OJK’s Expanded Framework on Digital Financial Assets: New Amendments and New Draft Regulation

18 December 2025

Indonesia has completed the shift of digital asset market trading oversight to the Financial Services Authority (“OJK”) with the enactment of the OJK Regulation No. 27 of 2024 (“OJK Regulation 27/2024”) which governs secondary-market trading and market infrastructure.

OJK Regulation 27/2024 was recently amended by OJK Regulation No. 23 of 2025 (“Amended OJK Regulation 27/2024”) which brought about a few key amendments, including:

	OJK Regulation 27/2024	Amended OJK Regulation 27/2024
Expanded scope/definitions	Definition was generic; Digital Financial Assets (DFA) were framed as “including crypto assets,” without a distinct non-crypto category or any reference to derivatives.	DFA are expressly split into (i) Crypto Assets and (ii) other DFA, and “other DFA” includes DFA derivatives.
Provisions on DFA offering	Does not regulate initial offerings.	Clarifies the regulation does not cover DFA offerings, whether initial or ongoing, for crypto assets and tokenised assets.
Eligibility criteria for listed assets	DFAs must be issued, held, transferred, and/or traded using DLT.	DFAs may (i) use DLT or other technology, or (ii) reference an underlying DFA already on the DFA List.
Registry	Daftar Aset Kripto (Crypto Asset List) set and maintained by the Exchange.	Becomes Daftar Aset Keuangan Digital (DFA List – umbrella list) set and maintained by the Exchange.
DFA derivatives trading framework	No explicit DFA derivatives-trading framework.	Expressly permitted subject to prior OJK approval for the Exchange.

The absence of DFA offering/issuances framework under the OJK Regulation 27/2024, leaving a primary-market gap. OJK has therefore circulated a Draft OJK Regulation on Digital Financial Asset Offerings (issued in September 2025) to provide a clear approval, disclosure, and gatekeeping standards for DFA offering and issuance (“Draft OJK Regulation”). This Draft OJK Regulation sets out the institutional framework, licensing requirements, offering mechanisms, consumer protection, reporting, and supervision for Digital Financial Asset offering providers. The key takeaways from this Draft are:

DFA classification	tokenised asset, backed crypto asset, and unbacked crypto asset
Offering formats	(a) Single offering: one window for offerings within 3-5 business days; and (b) ongoing subscription, permitted only for tokenised assets and backed crypto (not unbacked)
DFAs excluded from the offering	(a) are securities as defined under the applicable capital markets laws and regulation; (b) are issued by a central bank; (c) cannot be traded or transferred between consumers; (d) are traded solely to access specific facilities provided by the issuer (closed-loop); (e) are unique in nature and cannot be exchanged for other DFA; (g) are offered free of charge.
Offering criteria	offered via mass media or to more than 100 persons, carried out within the jurisdiction of Indonesia.
Criteria of a tokenised asset	(a) take the form of an asset or beneficial interest in an asset, and/or an intangible asset or other rights, other than the digital financial asset itself or other assets available only in digital form; (b) be legally and validly under the issuer’s possession, control, and ownership; (c) not be subject to any dispute; (d) not be encumbered as collateral, under seizure, and/or subject to any other security interest; and (e) generate economic benefits that can be distributed to consumers.
Types of assets prohibited to be tokenised	(a) derivates of financial asset; and (b) crypto asset.
Issuance requirements	the Draft OJK Regulation provides all the requirements for an issuer in order to issue DFAs.
Offering approval and procedure	the Draft OJK Regulation provides all the requirements to obtain approval and the procedure to conduct offering of the said DFAs. This includes all the obligations post-offering.
New role: Asset Custodian	the Draft OJK Regulation identifies a new role of “Asset Custodian” which in charge of managing the assets that will be tokenised and will cooperate with the DFA issuer in storing the asset which will be tokenised.

Read together, OJK Regulation 27/2024 (as amended) and the Draft OJK Regulation, signal a clear policy direction that OJK is moving toward a more integrated and enhanced regulatory architecture for both the secondary and primary markets of DFA in Indonesia. OJK is actively finalising the draft regulation and, in parallel, supervising and collaborating with industry participants through the regulatory sandbox to promote a safer market for consumers and investors.