Regulating Fintech in Indonesia, Hongkong and Singapore: Comparison and

Challenges

Adi Wibowo1, Agus Susanto1 and Dewa Bagus1

BINUS Graduate Program
Bina Nusantara University
Kemanggisan, Kebon Jeruk, Jakarta, Indonesia
{ adi; agus.susanto001; dewa }@binus.ac.id

ABSTRACT. The growth of Fintech make it effect to various aspects of industries such as
banking and capital markets, asset and wealth management, insurance, funds transfer and
payments. In year 2018 in Asia, Fintech investments hit $22.7 B acros 372 deals,
specifically in Indonesia, Fintech investment hit IDR 1.4 Tn. Otoritas Jasa Keuangan (OJK)
is Indonesian Regulator for Fintech, stands to keep good balance between Innovation and
integrity of Financial markets and customer protections by issuing some Regulations. One
of regulations that is issued by OJK is Sandbox Regulatory which applied to test the
reliability of Fintech firm business model and technology in few months up to 1 year
duration. Some initiatives have been applied by other countries such as Hongkong and
Singapore to improve time efficiency of testing activity or to support fintech development.
As OJK open opportunity to collaborate with International Stakeholder, Hongkong and
Singapore are good choices to collaborate with.
Keywords: Fintech, Fintech Development, Fintech Regulation, Indonesia, OJK

1. Introduction.
The increasing availability and pervasiveness of mobile devices and Internet of Things (IoT)-
enabled devices are opening revolutionary opportunities toward next-generation services,
systems, and applications in various areas, including environmental monitoring,
transportation, entertainment, security, healthcare and financial. [1], Combinations
between financial and technology that enable innovation and could result in new Business
models, applications, process or products with an associated material effect on financial
markets and institutions and the provision of financial services is called Financial Technology.
[2]. The growth of Fintech make it effect to various aspects of industries such as banking and
capital markets, asset and wealth management, insurance, funds transfer and payments. In
aspect of Payments, innovation of fintech enable new services such as Mobile Payments,
Integrated Billing, Mobile Money, P2P Money Transfer and Cryptocurrency. [3].

World of Fintech investment is increasing year by year and it keeps to receive investment
since Year 2004 until now Q2 of 2019. [4]

According to KPMG by it’s report, in 2018 the volume of investment on Global Fintech
venture companies rockets to a record $111.8 B including 2196 deals [5]. At the same year
in Asia, Fintech investments hit $22.7 B acros 372 deals, specifically in Indonesia, Fintech
investment hit IDR 1.4 Tn. Fintech Lending helps to increase financial inclusion for
Indonesia by potentially providing additional credit access to those that were previously not
catered or underserved by formal financial institutions. The numbers tell the story: in 2018,
additional credit access for MSMEs is estimated to be IDR 4.3 trillion, while in 2019 the
additional credit access will be IDR 7.5 trillion and IDR 19.4 trillion in 2020. [6]

Data per 30 September 2019, Total 127 Fintech registered and licensed according to OJK,
containing 530.385 Lender account, 12.832.271 Borrower account with total IDR 9.69 Tn
[7]

As the FinTech revolution gains momentum, a key challenge threatens to bring this progress
to a crashing halt: cybersecurity. Given the scope, complexity, and dynamism of FinTech
solutions, cyberattacks are inevitable, making enhanced security technology indispensable to
ensuring future growth. Information leakage is one of the most common vulnerabilities and
is still difficult to be prevented completely. [8]

In this paper, we present current Regulations of Security Standard in Indonesia that issued by
OJK and compare to another Regulations in the World such as another countries regulations
and also World Security Standard in Fintech. For this purpose we collect and review some
regulations present in the literature, analyze all regulations and define some challenges for
future Indonesian Regulations improvement. Section two presents the methodology used in
this paper in order to select the most appropriate recent regulation or security standard and
development or technology as published in literature review covering the topics of Fintech
security segulation, standard, technology and secure computation. The in-depth analysis of
the results, as identified by our methodology, is given in Section 3. Initially, existing defined
regulation and security standard are analyzed with a focus on how to provide technology
standard for fintech security. Afterwards, a comparison of the existing regulations is given.
The analysis is concluded by overviewing Indonesian Regulation by defining its difference
compare to another standard and technology in the world. The fourth section discusses
challenges and improvements associated with technology constraints along with secure
computation, networking, interoperability issues, big data analyses, security and privacy. An
overview of useful guidelines and solutions needed to face these challenges is given. Finally,
this paper is concluded in the fifth sect

