Indonesia’s blockchain market has been shifting from being primarily focused on crypto asset trading toward a broader utilization of blockchain technology that is increasingly oriented toward infrastructure and utility, from focusing on regulating crypto assets as investment instruments toward utilizing blockchain technology as part of financial infrastructure and the public sector more broadly. This direction of development was also highlighted by Adi Budiarso, Chief Executive of the Financial Sector Technology Innovation, Digital Financial Assets and Crypto Assets Supervision at the Financial Services Authority (“Otoritas Jasa Keuangan” or “OJK”), during an event, Coinfest Asia 2026. On that occasion, Adi Budiarso stated that Indonesia’s economy in the future is expected to increasingly shift toward an on-chain economy, [1] referring to a condition in which economic activities and transactions are conducted by utilizing blockchain technology as one of the key underlying infrastructures.

This development is also reflected in an OJK publication dated 2 October 2025 concerning the tokenization of Real-World Assets (“RWA”) in an OJK publication, Beyond Infinity Edition 2.[2] In the publication, OJK discussed various aspects of RWA tokenization, including the opportunities and challenges associated with its implementation, as well as its potential and development targets in Indonesia. The publication indicates that OJK has begun to place greater attention on the utilization of blockchain technology beyond crypto asset trading, including for representing assets or economic rights that have value in the real world. This, in turn, creates opportunities for the broader application of blockchain technology to support the development of Indonesia’s financial sector and economy. The OJK has also appointed Asosiasi Blockchain Indonesia as the Financial Sector Technological Innoviation (ITSK) Provider Association in 2025.

Furthermore, OJK is also known to be in the process of preparing a regulatory framework concerning the utilization of stablecoins, including plans to test their use as transaction instruments, as well as conducting sandbox testing for several types of digital assets. Such testing includes stablecoins whose value is linked to Rupiah, government securities, gold, and economic rights relating to property.[3] These plans indicate that the development of digital assets in Indonesia is increasingly being directed toward broader applications in economic and financial activities, rather than being used solely as investment instruments.

Although the trading and ownership of crypto assets have been implemented in Indonesia, OJK continues to develop supporting infrastructure to enhance transparency and investor protection. One of the initiatives currently being considered is the implementation of a Single Investor Identification (“SID”) for crypto-asset investors.[4] The concept refers to a mechanism that has been implemented in Indonesia’s capital market, whereby each investor is assigned a unique identification number that can be used to identify and monitor their investment activities. The implementation of SID for crypto assets is expected to strengthen investor identification and support the supervision of crypto asset trading activities in Indonesia.

[1] OJK: Indonesia’s ‘On-Chain Economy’ is Coming – AMBCrypto

[2] OJK Beyond Infinity Edisi 2 – Tokenisasi Real World Assets (RWA)

[3] Coinfest Asia 2026 highlights Indonesia’s digital asset ambitions in finance, investment – Quick Dispatch – The Jakarta Post

[4] OJK Buka Peluang Pemberian SID untuk Investor Kripto | tempo.co

Currently, business activities relating to blockchain technology generally continue to refer to Government Regulation No. 28 of 2025 concerning the Organization of Risk Based Business Licensing (“GR No. 28/2025”).  Until the issuance of this article, the government has not issued any further implementing regulations with respect to blockchain technology in Indonesia. Under GR No. 28/2025, blockchain technology development activities are classified under KBLI 2020 No. 62014 (Blockchain Technology Development Activities). To carry out such business activities, business actors are generally required to fulfil two basic requirements, namely: (i) a Business Identification Number (“Nomor Induk Berusaha” or “NIB”) as the official identification of the business actor; and (ii) a Standard Certificate as evidence of compliance with the applicable business standards. Pursuant to Article 186 of GR No. 28/2025, such business activities fall under the Electronic System and Transaction Operations sector, which includes, among others, blockchain technology development activities, digital identity provision activities, and artificial intelligence based programming activities.

However, Indonesia has recently adjusted the classification of business activities through KBLI 2025, as established under BPS – Statistics Indonesia (“Badan Pusat Statistik” or “BPS”) Regulation No. 7 of 2025 concerning the Indonesian Standard Industrial Classification (“BPS Regulation No. 7/2025”). Under KBLI 2025, blockchain technology development activities, which were previously classified under KBLI 2020 No. 62014, are now classified under KBLI 2025 No. 62193 (Blockchain Technology Based Application Development Activities). Accordingly, the change in KBLI code should be taken into consideration in determining the appropriate classification of blockchain based business activities.

