Regulatory Bodies

The primary regulator for blockchain and crypto-asset businesses in Indonesia is the OJK. Following the enactment of Law No 4 of 2023 regarding the Development and Strengthening of the Financial Sector (P2SK Law), supervisory authority over crypto-assets was transferred from the Commodity Futures Trading Regulatory Agency (Badan Pengawas Perdagangan Berjangka Komoditi, or Bappebti) to the OJK, with effect from January 2025. The OJK is responsible for licensing entities in the digital financial asset sector, supervising licensed entities’ compliance, and issuing sector regulations.

Bank Indonesia (the central bank) retains relevance to the extent that crypto-asset transactions intersect with the payment system, given its authority over PJPs and its ongoing development of the Digital Rupiah. The Ministry of Communication and Digital Affairs is also relevant, as Digital Financial Asset Trading Operators are required to be registered as ESPs with that ministry – a requirement expressly confirmed under OJK Reg 27/2024, as amended.

Regulatory Approach

The OJK’s approach to regulating the digital asset sector has been incremental and consultative. The regulator has progressively expanded the scope of the framework, from the foundational regime to addressing crypto-asset derivatives under OJK Reg 27/2024, as amended, and primary market offerings through the Draft OJK Regulation on digital financial asset offerings. The OJK typically consults industry associations and stakeholders when developing new regulations.

Classification of Crypto-Assets

Under OJK Reg 27/2024, crypto-assets are classified as digital financial assets, characterised as digital commodities intended for investment. Despite being supervised by the OJK, crypto-assets are not classified as financial instruments in the traditional sense. The framework distinguishes between backed crypto-assets, whose value is tied to underlying assets, and unbacked crypto-assets, which have no such backing.

Regulated Activities

The activities regulated under OJK Reg 27/2024 are those conducted by licensed Digital Financial Asset Trading Providers. The Digital Financial Asset Trader licence is the most commonly sought authorisation by foreign entities entering Indonesia, and permits the following activities:

• buying and selling crypto-assets against Rupiah;
• exchange between one or more types of crypto-assets;
• custody of consumer crypto-assets; and
• transfer or movement of crypto-assets between wallets.

Prohibited Activities

There is no exhaustive list of prohibited crypto-asset activities. However, the use of crypto-assets as a means of payment is not permitted, as the Rupiah is the sole recognised legal tender in Indonesia. PJPs are also prohibited from processing payment transactions involving crypto-assets. In addition, only crypto-assets listed on the official approved list may be traded on licensed platforms; assets not on this list cannot be offered or traded through Indonesian licensed channels.

Upcoming Regulations

The most significant near-term regulatory development is the anticipated finalisation of the OJK’s draft regulation on digital financial asset offerings, which would establish Indonesia’s first regulatory framework for Initial Coin Offerings (ICOs) and Initial Token Offerings (ITOs). Published for public consultation in September 2025, this regulation will introduce a structured approval and disclosure regime for primary market activities in the digital asset sector, once finalised.

The use of a legal wrapper, such as a fund, does not alter the fundamental licensing requirements applicable to crypto-asset activities in Indonesia. Any entity that conducts activities falling within the scope of regulated digital financial asset trading activities under OJK Reg 27/2024, as amended, will be required to obtain the appropriate OJK licence, regardless of its corporate form, as the licensing obligation attaches to the nature of the activity being conducted rather than the legal form of the entity. This also means that any fund wishing to conduct activities within the scope of OJK Reg 27/2024, as amended, would need to obtain the requisite licence.

Regulatory Status of ICOs and ITOs

Indonesia does not yet have a finalised regulatory framework governing the issuance of crypto-assets to the public through ICOs or ITOs. The OJK published a draft regulation on digital financial asset offerings for public consultation in September 2025, but it has not yet been finalised. Until it comes into force, there is no formal process through which an entity can lawfully conduct an ICO or ITO in Indonesia.

Listed Assets Requirement

Under OJK Reg 27/2024, as amended, only crypto-assets included in the official list of approved digital financial assets may be traded on licensed platforms in Indonesia. Any crypto-asset not on this list cannot be offered or traded through Indonesian licensed channels, regardless of how the asset was issued. This gatekeeping mechanism effectively determines which crypto-assets have access to the Indonesian market.

Crypto-Asset Markets

There is currently no market abuse or insider trading framework specifically applicable to crypto-asset trading in Indonesia. OJK Reg 27/2024, as amended, and its amendments do not contain provisions addressing market manipulation, insider trading or other forms of market abuse in the crypto-asset context. This represents a notable gap in the regulatory framework, particularly as the crypto-asset market continues to grow.

