Implementing Consumer Protection Policy in Digital Financial Services: Evidence from Indonesia's Financial Services Authority

This study examines the implementation of Financial Services Authority Regulation No. 22 of 2023 on Consumer and Public Protection in the Financial Services Sector at the OJK Malang Regional Office, a regulation enacted pursuant to Law No. 4 of 2023 on the Development and Strengthening of the Financial Sector. Previous studies have repeatedly concluded that consumer protection policies in Indonesia are not yet optimal, but have not yet applied an implementation framework capable of pinpointing the root of the problem. This study employs a qualitative approach using a case study design, applies the six variables of the implementation model proposed by Van Meter and Van Horn (1975), and triangulates the perspectives of three stakeholder groups: regulators, fintech lending providers, and consumers. Data were collected through in-depth interviews, field observations, and document analysis, and were subsequently analyzed using the interactive model proposed by Miles et al. (2014). The results reveal an uneven configuration. Four variables related to the implementer side namely, policy standards and objectives, interorganizational communication, characteristics of implementing agents, and the attitudes of implementers demonstrated supportive performance, and no resistance was found among industry actors. Conversely, the variables of resources and the economic, social, and political environment acted as limiting factors. This configuration indicates that implementation issues do not stem from regulatory design or implementers’ commitment, but rather from institutional capacity and the readiness of the target group. This study also identifies the paradox of digitalization: digital complaint channels do not reduce institutional workload because low consumer digital literacy redirects service requests back to in-person assistance. Theoretically, this study argues that consumer literacy is not a passive element within environmental variables but rather a cross-variable constraining factor that limits the effectiveness of all other implementation variables.