data, Satgas PASTI reports, Indonesia Anti-Scam Centre (IASC) data, and scholarly literature on digital finance, consumer vulnerability, market conduct, and policy implementation. The findings show that digital financial consumer protection is challenged by four interrelated issues: the rapid growth of digital credit, uneven financial literacy, persistent illegal lending entities, and fragmented redress mechanisms. OJK data show that as of October 2025 outstanding online lending reached Rp92.92 trillion with TWP90 of 2.76%, while banking BNPL reached Rp25.72 trillion with 30.99 million accounts. From 1 January to 17 November 2025, OJK received 48,355 consumer complaints through APPK, with fintech generating the largest number of complaints. By 30 November 2025, OJK received 23,147 complaints related to illegal entities, including 18,633 complaints concerning illegal online lending and stopped 2,263 illegal online lending entities. The article argues that consumer protection must move beyond financial literacy campaigns toward integrated, risk-based policy governance involving market conduct supervision, responsible digital lending, platform accountability, real-time legality verification, integrated complaint handling, and rapid fund-freezing and restitution mechanisms.

Keywords : Consumer protection; digital finance; illegal online lending; buy now pay later; public policy analysis; market conduct; OJK;