Capital Markets Framework

By contrast, Indonesia’s capital markets framework contains well-established insider trading provisions under Articles 95 to 98 of Law No 8 of 1995 regarding Capital Markets, which are applicable to securities traded on the Indonesian Stock Exchange. The following conduct is prohibited:

• any insider of an issuer or public company possessing inside information is prohibited from purchasing or selling that company’s securities or the securities of companies transacting with it;
• any insider from influencing other parties is prohibited from trading on inside information, or from disclosing inside information to any party that could reasonably be suspected to use it to trade;
• any non-insider who knows or should know that information is inside information is prohibited from conducting the above acts; and
• securities companies possessing inside information are prohibited from conducting securities transactions involving those securities, unless acting on customer instructions without providing any recommendation.

These provisions apply to securities and do not extend to crypto-assets. The absence of an equivalent framework for crypto-asset markets means that conduct prohibited in the securities context may not currently be subject to regulatory sanction in the crypto-asset context.

Enforcement Against Unlicensed Entities

The most visible enforcement mechanism applied in Indonesia’s crypto-asset sector is the blocking of access to foreign platforms that provide regulated crypto-asset services to Indonesian consumers without a local licence. In practice, the websites and applications of such platforms are blocked in Indonesia and cannot be accessed without a VPN. This has been applied to a significant number of foreign crypto-asset platforms, and reflects a consistent regulatory policy.

Enforcement Against Individuals

Enforcement actions specifically targeting individual foreign nationals providing crypto-asset services to Indonesian consumers have not been a prominent feature of the regulatory landscape. The enforcement focus to date has been on the entities providing the services rather than on individuals.

Outlook

The regulatory enforcement stance is unlikely to change materially in the next 12 months. The approach of blocking unlicensed foreign platforms has been consistent since the early development of the crypto-asset industry in Indonesia, and reflects a settled policy position. As the OJK’s institutional capacity grows, more active enforcement across a broader range of non-compliant conduct may be expected over time.

Triggers for Licensing

A licence from the OJK is required when a company wishes to conduct activities falling within the scope of regulated digital financial asset trading activities under OJK Reg 27/2024, as amended. This encompasses the activities of Digital Financial Asset Trading Providers. Any company whose proposed business model involves any activity that falls within the defined scope of these licenceswill be required to obtain the relevant licence before commencing operations.

Territorial Scope

The licensing requirement applies to entities providing services to consumers in Indonesia, regardless of where the entity is incorporated or based. The OJK takes the position that foreign entities actively offering or providing regulated crypto-asset services to Indonesian consumers are subject to Indonesian licensing requirements. The most common basis for requiring a foreign entity to establish a local presence is the solicitation or provision of services to Indonesian residents.

Grandfathering

There are no grandfathering provisions under the Indonesian crypto-asset regulatory framework. All entities wishing to conduct regulated digital financial asset activities in Indonesia must obtain the relevant OJK licence before commencing operations. There are no transitional arrangements permitting existing businesses to continue operating during the course of a licensing application.

To obtain a Digital Financial Asset Trader licence, which authorises the holder to provide crypto-asset buying, selling, exchange, custody and wallet transfer services to Indonesian consumers, the following principal requirements apply.

Capital Requirements

Applicants must demonstrate paid-up capital of at least IDR100 billion (approximately USD6 million) and maintain equity of at least IDR50 billion (approximately USD3 million). Capital used to fund the entity may not be sourced from loans or other forms of debt financing.

Personnel and Organisational Requirements

The applicant must employ at least one staff member holding a Certified Information Systems Security Professional (CISSP) certification. A minimum of three directors is required, with the majority being Indonesian citizens domiciled in Indonesia, and the President Director is required to be an Indonesian citizen. A minimum of two commissioners must also be appointed, with the total number not exceeding the number of directors. The organisational structure must include at a minimum divisions for information technology, audit, legal, consumer complaints, client support, and accounting and finance.

Operational and Regulatory Requirements

The applicant must operate an online trading system through which it provides its services, and must maintain standard operating procedures covering all obligations under applicable regulations. The applicant must also be registered as an ESP with the Ministry of Communication and Digital Affairs – a requirement confirmed under OJK Reg 27/2024, as amended.

Any change in the shareholders, directors or commissioners of a licensed Digital Financial Asset Trading Provider requires prior OJK approval through a Fit-and-Proper Test (FPT) process. Accordingly, the acquisition of a licensed Digital Financial Asset Trading Provider resulting in a change of controlling shareholder requires the incoming shareholder to undergo and pass the OJK FPT before the change of control takes effect. The same requirement applies to changes at the director and commissioner level.

The FPT involves the OJK assessing the integrity, competence and financial soundness of the proposed shareholder, director or commissioner. In practice, parties planning an acquisition of a licensed entity should factor in the time required for the FPT process when structuring the transaction timeline, and acquisition agreements typically include the successful completion of the FPT as a condition precedent to closing.

