The rapid growth of Sharia-compliant fintech in the post-pandemic era has brought both innovation and significant risks. The massive fraud case of PT DSI in early 2026, which caused a loss of IDR 2.4 trillion to over 15,000 investors, exposed critical vulnerabilities in the current regulatory landscape of Sharia P2P Lending.
About This Journal
This critical analysis by Dr. Bahori Ahoen, M.E., M.H. (Dosen Hukum Ekonomi Syariah, Universitas Tazkia) performs a legal autopsy on the PT DSI scandal. It investigates how a “Sharia” labeled platform could execute a systemic Ponzi scheme despite existing regulations (POJK No. 10/2022).
Key focus areas include:
- The “Halal Halo Effect”: How psychological bias towards religious labeling caused investors to overlook due diligence.
- Regulatory Loopholes: The absence of mandatory “Independent Trustee” mechanisms and direct asset collateralization.
- Systemic Fraud Anatomy: How PT DSI manipulated project data and used new investor funds to pay old returns.
The Proposed Solution: ICMS (Integrated Collateral Management System)
To restore trust in the Islamic digital economy, the journal proposes a Zero Trust Architecture implemented through an Integrated Collateral Management System (ICMS). This system relies on a “Triple-Lock” mechanism:
- Independent Trustee (Wali Amanat): Removing control of funds from the fintech platform. Funds are held by a third-party Sharia Bank and only disbursed upon verified project milestones.
- Digital Mortgage Rights (Hak Tanggungan Digital): Automatic locking of collateral assets integrated with the National Land Agency (BPN) to prevent double-pledging or asset stripping.
- Smart Contract Execution: Automated disbursement based on physical progress verification, ensuring funds are used strictly for the intended project.
Policy Recommendations
The paper urges immediate regulatory reforms:
- OJK: Mandate the use of Trustees and automatic collateral registration for all P2P lending.
- Cross-Agency Integration: Collaboration between OJK, BPN, and the Ministry of Law to create a tamper-proof Digital Collateral protocol.
- Investor Protection Fund: Establishment of a specialized guarantee fund for Sharia fintech to mitigate systemic fraud risks.
Why It Matters
As Indonesia aims to become a global hub for Islamic Finance, the integrity of its fintech ecosystem is paramount. This journal argues that moral promises are insufficient; the industry needs a framework where Sharia compliance is enforced by unalterable code and strict legal structures.
📄 Read the full journal below: