Analysis of Sharia Compliance in Refinancing Procedures for Non-Performing Clients: A Case Study of the Sharia Supervisory Board's Opinion at BPRS Amanah Ummah

The expansion of Indonesia’s Islamic banking financing, which reached IDR 643.55 trillion in 2024, alongside a non-performing financing ratio of 2.12%, highlights the need for Sharia compliance in refinancing distressed clients. Prior research has examined product-level compliance, while limited attention has been given to Sharia Supervisory Board (DPS) opinions as ex-ante controls in refinancing decisions at Sharia Rural Banks (BPRS). This study analyzes the refinancing procedure for a non-performing client at BPRS Amanah Ummah and assesses the conformity of DPS Opinion No. 01/DPS/BPRS AU/VI/2025 with DSN-MUI Fatwas. Using a qualitative case-study design, the study examined four documentary sources: the DPS opinion, refinancing contract and addendum, standard operating procedure, and business-condition documents. Data were analyzed through extraction, mapping, compliance assessment, classification, and synthesis. Findings show that the DPS opinion operates as an ex-ante compliance control that informs contract adjustment, obligation rescheduling, and post-refinancing monitoring. The Musyarakah Mutanaqishah–Ijarah refinancing arrangement was consistent, within the reviewed documents, with the assessed provisions of DSN-MUI Fatwas No. 89 on Sharia refinancing, No. 73 on Musyarakah Mutanaqishah, No. 48 on rescheduling, No. 09 and No. 112 on Ijarah, and No. 43 and No. 129 on ta’widh. No documentary evidence of riba, gharar, or zulm was identified. However, asset valuation, Ijarah pricing, disclosure quality, and enforcement fairness were outside the assessment scope. It proposes a document-based DPS supervision model comprising formal opinion issuance, a contract-addendum supervision loop, and post-refinancing monitoring. This model guides BPRS and DPS in mitigating Sharia non-compliance risk.