INDONESIA Trends and Developments Contributed by: Vik Tang, Michelle Virgiany, Almira Tengku, Ruth Ginting and Ryu Wirjadi, Hiswara Bunjamin & Tandjung in association with Herbert Smith Freehills Kramer
two directors and one commissioner. Members of the board of directors, board of commissioners, and controlling shareholders are classified as “main parties” ( pihak utama ) and are therefore subject to the OJK’s fit‑and‑proper test. • Operational and co-operation obligations: financial services aggregators are required to have formal co-operation arrangements with financial ser - vices institutions and/or other parties operating in the financial services sector. These co-operation arrangements must include electronic system con - nectivity with partners. • Notably, OJK Regulation 4 strictly prohibits finan - cial services’ aggregators from collecting funds from consumers, except where funds are merely forwarded to a licensed payment service provider partner as part of the transaction flow. This restric - tion reinforces the distinction between aggregation activities and regulated fund‑handling or intermedi - ary services. Existing financial services’ aggregators that are registered with the OJK must apply for a licence in accordance with OJK Regulation 4 by 21 February 2026. They must also comply with the new foreign ownership limit within one year after obtaining their licence from the OJK. The authors note that financial services’ aggrega - tion continues to play a critical role in enhancing the transparency and accessibility of financial products in Indonesia. As the OJK progressively transitions other mature ITSK business models into dedicated regulatory regimes, market participants can expect a continued shift to greater supervisory intensity and institutionalisation within the fintech sector. The OJK continues to operate regulatory sandboxes for a number of emerging business models, includ - ing digital identity solutions, crypto fund managers, stablecoins, and digital financial market infrastruc - ture. These initiatives indicate that the OJK is actively monitoring the development of new technology‑driven activities within the financial services sector. It will be interesting to see how the OJK responds as these business models mature, and whether they will transi- tion to dedicated ITSK regulatory regimes, in line with
the approach taken for ACS and financial services aggregators. Digital Assets Indonesia’s crypto market continues to exhibit deep mass-market penetration on a user-count basis. OJK- reported figures put registered crypto consumers at 19.56 million as of November 2025 – more than dou - ble the number of stock investors registered on the Indonesia Stock Exchange (IDX). Further, the value of crypto transactions reached IDR482.23 trillion in 2025, although month-to-month volatility remains a feature. Following the transition of oversight from Indonesia’s Commodity Futures Trading Supervisory Agency ( Badan Pengawas Perdagangan Berjangka Komoditi or Bappebti) to the OJK, the regulatory regime has evolved into a more comprehensive framework for digital assets more generally, not only for spot trad - ing of cryptocurrencies. In particular, OJK Regulation 23 of 2025 (amending OJK Regulation 27 of 2024) expressly expands the concept of “Financial Digital Assets” beyond crypto-assets to include other digital financial assets and digital financial asset derivatives. Platforms facilitating the trading of digital financial asset derivatives must comply with additional require - ments, including that customers should be aware of the risks, and the placement of margins. Importantly, the continuation of the white-list approach means that only digital financial derivatives that have been approved can be traded in Indonesia. Indonesia is also moving towards regulating the pri - mary market for digital financial assets. In Septem - ber 2025, the OJK released for public consultation a draft regulation on Public Offering of Digital Financial Assets. This signals its intent to build a licensed, dis - closure-driven onshore issuance ecosystem (including tokenised assets and certain crypto-asset offerings) rather than limiting supervision to secondary trading. Market players continue actively to explore stable - coin-use cases to support payment-related activities. Given the BI’s position on digital financial assets, and its prioritisation of sovereign digital currency projects such as Digital Rupiah under Project Garuda, there is still a separation between the payment systems under the BI’s regulatory purview and the digital financial
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