Nevertheless, as of the date hereof, certain sectoral regulations have yet to update their KBLI references to reflect KBLI 2025 as established under BPS Regulation No. 7/2025. Accordingly, in practice, certain provisions continue to refer to KBLI 2020, including the provisions under GR No. 28/2025. This condition should be taken into consideration by business actors when determining the applicable legal basis and classification of their business activities, particularly while the transition from KBLI 2020 to KBLI 2025 remains ongoing.

Despite the framework set out under GR No. 28/2025 and the BPS Regulation No. 7/2025, there is currently no specific and comprehensive regulatory framework governing all forms of blockchain technology utilization. This is partly attributable to the evolving nature of blockchain technology and its broad range of applications across various sectors. In the financial services sector, OJK provides a framework for the development and testing of technological innovations through OJK Regulation No. 3 of 2024 concerning the Implementation of Financial Sector Technological Innovation (“OJK Reg No. 3/2024”). One of the mechanisms provided under OJK Reg No. 3/2024 is the regulatory sandbox, which is intended to provide a controlled environment for the testing and development of technological innovations in the financial sector under OJK supervision. [1]

In simple terms, through the regulatory sandbox mechanism, participants are given an opportunity to test and develop technological innovations or products within a specific period and scope determined by OJK. Following the completion of the testing period, OJK will evaluate the results of the testing to determine the appropriate follow up measures in accordance with the applicable regulations. Through this mechanism, the development of blockchain-based innovations in the financial sector can be conducted within a controlled testing environment, while also allowing OJK to assess the risks and characteristics of such innovations before they are implemented more broadly.

[1] Article 6 OJK Reg No. 3/2024

The trading and the general crypto assets industry in Indonesia have been widespread in recent years. Discussions surrounding blockchain technology have therefore often been associated with crypto asset trading and investment activities. However, developments in Indonesia’s policies and technological innovation indicate that the utilization of blockchain is increasingly being viewed in a broader context, beyond crypto assets. This is reflected, among others, in the recognition of blockchain technology-based application development activities under KBLI 2025 No. 62193 (Blockchain Technology-Based Application Development Activities), as well as the availability of a regulatory sandbox mechanism under OJK Reg No. 3/2024. Through this framework, business actors have the opportunity to develop and test various blockchain based innovations, particularly in the financial services sector, while remaining subject to OJK supervision.

This development is also reflected in OJK’s publication, OJK Beyond Infinity Edition 6 – Accelerating Digital Economy, published in May 2026. In the publication, OJK identified several regulatory sandbox participants that had successfully completed the testing process for tokenization-based products, namely: (i) PT Indonesia Blockchain Persada through Gold Indonesia Republic (GIDR) as the issuer of gold tokenization; (ii) PT Sejahtera Bersama Nano through ID Digital Bonds (IDDB) as the issuer of tokenized Indonesian Government Securities (“Surat Berharga Negara” or “SBN”) RI0234 under the KPD scheme; and (iii) PT Properti Gotong Royong through GORO as the issuer of tokenized property ownership benefits. These developments indicate that the application of blockchain in Indonesia is increasingly being directed toward use cases that represent RWA and economic rights, including gold, government securities, and property ownership benefits.

In addition to asset tokenization, OJK has also identified the potential utilization of blockchain technology in the development of Islamic fintech in Indonesia. Technologies such as asset tokenization and smart contracts may be developed and combined with the principles of maqashid al-sharia, including transparency, fairness, trustworthiness, and risk sharing. This approach may serve as one of the foundations for developing more measurable digital financial products that are aligned with the characteristics of Islamic finance. [1]

Accordingly, the development of blockchain in Indonesia is no longer solely associated with crypto asset trading, but is increasingly evolving toward the utilization of blockchain technology as infrastructure to facilitate broader access to various financial products and real-world assets.

[1] OJK Beyond Infinity Edisi 6 – Accelerating Digital Economy – Page 25

Indonesia, through Bank Indonesia (“BI”), is currently developing a Central Bank Digital Currency (“CBDC”) known as the Digital Rupiah under “Project Garuda”. Project Garuda is a strategic initiative of BI to develop the Digital Rupiah as a form of digital currency issued by the central bank and as part of Indonesia’s broader payment system development.

Based on the Indonesia Payment System Blueprint 2030 (“Blueprint Sistem Pembayaran Indonesia 2030” or “BSPI 2030”), the future development of the Digital Rupiah will focus on further experimentation, including the replication of wholesale market functions and the deepening of financial markets.[1] Accordingly, the development of the Digital Rupiah is not limited to creating a digital form of the Rupiah, but also seeks to explore its potential use in transactions and financial market infrastructure.

