INDONESIA Law and Practice Contributed by: Emir Nurmansyah, Monic N. Devina, D. Meitiara P. Bakrie and Nesya Ashari, ABNR Counsellors at Law
10.9 Decentralised Finance (DeFi) Decentralised finance (DeFi) is not yet regulated in Indonesia. Nonetheless, some local players have tested the water, as follows. It should be noted that the following are still in their early stages and that the market is expected to evolve. • Litedex Protocol, a decentralised exchange (DEX), is a protocol that will serve as a meta finance blockchain developer for local players. The proto - col develops elements of DeFi, including staking, yield farming, swapping, liquidity pool and bor - rowing and lending, as well as non-fungible token (NFT) marketplace and bridge features. Litedex Protocol is also developing its native token, the LDX token. • Tokocrypto, the first registered crypto-asset trader (crypto-exchange), initiated a DeFi utility project through its platform token, Toko Token (TKO). The TKO ecosystem promotes some DeFi elements, such as borrowing and lending, and staking and savings. On another note, tokocrypto, and some other traders, also list native DeFi tokens available for trading purposes on their platforms. 10.10 Regulation of Funds Currently, funds investing in blockchain assets are not regulated, although, as per the prevailing regulation, only individuals are allowed to become crypto-asset customers trading in the Indonesian physical/spot crypto-assets market. 10.11 Virtual Currencies Virtual currencies and blockchain assets are treated differently, in that virtual currencies are prohibited from use as legitimate means of payment in Indonesia, except for the digital rupiah (see 10.2 Local Regu- lators’ Approach to Blockchain for further detail). According to Law 4/2023, in a move to keep up with the fast-changing crypto landscape, Indonesia has now paved the way for CBDC through a digital rupiah, which will be a form of legal tender and have effec - tively the same role as the fiat rupiah. In contrast, blockchain assets or crypto-assets are recognised as commodities that can be traded on the country’s crypto exchanges.
client-support division, as well as an accounting and finance division; • having sufficient online trading systems and facili - ties to facilitate the trade; • having certain trading rules and standard operating procedures based on minimum requirements set out by the regulations; • having at least one employee who is a certified information systems security professional; • having prospective members of the board of direc - tors, board of commissioners, shareholders, and/ or controllers who pass the fit-and-proper test conducted by the OJK; and • being registered as a private electronic system operator. 10.6 Staking Article 82 paragraph 4 of OJK Reg 27 acknowledges that the OJK may grant additional licences to licensed crypto-asset traders, including licences for staking services. However, such authorisations are contin - gent upon the trader entering into a co-operation agreement with the Ministry of Home Affairs to secure access rights and use population data in connection with the implementation of AML, CFT, and the Pre - vention of Proliferation of Weapons of Mass Destruc - tion Funding Programmes. Nevertheless, OJK Reg 27 does not yet provide specific details regarding the staking licence. 10.7 Crypto-Related Lending Crypto-related lending remains unregulated under the current regulatory frameworks. 10.8 Cryptocurrency Derivatives In December 2025, the OJK amended OJK Regulation No 27 of 2024 on the implementation of the Trading of Digital Financial Assets, Including Crypto-Assets (“OJK Reg 27”) through the issuance of OJK Regula - tion No 23 of 2025 (“OJK Reg 23/2025”). There have been several changes made to OJK Reg 27, particu - larly in relation to crypto derivatives. Previously, there had been no mention of derivatives of a digital asset. OJK Reg 23 clarified that digital assets now include not only crypto-assets, but also other digital financial assets and their derivatives.
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