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Crypto Regulation in Indonesia – A Guide for Businesses

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Indonesia’s crypto landscape is evolving at an extraordinary pace. By the end of 2023, the country had recorded over 17 million crypto investors, with transaction volumes surpassing IDR 300 trillion. This momentum carried into 2024, where volumes skyrocketed to over IDR 650 trillion. These figures reflect not only increasing investor interest but also a growing recognition of crypto’s economic impact. Recognizing the urgency to provide robust oversight, Indonesia is transitioning its regulatory approach from a commodities-focused regime to a financial services framework marking a major milestone in digital asset governance.

Historically, the supervision of crypto assets in Indonesia rested with the Commodity Futures Trading Regulatory Agency (BAPPEBTI). However, in an effort to align crypto regulations with financial market standards and strengthen investor protections, the Financial Services Authority (OJK) will take over this role starting January 10, 2025. This shift is part of a broader effort to integrate crypto assets into the formal financial architecture and foster innovation through Digital Financial Innovation (DFI).

Key Takeaways

  • OJK Takes Over Regulation: Starting January 10, 2025, OJK replaces BAPPEBTI as the primary regulator of crypto in Indonesia.
  • New Licensing Rules Apply: POJK No. 27 of 2024 introduces comprehensive requirements for crypto exchanges and custodians.
  • Crypto Reclassified as DFA: Digital assets are now treated as Digital Financial Assets (DFAs), aligning with global financial standards.
  • Mandatory AML/KYC Compliance: All crypto businesses must adhere to anti-money laundering and know-your-customer regulations.

Regulatory Shift: From BAPPEBTI to OJK

The shift in regulatory authority is not arbitrary, it stems from the enactment of Law No. 4 of 2023 on Financial Sector Development and Strengthening (P2SK Law), reinforced by Government Regulation No. 49 of 2024. Effective from January 10, 2025, this legal framework officially transfers regulatory duties for crypto and other digital financial assets from BAPPEBTI to OJK. The move reflects the government’s intention to treat crypto as a component of financial services, with regulatory rigor comparable to that of traditional banking and securities.

Legal Transition Timeline & Authority Transfer

To ensure a smooth transition, the changeover was formalized through a Memorandum of Understanding (MoU) and official minutes signed on January 10, 2025. While the transition period will continue until January 2027, core responsibilities particularly in licensing and oversight are effective immediately. This timeline allows businesses time to adapt, but it also requires immediate action on compliance and documentation.

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Key Laws and Implementing Regulations

OJK has laid out the legal foundation for this transition through POJK No. 27 of 2024 and Circular Letter SEOJK No. 20 of 2024. These regulations provide detailed requirements for licensing, operations, corporate governance, risk management, and reporting obligations. Together with Government Regulation No. 49 of 2024, they constitute the cornerstone of Indonesia’s new digital asset regulatory regime.

Crypto Reclassification: From Commodity to Financial Asset

One of the most significant changes is how crypto assets are now classified. Previously treated as commodities under BAPPEBTI, they are now redefined as Digital Financial Assets (DFAs) under OJK. This reclassification implies tighter regulation and oversight, similar to securities markets. It also aligns Indonesia’s approach with international best practices, improving market integrity and investor confidence.

Licensing Requirements Under OJK Oversight

Entities intending to operate within Indonesia’s crypto ecosystem such as exchanges, custodians, clearinghouses, and brokers must now apply for licenses from OJK. These licenses are granted to Digital Financial Asset Trading Providers and come with rigorous requirements on governance, compliance, and transparency. This marks a departure from the relatively lenient framework under BAPPEBTI.

Capital Requirements: Higher Thresholds for Market Players

Capital requirements have also become more stringent. For instance, crypto exchanges must have a minimum paid-up capital of IDR 1 trillion, with 80% held in equity. Clearing and settlement institutions require IDR 500 billion, and custodians need at least IDR 250 billion. These thresholds aim to ensure only financially stable and trustworthy entities participate in the ecosystem, though they may pose a challenge for smaller startups.

Fit-and-Proper Tests, Governance, and Data Protection

In line with global regulatory trends, OJK now requires licensed entities to pass comprehensive fit-and-proper tests for their directors and commissioners. Businesses must also implement strong corporate governance frameworks and comply with personal data protection obligations. Importantly, all licensed crypto service providers must fully implement consumer protection measures by July 2025, signaling OJK’s focus on safeguarding user interests.