In its implementation, the Digital Rupiah is divided into two forms: (i) w-Digital Rupiah, which is intended for wholesale purposes; and (ii) r-Digital Rupiah, which is intended for retail purposes. BSPI 2030 further divides the development of the Digital Rupiah into three stages. The first stage, immediate, focuses on the use of w-Digital Rupiah to support the issuance, destruction, and transfer of funds between parties. The second stage, intermediate, expands the use of w-Digital Rupiah to support transactions and activities in financial markets. Meanwhile, the end state stage represents the final stage, which is directed toward testing the concept of end-to-end integration between w-Digital Rupiah and r-Digital Rupiah. [2]

In 2024, BI completed the development of the first or immediate stage. The subsequent development has entered the intermediate stage, which includes the development of a securities ledger. The experimentation at this stage is planned to be carried out in three sequences. First, BI will develop and test the design for the issuance, transfer, and destruction of digital securities, covering securities issued in the form of native tokens as well as informational tokens. Second, the functionality of such digital securities will be expanded to support monetary operations and financial market transactions, particularly in the Rupiah money market. Third, the development will focus on utilizing programmability, composability, and tokenization features, taking into account the results obtained from the experimentation conducted in the preceding sequences.[3]

This development forms part of the stages planned under Project Garuda through BSPI 2030. Through this phased approach, BI is not only testing the technical aspects of the Digital Rupiah, but also exploring how digital technologies, including Distributed Ledger Technology (“DLT”), may be applied to financial market infrastructure and support the deepening of Indonesia’s financial markets.

[1] Blueprint Sistem Pembayaran Indonesia 2030 Page 67-70

[2] Blueprint Sistem Pembayaran Indonesia 2030 Page 67-70

[3] Blueprint Sistem Pembayaran Indonesia 2030 Page 67-70

In Indonesia, crypto assets are currently recognized as tradable commodities rather than currency, and their use is subject to a specific regulatory framework. Crypto assets are defined as digital representations of value that may be stored and transferred through technologies that enable the use of distributed ledgers, such as blockchain. In practice, crypto assets are primarily used as an investment instrument, as they are not permitted to be used as a means of payment.

Following the enactment of the Financial Sector Development and Strengthening Law (“Undang-Undang Pengembangan dan Penguatan Sektor Keuangan” / “UU P2SK”) in 2025, the supervisory authority on crypto assets has shifted from Bappebti as part of the futures commodity exchange to OJK. Since then, OJK has issued OJK Reg No. 27/2024 and all crypto business actors, such as exchanges, depository managers, and traders are required to obtain a license from OJK and comply with detailed rules regarding trading mechanisms, asset storage, risk management, and consumer protection. The regulation sets out detailed provisions on crypto asset sales mechanisms, as well as the obligations of exchanges, marketplace operators, and other relevant stakeholders, including requirements for secure asset storage. Through this framework, OJK emphasizes transparency, prudence, and consumer protection by requiring crypto asset service providers to establish clear operational standards, implement effective risk management practices, and provide adequate public education.

Unlike other jurisdictions, Indonesia does not recognize Virtual Asset Service Provider (“VASP”) License which generally provides companies to legally provide services relating to virtual assets. Instead, under OJK Reg No. 27/2024, business actors in the field of digital financial assets, such as crypto may acquire a license, specific for its business activity in the field of digital financial assets, such as (among others) exchanges, depository managers, and traders. This framework limits the line of business of digital financial business actors to only conduct certain type of scope / activities as provided under OJK Reg No. 27/2024.

On 31 October 2025, OJK enacted OJK Regulation No. 23 of 2025 concerning Amendment to OJK Reg No. 27/2024 (“OJK Reg No. 23/2025“), effective 10 November 2025, which expands the regulatory scope beyond crypto assets to cover “other digital financial assets,” expressly including derivatives of digital financial assets. Under this amendment, licensed exchanges may facilitate derivatives trading subject to OJK’s prior approval, while clearing and guarantee institutions and traders need only notify OJK before commencing such activities, subject to a new ongoing requirement to maintain equity of at least 80% of paid-up capital. Parties that have been facilitating digital asset derivatives trading without an OJK trader license must transfer such activities to a licensed trader by 9 January 2026.

Meanwhile, Decentralized Finance (“DeFi”) has not yet been specifically regulated in Indonesia. DeFi activities outside licensed platforms continue to operate without clear regulatory oversight. Nevertheless, crypto-related services that fall within the scope of financial services, including payment providers and digital transaction facilitators, remain subject to licensing requirements and supervision by OJK and the Bank Indonesia.

As of September 2026, there have been no updates to the Anti-Money Laundering (“AML”) and sanctions regulations applicable to crypto assets and DeFi in Indonesia. The obligations on the implementation of AML measures through AML and Counter-Terrorism Financing (“CTF”) programs, are regulated under the OJK Reg No. 27/2024 as amended by OJK Reg No. 23/2025 which are also integrated into the national AML framework. This means that, in addition to complying with OJK provisions, crypto traders and other stakeholders are also required to adhere to Indonesia’s AML regulations.

