Tata Kelola Risiko Digital sebagai Kapabilitas Dinamis: Heterogenitas Jalur Institusional Antarjenis Bank di Indonesia

Abstract

This paper argues that digital risk governance in the Indonesian banking sector should be understood not merely as a compliance function reacting to environmental pressure, but as a dynamic capability — a sensing-seizing-transforming cycle that constitutes a source of institutional resilience and competitive differentiation. Building on this premise, the paper further proposes that the conversion of digital risk governance into sustainable outcomes is heterogeneous across bank types, following at least three distinct institutional pathways: resource dependence (State-Owned Banks), dynamic-capability agility (Digital Banks), and stakeholder legitimacy (Islamic Banks). To ground these propositions empirically, the internal and external environment of the sector is diagnostically scanned using SWOT (enriched by the Resource-Based View and Dynamic Capabilities Theory) and PESTEL (complemented by Porter's Five Forces, Institutional Theory, and Stakeholder Theory), with results mapped onto the IFE–EFE and Internal–External (IE) Matrices. These tools function as a diagnostic scaffold rather than the paper's theoretical contribution: the resulting Hold-and-Maintain position (IFE 2.50; EFE 2.46) is treated as supporting evidence for capability-gap diagnosis, not as a novel finding in itself. The study relies on secondary and empirical data — regulations of the Financial Services Authority (OJK), publications of the National Cyber and Crypto Agency (BSSN), banking statistics, and industry sustainability reports — following a desk-based strategic analysis approach. The core contribution is twofold: (1) repositioning digital risk governance as a strategic capability rather than a reactive compliance response, and (2) formalizing three testable propositions on the heterogeneity of governance pathways across bank types, intended as the conceptual foundation for a subsequent SEM-PLS study with bank type as a moderating variable. Benchmarking against recent Indonesian banking risk-management and public-finance studies, which apply comparable diagnostic tools without addressing capability heterogeneity across institution types, further clarifies where this paper's contribution is — and is not — located.