INDONESIA Law and Practice Contributed by: Winnie Yamashita Rolindrawan, Bianca Putri Kadarisman and Qafaldi Putra Ismayudha, SSEK Law Firm
1. Overview of Blockchain and Crypto- Assets 1.1 Blockchain 1.1.1 Evolution of Uses of Blockchain Blockchain Use in Indonesia In Indonesia, the primary application of blockchain technology to date has centred on crypto-asset trad- ing. The existing regulatory framework for crypto- assets – principally Financial Services Authority ( Otori- tas Jasa Keuangan , or OJK) Regulation No 27 of 2024 regarding the Implementation of Digital Financial Asset Trading, including Crypto Assets (OJK Reg 27/2024) – focuses on the operation and supervision of trading- related activities conducted by licensed entities such as Digital Financial Asset Traders, Bourses, Clearing Institutions and Custodians (Digital Financial Asset Trading Providers). Over the past 12 months, the OJK has issued OJK Regulation No 23 of 2025 regarding the Amendment of OJK Regulation No 27 of 2024 (OJK Reg 27/2024, as amended), which introduces a number of key changes, including the formal recognition of digital financial asset derivatives, the Electronic System Provider (ESP) registration requirement, and revised obligations for Digital Financial Asset Trading Provid- ers, signalling the regulator’s continued and active development of the framework. However, OJK Reg 27/2024, as amended, does not specifically address broader uses of blockchain technology beyond this trading context. At the business registration level, Indonesia’s standard business classification system ( Klasifikasi Baku Lapan - gan Usaha Indonesia , or KBLI) recognises blockchain- related businesses, with KBLI No 62014 regarding Blockchain Technology Development Activities. This classification encompasses companies engaged in the development and implementation of blockchain technology, including smart contracts and the design of public and private blockchain infrastructure. How- ever, this recognition has not been accompanied by a specific licensing regime from the OJK or any other regulator for companies operating solely in the block- chain development space.
Looking ahead, the most significant issue likely to impact the use of blockchain in Indonesia over the next 12 months is the gap between the pace of inno- vation and the pace of regulation. Many business models that leverage blockchain innovation remain in a regulatory grey area, either unaddressed by exist- ing regulation or subject to uncertainty regarding their permissibility. This uncertainty affects how block- chain-based businesses structure their operations in Indonesia, and may deter some foreign players from The intersection of intellectual property law and blockchain in Indonesia remains largely unexplored in practice. Given that most blockchain-related activity in Indonesia is channelled through regulated crypto- asset trading rather than broader blockchain applica- tions, there has been limited occasion for intellectual property considerations to arise specifically in connec- tion with blockchain businesses. The general intellec- tual property framework applies to blockchain-related developments, but no blockchain-specific intellectual property rules or guidance have been issued. entering the market. Intellectual Property Indonesia provides a regulatory sandbox mechanism for financial innovations that fall outside existing regu- latory frameworks. The sandbox is administered by the OJK and is intended to allow financial technol- ogy innovations to be tested under OJK supervision before a formal regulatory regime is established. The mechanism is governed by OJK Circular Letter No 5/ SEOJK.07/2024 regarding Mechanism for the Testing and Development of Innovations dated 3 June 2024 (OJK CL 5/2024). To be eligible for the sandbox, an innovation must satisfy the following criteria: • the innovation falls within the scope of the financial services sector and is intended to be used by con- sumers, partners and/or the public in Indonesia; • the innovation demonstrates novelty and/or has significant distinguishing elements compared to existing activities in the financial sector; 1.1.2 Regulatory Sandbox OJK Regulatory Sandbox
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