Additionally, the use of cryptocurrency as a means of payment in Indonesia is strictly prohibited, as only the Indonesian Rupiah is recognized as legal tender.[1] Consequently, merchants or service providers that accept payments in cryptocurrency may be subject to sanctions ranging from administrative fines and revocation of business licenses to the termination of operations. This policy has been implemented to safeguard the stability of the national financial system, ensuring the effectiveness of Indonesia’s payment infrastructure, and preventing money laundering activities utilizing crypto assets.

A concrete example of AML and CTF provision set under OJK Reg No. 27/2024 stipulate that depository managers must refuse to store Digital Financial Assets (“DFA”) originating from suspicious sources or Crypto Assets that are not included in the Crypto Asset List[2] and that DFA Trading Organizers are required to report any suspicious financial transaction to the Head of the Financial Transaction and analysis Reporting Center.[3]

[1] Article 21 (1) in conjunction with Article 33 (1) Law Number 7 of 2011 on Currency as amended by Law Number 4 of 2026

[2] Article 112 (1) OJK Reg No. 27/2024

[3] Article 40 Paragraph (2) (b) OJK Reg No. 27/2024

The Government of Indonesia imposes taxation on cryptocurrency transactions in accordance with the general tax framework. As of September 2026, taxation on cryptocurrency transactions remains subject to Minister of Finance Regulation No. 50 of 2025 concerning Value Added Tax (“VAT”) and Income Tax (“PPh”) on Crypto Asset Trading Transactions (“MoF No. 50/2025”). Under MoF No. 50/2025, crypto assets are classified as securities or digital financial assets and, accordingly, effective as of 1 August 2025, are no longer subject to VAT. However, crypto trading activities remain subject to final PPh Article 22 at a rate of 0.21% of the transaction value, increased from the previous rate of 0.20%

Furthermore, offshore Electronic System Trading Operators (“Penyelenggara Perdagangan Melalui Sistem Elektronik” or  “PMSE”), are not automatically required to withhold PPh Article 22. This obligation applies only to PMSE operators that have been specifically designated as tax collectors by the Directorate General of Taxes (“DJP”). To be designated, a PMSE operator must meet certain criteria, which may include the value of transactions with Indonesian buyers and the number of visitors or volume of traffic over a 12 month period. The specific thresholds for these criteria will be determined by the Minister of Finance.[1]

The sale of crypto assets through offshore platforms is subject to a final PPh of 1%, which is withheld directly by the Traders through the electronic system / application in which they developed.[2] Furthermore, starting in 2026, income derived from crypto mining activities will also be subject to Income Tax in accordance with the general tax provisions.[3]

Meanwhile, specific provisions governing individual income tax on capital gains from crypto assets have not yet been regulated. In general, such gains are considered taxable income and must be reported in the Annual Income Tax Return. Accordingly, crypto industry participants remain required to report their income in compliance with the applicable Indonesian tax regulations.

[1] Article 18 MoF No. 50/2025

[2] Article 22 (1) MoF No. 50 / 2025

[3] Article 27 MoF No.  50/2025

In Indonesia, retail and wholesale tokenization projects are generally discussed in the context of RWA tokenization. Its implementation, however, has not yet been widely adopted. Nevertheless, OJK has highlighted the potential development of RWA tokenization through its Beyond Infinity Second Edition – June 2025 publication on RWA Tokenization. In the publication, OJK identified the potential for Indonesia to develop RWA tokenization, given the country’s diverse range of resources and physical assets, including land, natural resources, and property. At the same time, public access to various types of such assets, particularly as investment instruments, remains relatively limited. In this context, RWA tokenization may serve as one mechanism to broaden public access to assets or economic rights that were previously more difficult to access.

One of the sectors highlighted in the discussion of RWA tokenization is the energy transition sector. RWA tokenization essentially involves representing physical assets or the economic rights associated with such assets in the form of digital tokens. Through this mechanism, assets or economic interests relating to physical projects, such as solar panels, wind turbines, or micro hydropower plants, may be represented in the form of tokens and subsequently developed as digital instruments.

The energy transition sector is considered to have potential for development through RWA tokenization, taking into account Indonesia’s geographical characteristics as an archipelagic country with a tropical climate. These conditions provide opportunities for the development of various renewable energy sources across different regions of Indonesia. The use of tokenization in this sector may ultimately support Indonesia’s energy transition and sustainable development agenda, including its commitment to achieving net zero emissions by 2060.

