Restrictions on social mobilization during the Covid-19 pandemic in the last two years have triggered the increasing use of  technology to enable people continue their daily activities. Such a condition has laid a fertile ground for various digital-based services ranging from transportation, trade, logistics, to other types of services to flourish to fulfill the people’s needs of technology.

One notable digital advancement is the emergence of super-applications, or better known super apps,  which refers to a web-based or mobile-based application that provide multiple services ranging from transportation, e commerce to payment and financial transaction processing.

There are a number of applications that provide delivery/pick-up services for goods, food and/or medicine, home-service, and paid video services. There are also  some e-commerce applications that include property tax payment services as well as purchases of airline tickets, trains, hotels, credit/electricity tokens, concert tickets and other services.

In Indonesia, there are a number of service applications in the non-financial sector, such as Gojek and Grab, which were initially specialized in the transportation sector, as well as Tokopedia and Shopee in e-commerce sector  that eventually offer various financial services.

Currently, Gojek application has payment system services through Gopay, credit services through GopayLater as well as buying and selling of gold and mutual funds services through GoInvestasi. In addition to Gojek application, there is also Shopee application that offers payment and credit system services through Shopee Pay and Shopee Paylater as well as Tokopedia application that provides mutual funds as well as buying and selling of gold services.

The provision of a number of financial services in one application is actually not new. Overseas, there are some super-apps offering services for buying and selling shares, Exchange Traded Funds (EFT), and crypto assets such as the Robinhood, Webull, and Cash App applications. These applications offer easy access for users to get three financial services at once in one application.

From a regulatory perspective, the super-app is subject to the provisions of Government Regulation No. 71 /2019 on the Implementation of Electronic Systems and Transactions. Article 1 number 1 Government Regulation No. 71/2019 states that:

An electronic system is a set of functioning electronic devices and procedures. prepare, collect, process, analyze, store, display, announce, transmit, and/or disseminate electronic information.

Based on Article 4 Government Regulation No. 71/2019, as long as it is not stipulated otherwise by a separate law, every electronic system operator is required to operate an electronic system by meeting the following minimum requirements:

  • can display electronic information and/or electronic documents in full in accordance with the retention period stipulated by the laws and regulations
  • can protect the availability, integrity, authenticity, confidentiality, and access of electronic information in the operation of the electronic system
  • can operate in accordance with procedures or instructions in the operation of the electronic system
  • equipped with procedures or instructions announced in language, information, or symbols that can be understood by the party concerned with the operation of the electronic system; and
  • have an ongoing mechanism to maintain the novelty, clarity, and accountability of procedures or instructions.

Based on the regulation, electronic system operators must ensure that the electronic system meet the minimum operational requirements stipulated in Article 4 Government Regulation No. 71/2019. But then one question arises, what if the electronic system provides services in the field of financial services such as the Gojek,  Shopee, and Tokopedia applications?

Financial service providers are under the supervision of  the Financial Services Authority (OJK) as regulated by Law No. 21/2011 on OJK. while the services of buying and selling gold and/or crypto assets  are under the supervision of the Commodity Futures Trading Supervisory Agency (Bappebti) as regulated by Law No. 32/1997 on Commodity Futures Trading.

In fact, there is no specific regulation issued by the OJK stipulating the minimum requirements for the electronic system to provide financial services. However, the electronic systems offering crypto asset physical market services are specifically regulated by the Commodity Futures Trading Supervisory Agency Regulation No. 8/2021 on Guidelines for the Implementation of Crypto Asset Physical Market Trading on the Futures Exchange.

Article 5 number 1 in conjunction with Article 13 paragraph (1) of the Commodity Futures Trading Supervisory Agency Regulation No. 8 of 2021 stipulates that the electronic systems offering trading on the physical market of crypto assets are under ownership of the physical traders of crypto assets that have secured the approval of the head of the Commodity Futures Trading Supervisory Agency.

To obtain such approval, traders of the physical market for crypto assets are required to meet the requirements as stipulated in Article 14 paragraph (1) of the Commodity Futures Trading Supervisory Agency Regulation No. 8/2021, one of which is to have an online trading system and/or means to facilitate the implementation of trading on the physical asset market of cryptocurrencies linked to Futures Exchanges and Futures Clearing Houses.

Crypto asset physical market trading systems must also meet a number of requirements such as processing data  in accordance to required specifications and database requirements. The organizing party must also be able to store data for a certain period of time until it has a server according to ISO specifications and certification as regulated by Article 14 of  the Commodity Futures Trading Supervisory AgencyRegulation No. 8/2021.

Based on the explanation above, super-app must fulfill the requirements stipulated in Article 4 Government Regulation No. 71/2019. However, super-app offering some financial services are bounded by  Government Regulation No. 71/2019 and  regulations of each institution that supervises particular services, more specifically financial services by the OJK and the physical market for crypto and gold assets services by the Commodity Futures Trading Supervisory Agency

Author / Contributor:

Chyntia Pinky Jullianti,  S.H. 



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