Indonesia

Layered atop this transition, OJK Regulation No. 23 of 2025 (POJK 23/2025) further amends POJK 27/2024, introducing new approval procedures for crypto derivatives trading, requirements for segregated custody accounts, and updated consumer-protection and reporting provisions. Notably, this amendment had already been in force for roughly nine months before being captured in the sourced record, and its precise commencement date remains unconfirmed -- a gap flagged for continued monitoring rather than resolved by inference. The regulatory sandbox mechanism introduced as part of the OJK transition requires that any firm offering crypto services be evaluated through that process; absent such evaluation, the firm is considered to be operating illegally. Older, still-relevant structural features persist alongside these updates: registration of crypto exchanges with the Commodity Futures Exchange (CFX) under 2019 Bappebti rules remains part of the documented historical baseline, and Indonesia continues to permit crypto trading as an investment activity while prohibiting the use of cryptocurrency as a means of payment.

Taken together, the licensing picture for Indonesia is now considerably more complete than in prior cycles, naming both the foundational transition regulation and its first amendment, but it remains an amber-rated picture rather than a fully resolved green one: the precise compliance timeline and detailed obligations under POJK 23/2025's derivatives and custody provisions are not yet independently confirmed, and the entire correction chain rests on secondary rather than primary legal sourcing.

Outlook

The principal open item is verification against OJK's own primary regulatory text for both POJK 27/2024 and POJK 23/2025, which would allow the derivatives-approval, custody-segregation, and reporting provisions introduced by the 2025 amendment to be dated and detailed with greater confidence. Barring a further legislative change, the licensing trajectory should be read as one of consolidation and tightening under OJK's expanded mandate rather than continued transitional uncertainty, though the amendment cadence -- a second regulation arriving within roughly a year of the first -- suggests the framework may continue to be actively refined in the near term.

Beyond this headline reclassification, two structural gaps in Indonesia's token-classification regime persist unresolved. First, no specific regulatory classification exists for non-fungible tokens (NFTs) distinct from the general crypto-asset rules; NFTs are addressed only incidentally, through AML-monitoring directives referencing money-laundering risk rather than through any dedicated NFT-specific framework. Second, OJK has not established any dedicated statutory sub-classification distinguishing stablecoins from other crypto assets more broadly -- stablecoins are simply crypto assets under the general digital-financial-asset umbrella, without a bespoke category of their own. Both gaps are treated as genuine, unresolved regulatory silences rather than as findings of deliberate non-regulation, and both are held at Uncertain confidence given the absence of any authoritative source confirming either a classification or a definitive absence of one beyond current sourcing.

Outlook

Continued monitoring is warranted on two fronts: whether any OJK or residual Bappebti guidance addresses NFT treatment directly as the broader digital-financial-asset framework matures under POJK 27/2024 and POJK 23/2025, and whether stablecoins receive any dedicated sub-classification as part of future rulemaking. Given that the core commodity-to-financial-instrument reclassification has now been confirmed as completed, it would be reasonable to expect further granularity -- including possible NFT or stablecoin-specific treatment -- to follow as OJK continues to build out its digital-financial-asset regulatory architecture, though nothing in the current sourced record confirms that such granularity is imminent.

Outside of these two touchpoints, Indonesia has not established any dedicated regulatory regime for decentralized finance (DeFi) lending, decentralized exchange (DEX) operation, node operation, or validator activity distinct from the centralized exchange licensing regime already described under crypto_licensing. This is treated as a genuine and currently unresolved regulatory gap rather than a deliberate non-regulation finding, and is held at Uncertain confidence reflecting the thinness of sourcing specifically addressing decentralized on-chain activity in Indonesia, as distinct from the comparatively richer sourcing available for centralized-exchange licensing and taxation.

Outlook

This module should be read as a genuine thin-coverage area rather than as evidence of an active regulatory silence-by-design; DeFi, DEX, node-operation, and validator activity in Indonesia simply have not yet attracted the kind of dedicated rulemaking seen for centralized exchanges, staking access, and mining taxation. Continued monitoring for any emerging OJK or Bappebti guidance specifically addressing decentralized on-chain activity is warranted, particularly as OJK's expanded digital-financial-asset mandate under POJK 27/2024 and POJK 23/2025 continues to develop and could plausibly extend into this space.