2. Review Methodology
This section presents the methodology used in the paper in order to select the most
appropriate recent developments as published in the literature covering the topics of Fintech
Regulation. The literature about fintech regulation was searched using the online service
Google Scholar (GS) (https://scholar.google.com/), and Indonesian Fintech Regulation was
reviewed for Indonesia Financial Services Authority (Otoritas Jasa Keuangan/“OJK”).
Google Scholar has a high coverage for high quality studies, is highly sensitive and could be
the first, and even more so a standalone choice for systematic reviews or meta-analysis
(Gehanno et al., 2013). We are only looking for publications, not including patents and
quotations. GS sorts all the results provided according to their relevance. Google Scholar's
ranking algorithm relies heavily on the number of article citations, but also gives high weight
to the words in the title (Beel and Gipp, 2009). We have considered only publication between
the years 2014 and 2019 Most of the advances in this area have happened within the last few
years, therefore papers prior to 2014 were not considered. (GS retrieves 324 publications
with keyword “Security Regulation of Fintech” in the title published before 2014, and 6250
publication published after 2014), which is in line with the Google trends as shown in Fig. 2.

Fig. 2 Interest over time according to Google trends since 2014 for terms Security
Fintech, Fintech Regulation and Fintech Security Standards

3. In- depth analysis of literature/Review Result and Analysis

The in-depth analysis of the results, as identified by our methodology, is given in Section 3.
Initially, existing defined regulation and security standard are analyzed with focus on how to
provide technology standard for fintech security. Afterwards, a comparison of the existing
regulations is given. The analysis is concluded by overviewing Indonesian Regulation by
defining its difference compared to another standard and technology in the world.

Fintech Ecosystem
There are five elements of the fintech ecosystem [13]:
1. Fintech startups (e.g., payment, crowdfunding,);
2. Technology developers (e.g., big data analytics, cloud computing, cryptocurrency, and
social media developers);
3. Government (e.g., financial regulators);
4. Financial customers (e.g., individuals and organizations); and
5. Traditional financial institutions (e.g., tradition-al banks, insurance companies, stock
brokerage firms, and venture capitalists).

From these element, the Fintech Regulation is under resonsibility of Government ecosystem.
Figure 3 shows the five elements of the fintech ecosystem

Fig. 2 Fintech Ecosystems

Fintech Regulation in Indonesia [9]

Currently, there are two authorities regulating fintech in Indonesia. Bank of Indonesia
regulates fintech relating to payments, whereas OJK regulates all fintech that provides
financial services, such as digital banking, P2P lending, crowd funding, insure-tech,
investment, and market aggregators. The existing regulations are divided into 5 kinds of
regulations such as :
[Source : ojk.go.id] OJK Regulation No.77/POJK.01/2016 on Information Technology-
based Lending, OJK Regulation No.12/POJK.03/2018 on the Implementation of Digital
Services by Commercial Banks, OJK Regulation No.13/POJK.02/2018 on Digital
Financial Innovation in the Financial Services Sector, OJK Regulation
No.37/POJK.04/2018 on Equity Crowd Funding, Bank of Indonesia Regulation
No.19/10/PBI/2017 on Fintech Companies, Bank of Indonesia Regulation
No.20/6/PBI/2018 on Electronic Money (E-money). The legal umbrella for all types of
fintech is OJK No.13/POJK.02/2018 which is effective from 16 September 2018 and has
key content of the regulation as summarized below :