In line with these developments, as of June 2026, OJK is known to be preparing regulations concerning the issuance and implementation of RWA tokenization. At that time, the regulations were still under development, and OJK targeted the issuance of regulations concerning RWA tokenization no later than the third quarter of 2026. [1] This development indicates that the regulatory framework for RWA tokenization remains under development, and broader implementation will therefore continue to depend on the policies and regulations to be established by OJK.

Meanwhile, the implementation of tokenization has begun to be tested through OJK’s regulatory sandbox mechanism. In OJK’s Beyond Infinity Edition 6 – Accelerating Digital Economy, published in May 2026, OJK identified several participants that had successfully completed the sandbox process in relation to the issuance of tokenization-based products, namely: (i) PT Indonesia Blockchain Persada through Gold Indonesia Republic (GIDR) as the issuer of gold tokenization; (ii) PT Sejahtera Bersama Nano through ID Digital Bonds (IDDB) as the issuer of tokenized Indonesian Government Securities RI0234 under the KPD scheme; and (iii) PT Properti Gotong Royong through GORO as the issuer of tokenized property ownership benefits. These developments indicate that, although the broader implementation of RWA tokenization continues to face regulatory and infrastructure-related challenges, certain forms of tokenization have already begun to be tested within OJK’s regulatory sandbox environment.

[1] OJK Targetkan Aturan Tokenisasi Aset Nyata Terbit pada Kuartal III-2026

As of the date of this article, crypto asset trading has become part of Indonesia’s digital asset activities, and, in principle, there is no prohibition on Indonesian citizens purchasing, selling, or holding crypto assets. The Government has instead established a regulatory framework for crypto asset trading through trading mechanisms conducted on futures exchanges that are duly licensed in accordance with the applicable regulations. Nevertheless, crypto assets may not be used as legal tender in Indonesia. BI has affirmed that crypto assets do not constitute currency or legal tender and therefore may not be used to make payments for goods and/or services.

Furthermore, crypto asset trading activities are currently subject to a more specific regulatory framework under OJK Reg No. 27/2024. This regulatory development was subsequently followed by the publication of the draft OJK regulation concerning the offering of digital financial assets on 19 September 2025, namely the Draft OJK Regulation on the Offering of Digital Financial Assets (the “Draft OJK Regulation on the Offering of DFA”).[1]

The Draft OJK Regulation on the Offering of DFA is intended to ensure that the offering, distribution, and trading of digital assets in Indonesia are conducted in an orderly, fair, transparent, and efficient manner. [2] To achieve these objectives, providers are required to implement sound governance principles, provide consumer protection, implement risk management measures, and maintain system and cybersecurity. The framework also covers compliance with provisions concerning the prevention and eradication of money laundering and the prevention of terrorism financing. [3] The scope of the draft regulation extends beyond Crypto Assets to include tokenized DFA. Accordingly, the regulatory framework being developed by OJK reflects an effort to establish a more comprehensive framework for various forms of digital assets, including assets utilizing tokenization technology. This approach also allows activities within the digital asset ecosystem to be conducted under more structured and accountable operational standards.

These developments indicate that the Indonesian Government has not adopted an approach that generally prohibits the existence or trading of crypto assets. Instead, the Government has established a regulatory framework that allows digital asset activities to be conducted within a supervised environment, while maintaining clear limitations, particularly with respect to the use of crypto assets as a means of payment. The development from a regulatory framework focused on crypto-asset trading toward a framework that also covers the offering of digital financial assets and tokenized assets further demonstrates the expanding scope of regulatory oversight over the development of Indonesia’s digital asset ecosystem.

[1] Penawaran Aset Keuangan Digital

[2] Article 2 Draft OJK Regulation on the Offering of DFA

[3] Ibid.

Regulation on the Offering of DFA, which, among other matters, regulates the offering in Indonesia. Under the Draft OJK Regulation on the Offering of DFA, an asset to be offered in the DFA Market must satisfy several criteria, including the use of DLT or other digital technology, not being a financial asset that has already been electronically recorded with a financial services institution, and not originating from activities that are contrary to applicable laws and regulations. [1]

The Draft OJK Regulation on the Offering of DFA also distinguishes offerings based on the scope of the parties targeted by the offering. An activity is categorized as a public offering if it is conducted within the territory of Indonesia, uses mass media, or is addressed to more than 100 parties. [2] Through this scope, OJK has a basis for supervising offering activities that may reach a broad segment of the public, while also establishing requirements relating to disclosure, consumer protection, and risk mitigation.