Outlook

This is a module to watch rather than a resolved gap: as OJK's digital-financial-asset framework continues to be built out and amended -- most recently through POJK 23/2025 -- there is a reasonable possibility that stablecoin-specific provisions could be introduced in future rulemaking, particularly given the segregated-custody-account requirements POJK 23/2025 has already introduced for the broader digital-asset space. No such stablecoin-specific development has been confirmed in this cycle's sourcing, and the module is emitted with an explicit no-analog disclosure pending future confirmation either way.

The more recent pillar is the OJK regulatory sandbox mechanism, effective 10 January 2025 alongside the broader Bappebti-to-OJK transition, which is designed to protect consumers, provide education, and prevent fraudulent crypto investment schemes. This framing is held at Probable confidence and is treated as consistent with, rather than a replacement for, the 2022 marketing restriction. A further, not-yet-fully-integrated layer concerns POJK 23/2025, which is understood from secondary legal commentary to introduce additional segregated-custody-account and consumer-protection provisions building on the 2024 framework; the specific detail of those provisions has not yet been captured at claim level in this cycle's sourced record and is tracked as an open item.

Outlook

The near-term priority for this module is twofold: locating any post-transition primary-source reaffirmation of the financial-institution marketing restriction, and capturing the specific consumer-protection and custody-segregation detail introduced by POJK 23/2025 once its primary text becomes available. Until then, this module should be read as directionally stable -- consumer-protection intent has clearly carried through the Bappebti-to-OJK transition and been reinforced by the newest amendment -- but with a documentation lag behind the underlying regulatory reality.

A further change concerns the special preferential 0.1% income-tax rate historically applied to mining activity, which sources indicate is being phased out during 2026, after which mining income would be subject to standard personal or corporate tax rates rather than the mining-specific carve-out. During composition, an internal date/stage inconsistency was identified and corrected: the claim's recorded effective date of 1 January 2026 for this change falls before the current reporting date, which is inconsistent with treating the change as merely enacted-but-not-yet-effective; the regulatory_stage has accordingly been aligned to reflect that the recorded date has passed. This technical alignment should not be read as independent confirmation that the carve-out has definitively lapsed on that exact date -- the precise within-year commencement communicated by underlying sources remains imprecise, and this residual uncertainty is preserved as an open monitoring item rather than resolved by the stage correction itself.

Outlook

The August 2025 rate changes are well-sourced and should be treated as settled features of the current regime. The mining income-tax carve-out's exact phase-out date remains the principal open item in this module and warrants continued monitoring for a precise commencement confirmation from primary tax-authority sources, given the material difference it would make to mining-sector tax exposure once the preferential rate is fully withdrawn.

Beyond this tax differential, no additional statutory restriction on outbound transfers of crypto assets to overseas exchanges or wallets has been identified in Indonesia's sourced record. This absence-of-restriction finding is held at Uncertain confidence, reflecting that it documents a genuine gap in available sourcing rather than an authoritative confirmation that no such restriction exists anywhere in the regulatory framework. Separately, and adjacent to but distinct from this module's core remit, it has not been confirmed whether Indonesia operates any crypto-specific cross-border travel-rule regime distinct from its general FATF-aligned AML/CFT framework; that question is treated as substantively owned by the Financial Integrity Monitor, with this module carrying only disambiguation context drawn from the FATF 2025 Follow-Up Report's continued enhanced-monitoring status for Indonesia.

Outlook

The fiscal differential between domestic and foreign-exchange-routed crypto sales is likely to remain the dominant, and best-documented, cross-border signal for Indonesia going forward. The two genuine open items in this module -- whether any non-tax outbound-transfer restriction exists, and whether a crypto-specific travel-rule regime is in operation -- both require further primary-source and cross-monitor-coordinated research before either can be resolved from an uncertain to a confirmed finding in either direction.