The Indonesian Financial Services Authority (Otoritas Jasa Keuangan or “OJK”) recently issued OJK Regulation No. 23 of 2025, which amends OJK Regulation No. 27 of 2024 on the Implementation of Digital Financial Asset Trading, including Crypto Assets (“OJK Reg. 23/2025”).
OJK Reg. 23/2025 aims to strengthen Indonesia’s regulatory framework and enhance clarity and investor protection in the digital asset market.
Recognition of Digital Financial Asset Derivatives
One of the most significant developments introduced under OJK Reg. 23/2025 is the express classification of derivatives of digital financial assets as digital financial assets in their own right. As a result, digital financial asset derivatives now fall squarely within the OJK’s regulatory oversight.
Previously, while digital asset derivatives were recognized in practice, the prevailing regulatory framework did not expressly regulate such instruments. By formally bringing derivatives within the scope of regulated digital financial assets, OJK Reg. 23/2025 enhances legal certainty for market participants and confirms that derivative trading activities are subject to a defined supervisory regime and strengthened investor protection measures.
In addition, OJK Reg. 23/2025 introduces a number of new requirements applicable to Digital Financial Asset Trading Operators (i.e., Digital Financial Asset Bourses (“Bourse”), Digital Financial Asset Clearing Institutions (“Clearing”), Digital Financial Asset Custodians (“Custodian”), Digital Financial Asset Traders (“Trader”), and other parties as may be determined by the OJK) that engage in the trading of digital financial asset derivatives. These new requirements include specific procedures for obtaining OJK approval to conduct such derivative trading activities.
Electronic System Provider Registration Requirement
Another notable development under OJK Reg. 23/2025 is the requirement for Digital Financial Asset Trading Operators to be registered as Electronic System Providers (Penyelenggara Sistem Elektronik or “PSE”).
While, in practice, Digital Financial Asset Trading Operators typically provide their services through websites and/or applications, activities that would generally trigger PSE registration obligations, such registration was not expressly required under the digital financial asset regulatory framework. Following the issuance of OJK Reg. 23/2025, however, Digital Financial Asset Trading Operators are now explicitly required to be registered as PSEs.
New Provisions Relevant to Bourses
OJK Reg. 23/2025 also introduces several new provisions relevant to Bourses. A key amendment concerns the expanded scope of duties of Bourse Committees. Under the previous regulation, the scope of work of a Bourse Committee was not expressly elaborated. OJK Reg. 23/2025 now clarifies that, at a minimum, a Bourse Committee is responsible for:
- supporting the development of the digital financial asset industry;
- providing recommendations in relation to the evaluation of digital financial assets included in the official list of digital financial assets; and
- providing recommendations on the determination of reference prices for digital financial asset derivatives.
Separately, OJK Reg. 23/2025 amends the requirements relating to ISO certification. Under the previous regulation, a bourse was specifically required to obtain ISO certification for its Disaster Recovery Center (“DRC”). The new regulation broadens this obligation so that ISO certification is now required more generally, rather than being limited solely to the DRC.
In addition, Bourse Rules are now required to include new mandatory provisions, including mechanisms for the settlement of digital financial assets that are removed from the list of approved digital financial assets. Where a bourse facilitates the trading of digital financial asset derivatives, further derivative-specific provisions must also be incorporated into the Bourse Rules.
New Provisions Relevant to Clearing Institutions
Similar to the amendments applicable to Bourses, OJK Reg. 23/2025 introduces additional requirements to be reflected in the Rules of Clearings. These include provisions governing the management of benefits derived from consumers’ funds. Where a Clearing institution facilitates the trading of digital financial asset derivatives, further provisions specific to derivative trading must also be included in the Clearing Rules.
A further notable change concerns the role of Clearing institutions in relation to Custodians. Under the previous framework, a Clearing institution was authorized to recommend Custodians, as well as the Custodian’s storage systems or mechanisms, to the OJK as part of the licensing process. OJK Reg. 23/2025 removes this requirement, such that Custodians are no longer required to obtain recommendations from a Clearing institution as a prerequisite for licensing.
New Provisions Relevant to Traders
With respect to Traders, OJK Reg. 23/2025 introduces clarifications to the licensing application process. Specifically, where the OJK requests additional documents and/or information, or requires adjustments to documents already submitted, a failure by a prospective Trader to comply with such requests will result in the cancellation of the license application process.
OJK Reg. 23/2025 also introduces a more flexible approach to the implementation of the Travel Rule in digital financial asset trading. Traders are now permitted to implement the Travel Rule through cooperation with third-party service providers. As the regulation does not further elaborate on the scope or mechanics of such cooperation, its practical application will need to be assessed in light of future guidance and market practice.
Amendments to the Segregated Account Regime
OJK Reg. 23/2025 also revises the provisions governing segregated accounts. Under the amended framework, functions that were previously carried out through segregated accounts in the name of Traders are now to be performed through segregated accounts in the name of Clearing institutions, for the benefit of each respective consumer.
By way of example, under the previous regulation, consumers were required to place transaction funds in a segregated account held in the name of the Trader prior to executing trades. Under OJK Reg. 23/2025, such funds must instead be placed in a segregated account held by the Clearing institution for the benefit of the relevant consumers. This change is reflected across other provisions relating to segregated accounts.
As a consequence, the obligation for Traders to grant a power of attorney to the Clearing institution for the supervision of segregated accounts, previously required under a prescribed format, is removed. Given these changes, it remains to be seen how the OJK will treat segregated accounts previously maintained in the name of Traders going forward.
Changes to the Classification of Supporting Providers
OJK Reg. 23/2025 amends the classification of supporting providers. Previously, supporting providers were categorized as:
- intermediary services related to payment service providers;
- providers of digital financial asset transaction facilitation services; and
- other supporting activities.
Under the amended regulation, the category of digital financial asset transaction facilitation service providers is removed. Accordingly, how the OJK will treat entities that were previously approved under the deleted category will need to be clarified through future regulatory practice or guidance.
Reporting Obligations of Digital Financial Asset Trading Operators
A further amendment concerns reporting obligations. Under OJK Reg. 23/2025, Digital Financial Asset Trading Operators are no longer required to submit daily reports. Instead, reporting obligations are now limited to monthly, quarterly, and annual reports, reducing the administrative burden associated with daily reporting requirements.
OJK’s Authority to Conduct Regulatory Sandbox Trials
Finally, OJK Reg. 23/2025 introduces a new authority for the OJK to conduct trials within a regulatory sandbox environment for digital financial asset derivative trading activities. Based on certain considerations, this provision enables the OJK to test and evaluate derivative trading models in a controlled regulatory setting, supporting innovation while maintaining supervisory oversight. (21 January 2026)