Among others, in the Draft OJK Regulation on the Offering of DFA  , from a licensing perspective, an issuer intending to conduct a public offering of Tokenized Assets or Backed Crypto Assets with an offering value of at least Rp1,000,000,000 is required to obtain a business license from OJK. Meanwhile, for offerings below such threshold, the issuer is generally only required to submit a notification to OJK prior to conducting the offering. However, where an offering is conducted in stages and the cumulative offering value within one year reaches Rp1,000,000,000, the obligation to obtain a business license will still apply. [3] Specifically for Unbacked Crypto Assets, each public offering must first obtain approval from the Exchange, regardless of the offering value, thereby introducing an additional review mechanism before such assets are offered to investors.

Overall, the provisions of the Draft OJK Regulation on the Offering of DFA indicate that OJK’s approach to digital asset offerings is directed toward establishing a more structured framework based on the characteristics of each type of asset. This is reflected in the distinction between Tokenized Assets, Backed Crypto Assets, and Unbacked Crypto Assets, including differences in licensing requirements, offering mechanisms, Reserve Asset requirements, and the involvement of the Exchange. Accordingly, if the Draft OJK Regulation is enacted, business actors intending to offer digital assets in Indonesia will need to consider not only the issuance and trading aspects of such assets, but also the asset structure, offering value, asset characteristics, and the accompanying governance and disclosure obligations.

To date, there is no clarity yet on when this Draft OJK Regulation will be enacted into a regulation.

[1] Article 3 Draft OJK Regulation on the Offering of DFA

[2] Ibid.

[3] Article 6 in conjunction with Article 8 Draft OJK Regulation on the Offering of DFA

The transfer of title to crypto assets in Indonesia is regulated under their classification as DFA under the OJK regulatory framework, following their transition from their previous classification as “commodities”. This regulatory shift was introduced through OJK Reg No. 27/2024 and has since been amended by OJK Reg No. 23/2025, which imposes a more comprehensive regulatory framework for crypto asset trading. Under the current framework, crypto assets are required to be issued, stored, transferred, and/or traded using distributed ledger technology, such as blockchain or equivalent systems.

A central element of title transfer, particularly in trading crypto assets, is the strict traceability requirement under OJK Reg No. 27/2024, which prohibits crypto assets from incorporating features that conceal ownership or transaction information.[1] This provision strengthens regulatory supervision and secures clear ownership chains on the blockchain systems. In addition, OJK Reg No. 27/2024 enforces the “Travel Rule” for crypto asset transfers:[2]

(i)   transactions of USD 1,000 (or equal value in Rupiah) or more must include complete sender and recipient information, including the name, address, and wallet address of the sender and recipient; and

(ii)   transactions below USD 1,000 (or equal value in Rupiah) require more basic details, such as the name and wallet address of the sender and recipient.

Trading platforms are prohibited from processing transfers that fail to meet these Travel Rule standards. These measures ensure that transfers of title remain transparent and traceable in line with AML / CTF objectives.[3]

With respect to the granting of security over crypto assets, as of September 2026, there is currently no specific regulation or legislation governing such matters. By applying the fundamental principle of law, cryptocurrency assets can be classified as intangible goods and, consequently, may be subject to pledge or fiduciary assignment. However, in practice, the creation of security interests over crypto assets is not generally accepted, primarily due to the lack of clear legal framework and also practical difficulties in executing and the technicalities on the enforcement and execution of crypto assets. For example, if a debtor were to provide pledge over a crypto asset, then there should be proper mechanisms under the crypto wallet / platform to either block or restrict the debtor’s ability to transfer or dispose the pledged asset, thereby preserving the creditor’s interest. In the absence of such mechanisms, creditors are facing significant risks in ensuring that the pledged assets remain intact and available for enforcement.

Consequently, to the conditions above, while contractual arrangements may be drafted to simulate security interests, such actions remain subject to substantial legal and practical uncertainties. Until authorities introduce a concrete legal framework and guidelines, the enforceability of security over crypto assets in Indonesia will remain limited and largely untested. In the context of the fiduciary assignment, it remains uncertain whether the fiduciary office is authorized to accept the registration of cryptocurrency assets as a fiduciary object.

[1] Article 8 (1) (d) OJK Reg No. 27/2024

[2] Article 96 OJK Reg No. 27/2024

[3] Article 96 (2) OJK Reg No. 27/2024

As of the date of this article, Indonesia does not yet have specific regulations governing smart contracts. Under the existing legal framework, smart contracts may generally be understood in the context of contracts that are entered into and/or performed electronically. Accordingly, their validity and enforceability remain subject to the general provisions governing agreements and electronic transactions. In principle, smart contracts are therefore subject to Article 1320 of the Indonesian Civil Code (the “Civil Code”), as well as the provisions of Law No. 11 of 2008 concerning Electronic Information and Transactions, as amended most recently by Law No. 1 of 2024 (the “ITE Law”), together with its implementing regulations, including Government Regulation No. 71 of 2019 concerning the Implementation of Electronic Systems and Transactions (“GR No. 71/2019”).