a. Recording and Registration Mechanism

All fintech firms must comply with OJK regulation and follow three key steps:
1. Recording
OJK analysis submitted required documents of fintech to decide whether : (1) meet
the criteria as innovators and comply with OJK regulation; (2) are selected to be tested
on the regulatory sandbox; and (3) which cluster they are classified in based on the
business model mapping.
2. Regulatory Sandbox
By using a sampling and prototyping method, selected fintech from each business
model (cluster) is tested with five key steps involved: 1) understanding the business
model, business process, and governance; 2) choosing the review methodology and
scenarios; 3) testing and experimentation; 4) improvement of model; and 5) final
evaluation. The length of the regulatory sandbox process could vary from a few
months to 1 year, with the extension of up to 6 months if they are required to rectify
their business.
3. Registration
Recommended Fintech firms from regulatory sandbox step must apply to the
registration stage 6 months.
b. Governance, Risk and Compliance
Developing and adopting good governance, effective risk management, and compliance
to all rules and regulations is a must to do by Fintech firms to ensure a safety and sound
practice
c. Monitoring and Surveillance Mechanism
Continuously, Fintech firms must submit performance report to OJK and to their
customers as well. There are 4 basic principles of customer protection that should be
applied by fintech including transparency, fair treatment, reliability, data privacy and
security, as well as effective and efficient handling of customers’ complaints.

Fintech Regulation in Hongkong [10]

In Hongkong, Hong Kong Monetary Authority (HKMA) stands as financial regulators and
ready to embrace technology and innovations that emerge in the course of fintech
development. In particular, HKMA adopts a risk-based and technology-neutral approach
in its supervision. and achieves that by emphasizing three key factors such as: its willingness
to learn about and understand fintech; its ability to maintain close contact with the industry
and other stakeholders; and its ability to achieve a good balance between market development
and customer protection. HKMA ensures the existing regulations are up to date also by
keeping in contact with the industry and regulators in other jurisdictions. HKMA announced
in September 2017 the seven smart banking initiatives (HKMA 2017c):
 1. full connectivity of digital retail payments through the Faster Payment System
(FPS),
2. upgrading the existing fintech supervisory sandbox (FSS) to version 2.0,
3. facilitating virtual banking in Hong Kong, China,
4. introducing a new Banking Made Easy initiative to reduce regulatory friction and
improve customer experience
5. development of an Open API framework,
6. stepping up cross-border collaboration in fintech, and
7. enhancing research and talent development.

To enhance coverage and linkages with other relevant partiesIn 2017 HKMA upgraded the
existing Fintech Supervisory Sandbox to have three new features: (i) a fintech supervisory
chatroom (Chat Room) to provide supervisory feedback to banks and technology firms at an
early stage of their fintech projects; (ii) tech firms’ direct access to the FSS by seeking
feedback from the Chatroom without going through a bank; and (iii) the sandboxes of HKMA,
the Securities and Futures Commission, and the Insurance Authority are linked to provide a
single point of entry for pilot trials of cross-sector fintech products. As of the end of May
2019, HKMA had received a total of 304 requests to access the Chatroom.
Against the backdrop of growing cyber-threats and cyber-risks, the Cybersecurity
Fortification Initiative was implemented in December 2016 to raise the cyber-resilience of
Hong Kong, China’s banking system which is founded on three pillars: (i) Cyber Resilience
Assessment Framework; (ii) Professional Development Programme; and (iii) Cyber
Intelligence Sharing Platform.

Fintech Regulation in Singapore [11]

Monetary Authority of Singapore (MAS), The financial regulator in Singapore is one of the
regulators worldwide that respond early to the development of FinTech and had since March
2001 been issuing a set of Internet banking and technology risk management guidelines
(today known as “Technology Risk Management Guidelines” with its latest revision in March
20135) as benchmarks for such assessment. To preserve trust and credibility in financial
system, MAS adopt the following policy approach in regulating this new wave of innovation
in financial services :

a. Firstly, MAS takes a differentiated approach to different technologies and their

applications since a “one-size-fits-all” regulatory approach will clearly not be
appropriate. As the current wave of FinTech start-ups are developing technology to
improve a particular financial service or product, the risks embedded in their activities
or due to the nature of their technology are different. So it’s possible different regulations
applied to Bank, Digital Payment or P2P Lending platforms.
b. Secondly, MAS will adopt a risk-based approach to FinTech innovation in the
unregulated sector. To keep innovation fintech grow, MAS is not introducing regulation
prematurely because it may stifle innovation and potentially derail the adoption of useful
technology, therefore it always ensures that regulation must not be a front runner of
innovation. Instead, MAS applies a materiality and proportionality test. Materiality test
 applied when risk by new technology becomes material and it is applied proportionate
to the risk posed.

c. Thirdly, MAS on 16 November 2016 issued “FinTech Regulatory Sandbox Guidelines”.

