Fintech 2025

INDONESIA Law and Practice Contributed by: Emir Nurmansyah, Monic N. Devina, D. Meitiara P. Bakrie and Ruth A. Mendrofa, ABNR Counsellors at Law

OJK, while futures commodities (including digital gold) fall under the supervision of Bappebti . The BI supervises the use of trading platforms within money and foreign exchange markets. 6.3 Impact of the Emergence of Cryptocurrency Exchanges Virtual currencies (including cryptocurrencies) are not recognised as a legitimate payment instrument in Indonesia. However, the increase in popularity of cryptocurrencies in Indonesia has pushed the Indonesian government to issue a legal framework for cryptocurrencies in the Indonesian market. Cryptocurrencies in Indonesia are recognised as crypto-assets that can only be traded as digi - tal financial assets at a crypto-assets futures exchange approved by the OJK. Trading can also be done through a crypto-asset traders’ platform connected with a digital financial assets exchange platform. Key players involved in cryp - to-assets transactions are: • exchanges; • clearing agencies; • traders; • depository agencies for crypto-assets; • facilitator of supporting activities in the digital financial assets market; and • FSTI organisers. All of these need to be licensed by the OJK. Tradable crypto-assets are only those regis - tered in the crypto-asset list issued by the digital financial asset exchanges and such list must be evaluated by the OJK. OJK Reg, 27 states that the crypto-asset list issued by Bappebti remains valid until a new list is issued by the exchange, which must be done within three months from the effective date of OJK Reg, 27. Currently, the

list is stipulated in Bappebti Regulation No. 11 of 2022 as lastly amended by Bappebti Regulation No. 4 of 2023 and Bappebti Regulation No. 1 of 2025 (the “Bappebti List of 2025” ). Under the Bappebti List of 2025, Bappebti has increased the number of types of crypto-assets that could be traded in the exchange from 545 to 1,396. These include: • SushiSwap (SUSHI); • PancakeSwap (CAKE); • AAVE; • Internet Computer (ICP); • Axie, Infinity (AXS); • Ethereum Name Service (ENS); • TROY; • Reef; • 1inch Network; • dYdX; • THORchain (RUNE); • The Graph (GRT); • Apecoin (APE); • Anchor Protocol (ANC); and • Secret (SCRT). See 10. Blockchain for more detail on the criteria for crypto-assets. 6.4 Listing Standards In Indonesia, listing standards are relevant for products in the capital markets sector, which includes stocks and bonds. The listing must fol - low the rules of the Indonesian Stock Exchange (IDX). There are currently three listing boards on the IDX: the main, development and accelera - tion boards. The main and development boards are desig - nated for companies that have already started operations within a certain period and have a certain level of assets. For example, to list its stocks on the main board a company must have

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