Indonesia does not operate a licence passporting regime. A licence obtained from the OJK to conduct digital financial asset activities is valid only within Indonesia and does not confer any right to conduct equivalent activities in other jurisdictions. Similarly, licences obtained in foreign jurisdictions do not provide any regulatory recognition or benefit in Indonesia. Each jurisdiction must be approached on its own terms, requiring a separate application process.

Cross-Border Service Restrictions

The cross-border provision of regulated digital financial asset services into Indonesia without a local licence is not permitted. The OJK’s position is that entities providing regulated crypto-asset services to Indonesian consumers must hold the appropriate Indonesian licence. Foreign entities that continue to provide such services without a licence face the risk of having their platform access blocked in Indonesia – a measure that has been actively enforced against a significant number of foreign crypto-asset platforms.

Exemptions and Reverse Solicitation

There are no formal exemptions to the licensing requirement for cross-border service providers. Reverse solicitation does not provide reliable protection in Indonesia, as the practical risk of platform access being blocked continues regardless of which party initiated contact. Reliance on reverse solicitation as a basis for serving Indonesian consumers without a licence carries significant regulatory risk given the OJK’s active enforcement stance.

Marketing of Digital Assets

There are no marketing restrictions in Indonesia specifically directed at digital assets themselves. Applicable marketing restrictions are directed at licensed Digital Financial Asset Traders and relate to how they promote their services. In particular, Digital Financial Asset Traders are prohibited from representing that crypto-asset investments are guaranteed to generate profits or are free from the risk of loss. General Indonesian consumer protection and advertising standards also apply to marketing activities in the digital asset sector.

White-label arrangements in the digital financial asset sector are not expressly addressed under OJK Reg 27/2024, as amended. Given that the licensing obligation attaches to the activity conducted rather than the specific commercial model used, a white-label arrangement through which an unlicensed entity provides regulated services to Indonesian consumers using an existing licensed entity’s licence would need to be carefully structured to ensure the licensed entity retains full regulatory responsibility and control.

Any arrangement that effectively results in an unlicensed entity providing regulated services to Indonesian consumers risks being viewed by the OJK as a circumvention of the licensing requirement. Parties considering such arrangements should seek specific regulatory guidance from the OJK before implementation.

DeFi in Indonesia

Decentralised finance is not yet explicitly regulated in Indonesia. There is no dedicated regulatory framework addressing DeFi activities, and the existing digital financial asset framework under OJK Reg 27/2024, as amended, does not specifically contemplate DeFi structures or activities.

CeFi Firms and DeFi

Licensed Digital Financial Asset Traders (the primary category of centralised finance entities in the Indonesian crypto-asset context) are permitted to engage in activities beyond their core licensed activities, subject to prior OJK approval. This provides a potential pathway for licensed Traders to incorporate DeFi-related elements into their service offerings. There is no established precedent regarding the terms on which such approval would be granted, and any DeFi-related product or service would be subject to OJK review.

As DeFi is not yet explicitly regulated in Indonesia, there are no established corporate structures used specifically for operating DeFi activities in the country. Decentralised autonomous organisations and similar structures do not have a recognised legal form under Indonesian law. Any entity wishing to engage in DeFi-related activities in Indonesia would need to operate through a recognised legal entity and, where those activities constitute regulated digital financial asset activities, would need to obtain the relevant OJK licence or approval.

As DeFi is not yet explicitly regulated in Indonesia, there is no established judicial or regulatory guidance addressing accountability and liability for harm caused by DeFi activities. No significant enforcement actions relating to DeFi have been reported in Indonesia to date. In the absence of a specific framework, claims arising from DeFi-related activities would need to be assessed under Indonesia’s general civil and commercial law, which is not designed to address the specific characteristics of decentralised protocols. This represents a significant area of legal uncertainty for DeFi participants operating in or in connection with Indonesia.

Payments in crypto-assets are not permitted in Indonesia. The Rupiah is the sole recognised legal tender, and all transactions within Indonesia must be denominated and settled in Rupiah. Crypto-assets are not recognised as a means of payment under any Indonesian regulation. PJPs are expressly prohibited from processing payment transactions involving crypto-assets as a payment instrument, reinforcing the prohibition at the payment infrastructure level.

Regulatory Classification

Under OJK Reg 27/2024 and the Draft OJK Regulation on digital financial asset offerings, tokenised assets are recognised as a distinct category of digital financial assets. The Draft OJK Regulation distinguishes between backed tokenised assets, supported by underlying real-world assets, and unbacked tokenised assets, which are not asset-backed. This classification reflects the OJK’s intention to develop a framework accommodating real-world asset tokenisation as a distinct product category.

Comparison With Non-Blockchain Equivalents

Traditional securities such as shares and bonds are regulated under Law No 8 of 1995 regarding Capital Markets, and supervised by the OJK’s capital markets division. Tokenised versions of such assets, to the extent they constitute digital financial assets under OJK Reg 27/2024, as amended, would fall under the digital financial asset framework rather than the capital markets framework.