Digital asset regulation and tokenization in Indonesia

In Indonesia, trading digital assets and using them to process payments belong to different frameworks. Financial regulator OJK supervises trading following the transfer from Bappebti, while Bank Indonesia retains responsibility for payments. A business must separate these functions even when they appear in the same application.

Tokenizing an asset adds another distinction: trading permission or supervised testing does not itself settle a new offering’s conditions. This guide explains how to allocate exchange, custody and settlement functions, document rights and distinguish current rules from issuance proposals.

What changed with the transfer to OJK

The transfer of supervision from Bappebti to OJK was formalised on 10 January 2025 under Law 4/2023 and Regulation 49/2024. POJK 27/2024 governs trading in digital financial assets, including crypto-assets. Service classification determines the permission required; developing software and conducting financial operations for customers are not equivalent functions.

POJK 23/2025, effective from 10 November 2025, expands categories, functions and digital asset derivatives rules. It also amends systems, reporting and customer-fund controls. Its adoption does not allow any provider to add derivatives or primary issuance without checking product conditions and its authorisation.

How trading differs from payment services

OJK oversees the trading ecosystem, with distinct exchange, clearing and settlement, storage and trader functions. Its May 2026 communication maintains that separation. Contracts and operational design must identify which entity performs each function, holds assets and bears responsibilities towards customers.

Bank Indonesia retains payment system responsibilities. Regulation 10/2025, effective from 31 March 2026, governs providers and infrastructure while preserving compatible earlier provisions. Article 119 prohibits accepting or using virtual currency as a source of funds for payment processing, or linking it to that processing, within its scope.

How applications, testing and authorisation relate

The OJK procedure requires identifying the subsector and applying through SPRINT, with activation and payment through designated systems. Applicants must demonstrate institutional, capital, personnel, procedural and technology requirements for the category. Corporate registration or a foreign licence does not replace local permission for a regulated function.

For innovations within the sandbox, OJK distinguishes testing, graduation, registration and licensing. Its February 2026 communication identifies tokenization models that passed testing and could proceed to subsequent applications. Graduation does not establish unrestricted permission for other assets, issuers or customers, or authorisation transferable to third parties.

What needs resolution before a tokenized offering

In April 2026 OJK described a specific tokenized asset offering proposal, addressing eligible assets, authorisation, protection and reporting. That announcement does not itself establish final rules. Trading permission and testing participation must not be treated as sufficient grounds for a new public token offering.

Structures must identify the issuer, reference asset, custody and enforceable right: a claim, an interest in a vehicle and a delivery entitlement are not interchangeable. OJK's tokenization precedents concern specific models. They do not establish a universal rule that transferring a token directly transfers land or removes corporate and registration formalities.

How to control money, assets and reporting

OJK clarifies that segregated customer accounts must be opened with OJK-licensed commercial banks under amended Article 87. Accounting segregation, key control and custody agreements must reflect actual asset flows. A segregated account must not be described as an automatic guarantee of full recovery following every incident or insolvency.

PADK 3/2026, adopted on 30 June with general commencement stated as 1 September 2026, develops asset assessment and periodic and incidental reporting. Its transitional arrangements preserve or replace specified provisions on different dates. Each reporting timetable must be checked rather than assuming every obligation changed upon adoption.

What to prepare before operating in Indonesia

Prepare a diagram separating dealing, custody, clearing, settlement and payments. Identify the entity responsible for each step and its intended OJK permission. For payments, specifically check Bank Indonesia restrictions: technical integration does not combine the authorisations.

For an offering, provide holder contracts and evidence of the underlying right. Confirm final offering rules and the project’s decision rather than relying solely on sandbox participation. Complete the design with customer accounts, key control and a reporting timetable under PADK 3/2026 and its transitional provisions.

To understand how this framework applies to your project, discuss your case with our team.