INDONESIA Trends and Developments Contributed by: Winnie Yamashita Rolindrawan, Bianca Putri Kadarisman and Qafaldi Putra Ismayudha, SSEK Law Firm
SSEK Law Firm Mayapada Tower I, 14th Floor Jl. Jend. Sudirman Kav. 28 Jakarta, 12920 Indonesia Tel: +62 21 2953 2000 +62 21 521 2038
Fax: +62 21 521 2039 Email: ssek@ssek.com Web: www.ssek.com
Introduction Indonesia’s digital asset sector continues to evolve at a rapid pace, driven by growing market participa- tion, sustained regulatory momentum, and increasing interest from both domestic and international players. Having established a foundational regulatory frame- work under OJK Regulation No 27 of 2024 regarding the Implementation of Digital Financial Asset Trad- ing, including Crypto Assets (OJK Reg 27/2024), the Financial Services Authority ( Otoritas Jasa Keuangan , or OJK) has moved swiftly to refine and strengthen that framework in response to market developments. The past year has seen notable regulatory activity, from amendments to the existing regime through to draft regulations addressing primary market activities. At the same time, newer financial models, such as prediction markets, are looking to enter the Indone- sian market, testing the boundaries of what Indone- sia’s regulatory regime can currently accommodate. This article examines the key legal and market devel- opments shaping Indonesia’s blockchain and crypto- asset landscape in 2026. Development of the Regime Under the OJK Following the enactment of OJK Reg 27/2024, which cemented the OJK’s authority as the central regulator of crypto-assets in Indonesia, the OJK has continued to actively develop and refine the regulatory regime. In January 2026, the OJK issued OJK Regulation No 23 of 2025 regarding the Amendment of OJK Regula- tion No 27 of 2024 (OJK Reg 27/2024, as amended), with the aim of strengthening the existing framework, enhancing legal certainty and providing more robust
investor protection in Indonesia’s growing digital asset market. The amendments address a range of matters, spanning market structure, licensing requirements, operational obligations and supervisory tools, reflect- ing the OJK’s intention to progressively mature the regulatory environment in line with market develop- ments. Recognition of digital financial asset derivatives One of the most consequential changes introduced by OJK Reg 27/2024, as amended is the formal rec- ognition of derivatives of digital financial assets as digital financial assets in their own right. This brings such instruments squarely within the OJK’s supervi- sory purview, resolving a gap in the prior applicable framework, which acknowledged crypto-asset deriva- tive products in practice but did not expressly regu- late them. Entities wishing to engage in the trading of digital financial asset derivatives are now subject to specific OJK approval requirements, providing greater legal certainty for market participants and reinforcing investor protection in this sector. Electronic System Provider (ESP) registration OJK Reg 27/2024, as amended, also introduces an explicit requirement for Digital Financial Asset Bourses, Clearing Institutions, Custodians and Digi- tal Financial Asset Traders (collectively, Digital Finan- cial Asset Trading Providers) to be registered as ESPs ( Penyelenggara Sistem Elektronik ). While these opera- tors have in practice provided their services through websites and applications, which are activities that would generally trigger ESP registration obligations, the requirement to be registered as an ESP was not
323 CHAMBERS.COM
Powered by FlippingBook