Asia/ID/Comparables
Indonesia
Otoritas Jasa Keuangan (OJK)
Indonesia moved crypto from the commodity futures regulator to the financial-services authority and then wrote a primary-law taxonomy. Law 4/2026 (effective 17 June 2026) creates Digital Financial Asset Financial Institutions, including a separate class for digital financial assets other than crypto (the stablecoin/tokenisation bucket). OJK licenses traders against a whitelist. Crypto is not a means of payment. There is no CIC and no $5 million fuse.
Law 4/2026
17 Jun 2026
POJK
27/2024 + 23/2025
PADK 3/2026
1 Sep 2026
Similar regulation
The statute book
Primary instruments, with the RCA job each one actually does. Links open the official text.
- In force
CASP / exchange analogue — licensed traders + bourse whitelist
Translation
Rule 100–500 map
| RCA | Peer | Fit | Desk |
|---|---|---|---|
| Rule 100 CIC | Crypto asset vs digital financial asset other than crypto (Law 4/2026) | Partial | Statutory taxonomy of the token class. No Howey wrapping. |
| Rule 103 disclosure | Whitelist + trader disclosures, not an issuer circular | No analogue | The public document is the OJK trader list and the bourse whitelist, not a Form 1-CRYPTO. |
| Rule 200 $5M | None | No analogue | No startup offering cap. Initial offerings are now in the statutory activity list, under OJK. |
| Rule 300 fundraising | Initial offerings as a regulated LJK AKD activity | Partial | The 2026 law names initial offerings. That is a licensed activity, not a Securities Act exemption. |
| Rule 400 safe harbor | None | No analogue | No deemed-cessation. |
| Rule 500 preemption | National OJK perimeter | No analogue | No passport. |
Analysis
What the file is
OJK took crypto from Bappebti under the P2SK architecture and then iterated the trading regulation (POJK 27/2024, amended by POJK 23/2025 to bring in derivatives and a wider digital-financial-asset definition). Law 4/2026, effective 17 June 2026, puts a statutory label on the firms: LJK Aset Kripto and LJK AKD selain Aset Kripto. The second bucket is where stablecoins and tokenised assets are supposed to live. PADK 3/2026 (from 1 September 2026) is the reporting and evaluation circular for traders. The public-facing fact is the OJK whitelist of licensed traders — Indodax, Pintu, Tokocrypto, Upbit and the rest.
Research
The record
- The bourse whitelist is the product filter. Tokens not on it are not tradable on licensed venues. That is closer to ADGM AVA than to Rule 100.
- OJK’s regulatory sandbox (ITSK) is where novel models (including crypto-backed rupiah liquidity) are being tested. A sandbox letter is not a licence.
Ideation
What to file
- Law 4/2026’s ‘initial offerings’ limb is the Indonesian analogue to a public token sale. If you would use it, say so. If you would not, because it is a licensed-trader market rather than an issuer exemption, say that too.
- Do not cite Bappebti as the current authority. It is not.
Analysis
What the file is
OJK took crypto from Bappebti under the P2SK architecture and then iterated the trading regulation (POJK 27/2024, amended by POJK 23/2025 to bring in derivatives and a wider digital-financial-asset definition). Law 4/2026, effective 17 June 2026, puts a statutory label on the firms: LJK Aset Kripto and LJK AKD selain Aset Kripto. The second bucket is where stablecoins and tokenised assets are supposed to live. PADK 3/2026 (from 1 September 2026) is the reporting and evaluation circular for traders. The public-facing fact is the OJK whitelist of licensed traders — Indodax, Pintu, Tokocrypto, Upbit and the rest.
Primary sources on file
OJK PADK No. 3 of 2026 — trading of digital financial assets including crypto assets
Otoritas Jasa Keuangan/30 Jun 2026/RCA review 10 Sept 2026
Primary regulatory
RCA publishes source-linked intelligence for professionals. Nothing here is a token-buying call, a legal opinion, or an “approved / safe / regulated” badge. Every material claim is dated. Incomplete files stay incomplete.