Debt-based crowdfunding activity which offer interest of the loan granted by the investor and the service provider with information technology basis as the intermediary with a low cost, make it easier for any of SMEs/Startup to build and develop their business. Compared to the United Kingdom as the first country which regulated debt-based crowdfunding activity and one of the country which has the most rapid growth of the debt-based crowdfunding activity. According to the research result, may be conclude that Otoritas Jasa Keuangan Regulation No. 77/POJK.01/2016 regarding Loan Services With Information Technology Basis (POJK) which issued by Otoritas Jasa Keuangan (OJK) and Crowdfunding and The Promotion of Non- Readily Realisable Securities Instrument 2014 and the amendment, Crowdfunding (Amendment) Instrument 2014 which issued by Financial Conduct Authority (FCA), has a lot of similarities but still has several differences. However, OJK still needs to add more of provisions especially regarding financial resources, evaluation report and the transfer of ownership, which will support the growth of debt-based crowdfunding activity in Indonesia and mitigate risks which might arise in the future.