INDONESIA Trends and Developments Contributed by: Vik Tang, Michelle Virgiany, Novita Wulandari and Fransiska Larasati, Hiswara Bunjamin & Tandjung
viders to engage the services of other parties in relation to non-critical electronic systems (eg, for testing the system capabilities and securing their data processing, helpdesk and consumer complaints services). • Credit score requirements: ACS Providers should produce credit scores using alterna - tive data (ie, data other than credit or financ - ing data) and are prohibited from using credit or financing data (ie, data concerning the state of the debtor’s or customer’s financing facility). The credit scores must satisfy the prescribed criteria, including being presented in the Indonesian language or, if required by customers, in bilingual format. Existing providers of innovative credit scoring services that are registered with OJK must apply for a licence in accordance with OJK Regulation 29 by 20 December 2025. They must also com - ply with the new foreign ownership limit within one year after obtaining their licences from OJK. The authors note that alternative credit scoring is playing an increasingly important role in growth and innovation in Indonesia’s financial services sector. This is evident in the increasing interest among market players and the added empha - sis placed by OJK on alternative credit scoring. The authors are therefore monitoring market and regulatory developments in this area closely. Digital Financial Assets: Crypto-Assets Last year, the Financial Services Omnibus Law mandated that supervision over digital financial assets – including crypto-assets – should be transferred from Bappebti to OJK by 12 January 2025; following this, OJK has issued Regulation No 27 of 2024 on Implementation of Trading of Digital Financial Assets Including Crypto Assets ( “OJK Regulation 27” ), which came into effect on 10 January 2025.
Some notable provisions under OJK Regulation 27 are as follows. • Minimum paid-up capital and equity: the minimum paid-up capital and equity require - ments for various actors in the digital financial assets space are: (a) exchanges – minimum paid-up capital of IDR1 trillion (circa USD60.6 million) and minimum equity of 80% of paid-up capital; (b) clearing and settlement institutions – minimum paid-up capital of IDR500 billion (circa USD30.3 million) and minimum equity of 80% of paid-up capital; (c) custodians – minimum paid-up capital of IDR200 billion (circa USD12.1 million) and minimum equity of 80% of paid-up capital; and (d) traders – minimum paid-up capital of IDR100 billion (circa USD6 million) and minimum equity of IDR50 billion (circa USD3 billion). • Onboarding of customers: detailed guidelines on the onboarding of customers were also introduced under OJK Regulation 27, becom - ing part of the obligations of traders. OJK Regulation 27 emphasises two categories of customers – ie, individuals and non-individu - als (eg, legal entities). Non-individual custom - ers are required to: (a) have a valid business licence from the relevant authority; (b) have a domicile or registered address in Indonesia; (c) be involved in digital financial trading as - sets for investment purposes, and not for payment or asset transfer purposes; and (d) ensure that all funds or assets originate from their own resources, and not from third parties, public levies or proceeds from criminal activities (including money
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