In the context of electronic transactions, the ITE Law recognizes electronic information, electronic documents, and electronic contracts as part of the legal framework governing electronic transactions in Indonesia. Article 1 point 17 of the ITE Law defines an electronic contract as an agreement between parties entered into through an Electronic System. Furthermore, Article 6 of the ITE Law generally recognizes electronic information and/or electronic documents as valid evidence, provided that such information is accessible, displayable, its integrity is assured, and it can be accounted for so as to explain a particular circumstance. Accordingly, a smart contract created and executed through blockchain technology may, in principle, receive legal recognition, provided that it satisfies the requirements applicable to electronic contracts and transactions.

From an Indonesian contract law perspective, the validity of a smart contract must also be assessed based on Article 1320 of the Civil Code, which requires the existence of the parties’ consent, the parties legal capacity to enter into an agreement, a specific subject matter, and a lawful cause. The use of code or an automated execution mechanism in a smart contract does not, in itself, dispense with these requirements. Accordingly, the relevant considerations extend beyond how the smart contract is programmed and technically executed and also include whether the legal relationship between the parties and the underlying agreement can be clearly established and evidenced.

Although the existing legal framework may provide a basis for assessing smart contracts, their application continues to raise a number of issues that have not been specifically addressed under Indonesian laws and regulations. These include, among others, differences in jurisdiction in cross-border transactions, potential discrepancies between the programming language and the parties’ intended agreement, and the risk of coding errors that may cause a transaction to be executed in a manner inconsistent with the parties’ intentions. In addition, to date, there is no Indonesian jurisprudence that specifically provides an interpretation of smart contracts.

Accordingly, although Indonesia does not yet have specific regulations governing smart contracts, the existing legal framework concerning agreements and electronic transactions may nevertheless provide a basis for assessing their validity and enforceability in Indonesia.

Currently, Indonesia does not have specific provisions recognizing a Decentralized Autonomous Organization (“DAO”) as a legal entity or an independent legal entity. Unlike business or organizational forms recognized under the Indonesian legal system, such as limited liability companies, cooperatives, foundations, or associations, a DAO does not yet have a legal status that is specifically regulated under Indonesian laws and regulations. Accordingly, the legal status of a DAO under the Indonesian legal framework remains subject to regulatory uncertainty.

As a DAO does not have the status of a legal entity or other specifically recognized legal entity, it cannot, in itself, generally be treated as a legal subject equivalent to a limited liability company or other recognized legal entity. Accordingly, where activities conducted by a DAO require legal acts or relationships with third parties, such as entering into agreements, holding assets, conducting business activities, or obtaining certain licenses, consideration should be given to using a legal entity recognized under Indonesian law as the vehicle through which such activities are carried out.

In this context, DAO related activities may be conducted through available legal entity structures, depending on the nature and objectives of the activities, including a company, foundation, or association. However, the use of a legal entity does not, by itself, transform the DAO into a legal entity. Rather, such structure serves as a means of providing a legal basis for the activities undertaken and establishing a party that can clearly act, hold rights and obligations, and assume responsibility toward third parties.

In Indonesia, law enforcement and regulatory measures relating to blockchain have thus far been primarily directed at the misuse of crypto assets for illicit financial activities, rather than the blockchain technology itself.

This demonstrates the law enforcement authorities’ commitment to prevent and combat financial crimes perpetrated through the use of digital assets. The focus lies in preventing AML and the CTF practices, with the Financial Transaction Reports and Analysis Center (“Pusat Pelaporan dan Analisis Transaksi Keuangan” / “PPATK”) actively monitoring, and investigating suspicious transactions involving crypto assets. The inherent anonymity of most crypto assets renders the process of identifying perpetrators and seizing assets significantly more challenging for the authorities.

Furthermore, several high-profile cases have illustrated how crypto assets have been used in illicit practices. One such example is the June 2026 corruption case within Indonesia’s Ministry of Immigration and Correctional Affairs, which implicated the an Ex-Vice Minister , along with several other immigration officials. The Corruption Eradication Commission (“Komisi Pemberantas Korupsi” or “KPK”) named eight suspects in connection with alleged extortion and gratification in the processing of residence permits for foreign nationals, with the total proceeds of the alleged extortion estimated at approximately Rp145,500,000,000 (one hundred and forty-five billion five hundred million Rupiah). Among the assets seized by the KPK as evidence are valued at a combined total of approximately Rp17,500,000,000 (seventeen billion five hundred million Rupiah), consisting of four crypto asset accounts worth Rp1,200,000,000 (one billion two hundred million Rupiah), which the KPK suspected had been purchased using funds derived from the alleged extortion proceeds.[1]

Furthermore, Indonesia’s Attorney General has also issued a guideline under Attorney General’s Guideline No. 7 of 2023 concerning the Handling of Crypto Assets as Evidence in Criminal Cases (“Attorney General’s Guideline No. 7/2023”). This general guideline act as a guideline for prosecutors to handle and store evidence in the form of Crypto Assets in criminal cases, which demonstrate the Attorney General’s office attempt to adapt and to prevent such criminal method of digital assets.