Certified Employee Requirements

To further strengthen internal controls, exchanges, custodians, and clearing entities must employ at least one certified information system auditor and one certified information system security professional. This ensures technical robustness and resilience against cybersecurity threats, a crucial requirement given the digital nature of crypto assets.

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Operational Compliance and Reporting: A New Digital Backbone

OJK has launched the Integrated Licensing System, known as SPRINT, to facilitate digital registration and compliance. This platform replaces the former BAPPEBTI system and serves as a centralized hub for all licensing processes, enabling faster, more transparent submissions.

Simultaneously, crypto businesses must now adhere to Anti-Money Laundering (AML) and Know-Your-Customer (KYC) obligations under SEOJK No. 20 of 2024. They are also required to report suspicious transactions to Indonesia’s Financial Transaction Reports and Analysis Center (PPATK). These standards are critical for preventing misuse of crypto assets for illicit activities.

Approved Crypto Assets and Whitelisting Mechanism

Crypto exchanges are no longer free to list any asset. In early 2025, BAPPEBTI had already expanded the tradable crypto whitelist to over 850 assets. Under OJK’s watch, trading platforms must revalidate and publish a reviewed whitelist by April 2025. Any digital asset not reapproved by February 2025 must be delisted, ensuring higher quality control over tradable instruments.

Implications for Exchanges, Fintech Startups, and Investors

The impact of these changes is significant. For exchanges and fintech startups, the increased capital requirements and compliance burdens may serve as a barrier to entry. Strategic partnerships or joint ventures might become necessary. On the other hand, investors stand to gain from more secure platforms, clear legal frameworks, and better consumer protection. Regulatory synergy between OJK, Bank Indonesia (BI), and PPATK is expected to promote a safer and more transparent investment environment.

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Enforcement, Penalties, and Consumer Safeguards

OJK is granted substantial enforcement powers under the new regulations. Non-compliance may result in serious consequences, ranging from license revocation and financial penalties to asset delisting and potential criminal charges. In addition, OJK’s ability to monitor transactions in real-time, combined with its collaboration with PPATK and law enforcement, enhances its capacity to detect fraud and prevent abuse in the crypto market.

Practical Commentary from Kusuma & Partners Law Firm

To navigate this regulatory transformation effectively, we offer the following recommendations:

  • Start early: Don’t wait until the deadline, initiate licensing and capital compliance submissions through SPRINT as soon as possible.
  • Enhance governance and data protection: Ensure your corporate policies align with OJK’s requirements, particularly by July 2025.
  • Whitelist review: Evaluate your listed assets and prepare for reapplication or removal as required.
  • Strengthen AML/KYC systems: Make sure your internal systems comply with the reporting and documentation standards under SEOJK No. 20 of 2024.
  • Seek legal guidance: Our team can assist in reviewing your contracts, compliance documentation, and operational readiness.

Conclusion

Indonesia’s regulatory landscape for crypto has entered a transformative phase. With OJK taking the helm effective January 10, 2025, crypto businesses must now operate within a financial framework designed for accountability, investor protection, and systemic resilience. Licensing requirements, real-time supervision, and tighter capital controls are not just bureaucratic hurdles, they are foundations for a sustainable and secure digital asset ecosystem.

By understanding the new rules, acting early, and partnering with experienced legal counsel, companies can not only survive this regulatory transition but thrive within it. The future of crypto in Indonesia is regulated, but also rich with opportunity.

How We Can Help

At Kusuma & Partners, we are here to guide you through every step of this regulatory transformation. Whether you are applying for a new license, reviewing governance policies, or preparing for a compliance audit, our team offers practical and strategic legal support. Reach out today to ensure your crypto venture is secure, legal, and future-ready in Indonesia’s evolving digital asset framework.

Fill in the form below to get our expert guidance.

“DISCLAIMER: This content is intended for general informational purposes only and should not be treated as legal advice. For professional advice, please consult us.

The transition officially begins 10 January 2025 under GR 49/2024, with full transition period up to January 2027.

Exchanges must submit whitelist updates by April 2025; unapproved assets require reapplication or delisting.

OJK may revoke licenses, force delisting, impose fines, and coordinate legal enforcement.

Consider joint venture structures or capital partnerships, and legal advisory for compliant structuring.

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