Blockchain as a Strategic Investment and Technological Pillar in Indonesia’s National Digital Economy Ecosystem

10 July 2025

Regulatory Background and Recent Developments in Indonesia’s Blockchain Landscape

In 2024, Indonesia emerged as the third highest adopter of cryptocurrency worldwide, following India and Nigeria. This surge in adoption coincided with a 72 percent increase in the number of registered blockchain companies, underscoring the sector’s accelerating momentum. In response, the Indonesian government has launched several strategic initiatives, most notably through Bank Indonesia’s plan to introduce a Central Bank Digital Currency (“CBDC”) in the form of a digital Rupiah, known as Project Garuda.

This initiative complements Bank Indonesia’s broader commitment to advancing national digital transformation. Specifically, it aligns with the ongoing efforts to integrate the country’s digital economic and financial ecosystems through two key frameworks: the Indonesian Payment System Blueprint 2030 (“BSPI 2030”) and the Blueprint for the Development of Money Market and Foreign Exchange Market 2030 (“BPPU 2030”). Together, these initiatives reflect a holistic, end to end strategy aimed at modernizing Indonesia’s monetary infrastructure and reinforcing its position in the global digital economy.

Alongside various government initiatives, a significant regulatory shift took effect on 10 January 2025. Pursuant to Article 3 of Government Regulation No. 49 of 2024 (“GR No. 49/24”) on the Transfer of Regulatory and Supervisory Authority over Digital Financial Assets, including crypto assets and financial derivatives, the responsibility for regulation and supervision has officially transitioned from the Commodity Futures Trading Regulatory Agency or the (“Bappebti”) to the Financial Services Authority or the (“OJK”) and Bank Indonesia.

This regulatory transfer represents a critical step toward establishing a more cohesive and robust framework for digital financial assets in Indonesia. The combination of clearer oversight mechanisms, targeted government initiatives, and the formalization of blockchain supervision reflects Indonesia’s firm commitment to embracing and navigating blockchain technology. Nevertheless, unlocking its full potential will require sustained investment in digital infrastructure, continued development of adaptive regulatory frameworks, and comprehensive public education to foster broader understanding and trust in the digital financial ecosystem.

This direction has also been emphasized in OJK Roadmap for the Development and Strengthening of Innovation in the Financial Technology Sector, Digital Financial Assets, and Crypto Assets for 2024 to 2028. Indonesia’s financial sector is undergoing rapid digital transformation, driven by a surge in Financial Sector Technology Innovation (Inovasi Teknologi Sektor Keuangan or the (“ITSK”). Indonesia has seen significant growth in this domain, as evidenced by the increase in ITSK companies from 2016 to 2023. This digital revolution is further underscored by the sharp rise in both the number of crypto investors and the overall transaction value, signalling the emergence of a dynamic digital investment climate in Indonesia.

In light of this accelerating transformation, the need for a comprehensive regulatory framework has become increasingly urgent. Law No. 4 of 2023 on the Development and Strengthening of the Financial Sector or the (“P2SK Law”) was enacted to address this need. The law grants the OJK clear authority to regulate and supervise financial technology innovation, including digital assets and crypto assets, thus reinforcing the state’s capacity to manage risks while supporting innovation and market development.

Unlocking Investment Opportunities in Indonesia’s Blockchain and Digital Asset Landscape

Indonesia has recently enacted Government Regulation No. 28 of 2025 on Risk-Based Business Licensing (“GR No. 28/25”). Notably, this regulation explicitly recognizes blockchain technology as an integral part of the national digital economy ecosystem. This development represents a pivotal milestone in the evolution of blockchain regulation in Indonesia. It reinforces the government’s strategic position in embracing decentralized technologies as a core component of its broader digital transformation agenda. By formally acknowledging blockchain within a risk-based licensing framework, Indonesia signals its readiness to foster innovation while ensuring regulatory clarity and investor confidence.

Article 186 (1) of GR No. 28/25 on Risk-Based Business Licensing provides a regulatory framework for the licensing of business activities within the sector of electronic systems and transactions. Under this provision, a Risk-Based Business License (“PB”) constitutes the formal legal authorization granted to business actors to commence and conduct operations in this sector.

The GR No. 28/25 enumerates specific activities that fall within this scope, including:

Consultancy and design services related to the Internet of Things (IoT);
Digital identity provision services;
Issuance of electronic certificates and services utilizing electronic certification;
Programming activities involving artificial intelligence technologies;
Development of blockchain technology; and
Software publishing activities.

In addition to core business licensing, Article 186 (2) of GR No. 28/25 also introduces the Supporting Business Licensing (Perizinan Berusaha untuk Menunjang Kegiatan Usaha or “PB UMKU”), which grants legal authorization for business actors to undertake supporting activities within the electronic systems and transactions sector.

The GR No. 28/25 stated that PB UMKU encompasses both operational and/or commercial support functions and includes the following key activities:

Registration of private electronic system operators across all business sectors; and
Classification of game products.

Regulatory Framework for Blockchain Supervision and Compliance in Indonesia

Indonesia’s regulatory framework for blockchain and digital assets continues to evolve, notably through the issuance of Financial Services Authority Regulation (Peraturan Otoritas Jasa Keuangan) No. 27 of 2024 (“POJK No. 27/24”) concerning the Administration of Digital Financial Asset Trading, including Crypto Assets.

Under POJK No. 27/2024, crypto assets are defined as digital representations of value that can be stored and transferred using technologies that enable the use of distributed ledgers such as blockchain to verify transactions and ensure the security and validity of stored information. These assets are not guaranteed by a central authority such as a central bank but are issued by private entities. They may be transacted, stored, transferred, or assigned electronically and may take the form of digital coins, tokens, or other asset representations. The regulation further classifies them into two categories: backed crypto assets and unbacked crypto assets. Importantly, POJK No. 27/2024 formally recognizes crypto assets as a subset of digital financial assets, defined as financial assets that are stored or represented in digital form.

Furthermore, in line with the regulatory framework for the administration of digital financial asset trading, Article 3 of POJK No. 27/2024 requires that digital financial asset trading be conducted in an orderly, fair, transparent, and efficient manner.

To that end, all digital asset trading platforms must implement the following key principles:

Good corporate governance;
Risk management;
Market integrity;
Information system security and reliability, including cyber resilience;
Consumer protection;
Prevention of money laundering, terrorism financing, and the proliferation of weapons of mass destruction;
Personal data protection; and
Compliance with applicable laws and regulations.

These obligations underscore the Indonesian government’s commitment to establishing a secure and trustworthy digital financial ecosystem. By enforcing these compliance standards, POJK No. 27/2024 seeks to balance innovation with market integrity, regulatory certainty, and investor confidence.

Conclusion

The explicit inclusion of blockchain development among the recognized business activities, alongside the comprehensive licensing and supervisory frameworks introduced through recent regulations, marks a significant regulatory acknowledgment of blockchain’s expanding role in Indonesia’s digital economy. By establishing legal certainty for these emerging sectors, the government of Indonesia aims to foster innovation while ensuring investor confidence and market integrity through structured oversight.

Collectively, this approach reflects the government’s broader commitment to cultivating a secure, transparent, and innovation-enabling digital financial ecosystem. As regulatory maturity progresses, Indonesia is well positioned to harness the transformative potential of blockchain and digital assets as key drivers of its national digital transformation agenda.

For further information regarding compliance obligations, sanctions, and the applicable procedures for obtaining risk-based business licensing, please do not hesitate to contact us. We would be pleased to provide more detailed guidance tailored to your needs.