[1] https://nasional.kompas.com/read/2026/06/04/19345661/kpk-barang-bukti-kasus-silmy-karim-dkk-nilainya-capai-rp-175-m

Lack of specific implementing regulations in general may be one of the hurdles in growing and operating blockchain activities in Indonesia. Despite this, the regulations under the Indonesian Personal Data Protection Law (“PDP Law”) may also conflicting with the operations of blockchain activities. The characteristics of blockchain technology, which allow data to be recorded permanently and may make such data difficult to modify, may also raise specific considerations regarding the correction, deletion, and management of personal data recorded on a blockchain.

Accordingly, the use of blockchain technology is not, in principle, prohibited in Indonesia. However, legal and regulatory compliance cannot be assessed solely based on the classification of the business activity or the use of blockchain technology itself. The assessment should instead consider the purpose and form of the blockchain application, the nature of the activities being conducted, and the characteristics of the assets or data recorded and processed through the blockchain. Based on this approach, the relevant sector-specific regulations, licensing requirements, and other applicable compliance obligations can be identified and assessed in relation to the relevant activities.

It cannot be overlooked that crypto assets, as one form of the utilization of blockchain technology, may also be exposed to risks of misuse in connection with various criminal activities. In practice, crypto assets may be used in transactions relating to, among others, money laundering and embezzlement. The characteristics of crypto assets, which allow assets to be transferred rapidly through digital networks and across jurisdictions, are also relevant considerations from a law enforcement and risk mitigation perspective.

In this context, Indonesia has begun to establish a legal basis for the handling of crypto assets in criminal proceedings through the Attorney General’s Guideline No. 7/2023. The guideline recognizes crypto assets as evidence that may be handled in criminal proceedings and provides guidance on the mechanisms for their handling. Furthermore, Chapter III – Handling of the Attorney General’s Guideline No. 7/2023 provides that the handling of crypto assets may be carried out through several measures, including: (a) establishing a Controlled Cryptowallet; (b) blocking; (c) transferring; and (d) converting or not converting the crypto assets. These provisions demonstrate that crypto assets are not viewed solely from the perspective of technology or transactional instruments, but have also become an object that must be taken into consideration in law enforcement proceedings.

Accordingly, parties conducting or intending to conduct activities involving crypto assets or blockchain technology should consider compliance and oversight requirements from the outset. In addition to ensuring that such activities comply with the applicable sector specific regulations, appropriate measures should be implemented to identify and mitigate potential misuse of crypto assets, including risks relating to money laundering, embezzlement, and other criminal activities.

Nevertheless, the application of blockchain technology does not only involve technological considerations or regulations that directly govern blockchain.

In practice, a blockchain based activity may also fall within the scope of various other sector specific regulations, depending on the nature of the activity, the data being processed, and the function for which the blockchain is used, including: (i) Personal Data Protection, particularly where the implementation of blockchain involves the collection, processing, storage, or use of individuals personal data; (ii) Prevention and Eradication of AML-CTF, particularly where blockchain technology is used in activities relating to financial systems or digital asset transactions; (iii) Electronic System and Electronic Transaction Administration, given that various blockchain applications may satisfy the characteristics of an electronic system or involve the conduct of transactions electronically; and (iv) Financial Services and Capital Markets, particularly where blockchain technology is utilized for the issuance, trading, or management of digital assets or other financial instruments. In such circumstances, the relevant activities may fall within the regulatory and supervisory scope of the competent authorities, including OJK, depending on the characteristics of the products and activities involved.

Furthermore, noting the absence of specific regulations relating to blockchain technology, it is also possible that a blockchain business may fall into the Financial Sector Technological Innovation legal framework (ITSK), which acts as the umbrella legal framework for new innovations and unregulated business in the financial technology sector. The ITSK legal framework enables novel unregulated business activities to operate under a “regulatory sandbox” scheme.

Accordingly, the use of blockchain technology should not be assessed solely based on whether specific regulations governing blockchain technology exist. The legal assessment should instead consider the purpose for which the blockchain is used and the activities conducted through such technology, as a single blockchain application may give rise to obligations under several different regulatory regimes simultaneously.