To enable Fintech releases their products or services to production, the Regulatory
Sandbox with risk based approach is performed at provided laboratory environment to
experiment the proposed financial services leveraging on innovative FinTech solutions.
Although the Sandbox cannot remove all risks, as failure is an inherent characteristic of
innovation, the Sandbox helps carve out a safe and conducive space to experiment with
FinTech solutions, and if the experiment fails, its impact on consumers and on financial
stability will be limited. MAS also has MAS FinTech Office to support Fintech by
providing a way to discuss other possible forms of support from MAS such as financial
support, cross-agency support, mentorship, training on regulatory framework, access to
Application Programming Interfaces (APIs), business partnerships, manpower, co-
working space, and introductory services and provisioning of a cloud environment for
sandbox experimentation

The regulatory comparison summarized as shown below :

Regulation Indonesia Hongkong Singapore

Approach Balanced Regulatory Risk Based

Framework Risk-based and
technology neutral
approach

Technology Constraint Yes Yes Yes

Multi regulation Yes Yes Yes

Collaboration Yes Yes Yes

Testing Mechanism Regulatory Sandbox Regulatory Sandbox Regulatory Sandbox

Security Standard Yes Nothing Nothing

Customer Protection Fintech Responsibility Fintech Responsibility Fintech Responsibility

Fintech Development No Yes Yes

Support

4. Challenges and solutions

Crucial issue in regulating fintech is always about speed comparison between Innovation
speed and Regulation Speed. Although OJK already realized this fact and even provide
strategies to support digital financial innovations in Indonesia, the process of applying for
permits for operational is somewhat slow based on Survey Conducted by Daily Social in
2018. In Indonesia, the approval process can take time from few months to 1 year with 6
months extension if needed. In Singapore by 7 Agustus, MAS launched Sandbox Express
which only requires 21 days to perform sandbox testing.
Another issue of Fintech Development is the support of Regulator in developing Fintech.
Hongkong launches Fintech Supervisory Sandbox to support Fintech Firm to get feedback at
an early stage, while Singapore has MAS FinTech Office to support Fintech by providing a
way to discuss other possible. The speed of regulation and support to Fintech Development
are challenges to Indonesian OJK and writer think OJK can adopt from Singapore &
Hongkong initiatives.

5. Conclusions

Major advancements in Fintech Development in recent years have triggered the attention of
Financial Regulators around the world, including Bank Indonesia and OJK. OJK stands to
keep good balance between Innovation and integrity of Financial markets and customer
protections.
As Fintechs are developing technology to provide particular services or products, OJK issued
multiple regulations to be appropriate for Fintech Business and technology. To validate the
reliability of business process, business model, financial instruments of Fintech Firm, OJK
apply Regulatory Sandbox which might take a few months to 1 year period with 6 months
extension. This Regulatory sandbox is claimed slow based on survey taken by Daily Social
which can be optimized by decreasing period of Sandbox Test Period. In addition with faster
time of Sandbox period, OJK can also provide a Team to support Fintech Development to
ease Fintech firm seeking feedback at an early stage of testing. Kind of sandbox regulation
improvements have been issued by Singapore & Hongkong such as Sandbox Express with
only 21 days period, Fintech Chat Room and Support Team from Regulators to supervise the
fintech firm. Since OJK open opportunity to collaborate with domestic or international key
stakeholder, Singapore and Hongkong are good choice to collaborate with.

References

[1] A. Nordrum, “The Internet of fewer things,” IEEE Spectrum, vol. 53, no. 10, pp. 12-13, 2016.
[2] FSB Definition
[3] https://www.pwc.com/gx/en/industries/financial-services/fintech-survey/report/data-explorer.html?11000
[4] https://assets.kpmg/content/dam/kpmg/xx/pdf/2019/07/pulse-of-fintech-h1-2019.pdf KPMG
[5] https://assets.kpmg/content/dam/kpmg/xx/pdf/2019/02/the-pulse-of-fintech-2018.pdf
[6] https://www.pwc.com/id/en/fintech/PwC_FintechLendingThoughtLeadership_ExecutiveSummary.pdf
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[12] FINTECH REPORT 2018
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