KEKABURAN HUKUM PENDAFTARAN KONTAK DARURAT DALAM PERJANJIAN KREDIT ONLINE BERDASARKAN PERATURAN OTORITAS JASA KEUANGAN NOMOR 10/POJK.05 TAHUN 2022

This study aims to analyze the urgency of regulating the registration of emergency contacts in online credit loan agreements based on the Financial Services Authority Regulation (POJK) No. 10/POJK.05/2022, and to formulate the appropriate legal provisions to ensure protection for individuals designated as emergency contacts. The practice of including emergency contacts without the data subject’s consent frequently gives rise to legal issues, particularly when such individuals become targets of debt collection or psychological pressure, despite having no contractual relationship with the fintech lending provider. Therefore, a comprehensive legal review is necessary to prevent violations of privacy rights and personal data protection. This research adopts a normative juridical method using a statute approach. Data were collected through literature study involving primary legal materials such as statutory regulations, including the Consumer Protection Law, the Electronic Information and Transactions Law (ITE Law), the Personal Data Protection Law, and POJK No. 10/POJK.05/2022. Secondary legal materials such as legal literature, scholarly journals, and relevant policy documents were also utilized. The findings indicate that POJK No. 10/POJK.05/2022 does not explicitly regulate the mechanism for registering emergency contacts, leading to legal uncertainty and potential misuse of personal data by both borrowers and fintech providers. Accordingly, the regulation should be revised to include normative provisions requiring verification, notification, and written consent from individuals listed as emergency contacts in order to establish fair and equitable legal protection within the fintech lending ecosystem.