Branchless banking is a new system which is implemented by banks in Indonesia with aims to provide services to rural communities in order to access banking services such as lending or deposit money in the bank through an intermediary agent. At first the rural communities are hard to obtain banking facilities such as micro-credit whereas economic activities are largely actuated by lower-class sector therefore the Financial Services Authority or Otoritas Jasa Keuangan (OJK) issued the regulation number. 19/POJK.03/2014 about the financial services without office in the framework of financial inclusion on November 18, 2014 to face it. In this regulation, there are several things that need to be reviewed such assessment accountability arrangements of agent as a third party who is not clearly regulated whereas according to some research there are some risk in the mechanism of implementation like as potential of fraud due to the using of agent in this system. Though basically branchless banking is one of the strategic national strategies to provide financing to small businesses in rural areas in order to increase the competitiveness of products to compete in the ASEAN economic community. Therefore, a legal instrument that can ensure and provide legal certainty in branchless banking system is a very important thing, more over branchless banking is the strategic of government to develop the quality of the rural economy to face the ASEAN economic community.