The development of digital payment systems through the Quick Response Code
Indonesian Standard (QRIS) has enhanced the efficiency of cashless
transactions. Nevertheless, in practice, some merchants continue to impose
Merchant Discount Rate (MDR) fees on consumers, despite Article 52 of Bank
Indonesia Regulation Number 23/6/PBI/2021 on Payment Service Providers
explicitly prohibiting such practices. Under this regulatory framework,
Payment Service Providers have specific legal obligations related to merchant
compliance with the prohibition on transferring MDR fees to consumers. This
research aims to analyze the effectiveness of the legal regulation governing
the role of PJP in ensuring merchant compliance with the prohibition of MDR
charges in QRIS transactions.
This study employs normative legal research using statutory and conceptual
approaches. Secondary data consisting of primary, secondary, and tertiary
legal materials were analyzed qualitatively. The analysis is grounded in the
theory of legal effectiveness proposed by Soerjono Soekanto and by Bruggink.
The findings indicate that although the regulation provides a clear normative
basis for assigning supervisory obligations to PJP, its effectiveness has not
been fully achieved due to weaknesses in sanction mechanisms and inter-PJP
coordination. Consequently, regulatory refinement is required to strengthen
consumer protection and legal certainty within the QRIS payment system.