Indonesia

Okay, here is the comprehensive report on the current status of Retail Cryptocurrency Trading in Indonesia, prepared by a specialized financial regulatory analyst.

**Report on the Current Status of Retail Cryptocurrency Trading in Indonesia**

**Date:** April 13, 2025

**Analyst:** Specialized Financial Regulatory Analyst

**Topic: Retail_Trading_Status**

**Description:** Assessment of whether individual citizens and residents in Indonesia are legally permitted to buy, sell, and hold cryptocurrencies, detailing the regulatory environment surrounding this activity (e.g., KYC/AML requirements imposed on platforms, general warnings issued).

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**1. Identified Status:**

**Allowed-Regulated**

**2. Detailed Narrative Explanation:**

Retail cryptocurrency trading (buying, selling, and holding) is legally permitted for individual citizens and residents in Indonesia, but it operates within a specific and evolving regulatory framework. The Indonesian government does not recognize cryptocurrencies as legal tender or a valid means of payment, explicitly prohibiting their use for transactions of goods and services. The Indonesian Rupiah remains the sole legal tender. (Sources: 1, 2, 4, 6, 8, 13, 19, 23, 24)

Historically, Indonesia initially approached cryptocurrencies with caution. Bank Indonesia (BI), the central bank, issued warnings and prohibited the use of crypto as a payment instrument in 2017 due to concerns about volatility, financial stability, and illicit activities like money laundering. (Sources: 1, 4, 8, 19, 23) However, recognizing the growing interest and potential, the government shifted its stance in 2018/2019. Instead of an outright ban on ownership or trading, crypto assets were legally classified as *commodities* that could be traded on futures exchanges. (Sources: 1, 2, 4, 6, 8, 12, 20, 24)

Regulatory oversight was initially placed under the Commodity Futures Trading Regulatory Agency (Badan Pengawas Perdagangan Berjangka Komoditi - BAPPEBTI), which falls under the Ministry of Trade. (Sources: 1, 2, 5, 20) BAPPEBTI established the primary regulatory framework through regulations such as Bappebti Regulation No. 8 of 2021 (as amended, e.g., by No. 13 of 2022 and potentially later ones like No. 2 of 2024 and No. 9 of 2024). (Sources: 1, 2, 3, 5, 20) These regulations mandated:
*   **Licensing:** Entities wishing to operate as crypto asset physical traders (exchanges) must obtain licenses from the regulator. (Sources: 1, 2, 4, 12, 22, 25) This involves meeting specific requirements, including significant paid-up capital (e.g., IDR 100 billion for traders, potentially higher for exchanges) and maintaining minimum equity levels (e.g., IDR 50 billion for traders). (Sources: 2, 4, 22)
*   **Approved Asset List:** Only crypto assets approved and listed by the regulator can be legally traded on licensed platforms. BAPPEBTI periodically updated this list (e.g., Bappebti Regulation No. 11 of 2022, as amended by No. 2 of 2024 listed 545 assets; a later update in Jan 2025 listed 1,396). (Sources: 2, 3, 5, 12, 20, 22)
*   **KYC/AML/CFT:** Strict Know Your Customer (KYC), Anti-Money Laundering (AML), and Counter-Financing of Terrorism (CFT) procedures are mandatory for all licensed platforms. This includes customer due diligence, transaction monitoring, and reporting suspicious activities. (Sources: 1, 4, 12, 29)
*   **National Exchange (CFX):** In July 2023, Indonesia launched a national crypto bourse, the Commodity Futures Exchange (CFX or PT Bursa Komoditi Nusantara), intended to enhance oversight, transparency, and investor protection by separating trading, clearing, and custody functions under regulatory supervision. Exchanges are required to register with CFX. (Sources: 1, 5, 26)

**Regulatory Transition:** A significant development is the transition of regulatory and supervisory authority over crypto assets (now often termed Digital Financial Assets - DFA) from BAPPEBTI to the Financial Services Authority (Otoritas Jasa Keuangan - OJK). This shift was mandated by Law No. 4 of 2023 concerning the Development and Strengthening of the Financial Sector (UU P2SK) and officially took effect in January 2025. (Sources: 1, 2, 3, 5, 9, 11, 14, 16, 27, 29) OJK issued Regulation No. 27 of 2024 (POJK 27/2024) in late 2024/early 2025 to govern the trading of DFAs, including crypto assets. (Sources: 3, 9, 11, 14, 29) This move aims to integrate crypto assets more formally into the financial services sector, aligning oversight with international standards and strengthening investor protection, governance, and risk management. (Sources: 3, 5, 9, 29) Existing licenses issued by BAPPEBTI remain valid during the transition, and entities are expected to comply with OJK regulations. (Sources: 3, 9, 14) The reclassification under OJK potentially shifts the view of crypto from purely a commodity towards a financial instrument or security, though the exact implications are still unfolding. (Sources: 2, 11, 14, 29)

**Taxation:** Crypto transactions are subject to taxation in Indonesia since May 2022, as outlined in Ministry of Finance Regulation No. 68/PMK.03/2022. This includes both Value Added Tax (VAT) and Income Tax (PPh Pasal 22 Final) on trading transactions, typically levied at rates like 0.11% for VAT and 0.1% for PPh if transacted via a registered platform. Different rates may apply if the platform is unregistered or for activities like mining. (Sources: 1, 2, 4, 7, 10, 15, 18, 21)

In summary, Indonesian individuals can legally buy, sell, and hold cryptocurrencies through licensed platforms. However, this activity is strictly regulated, covering platform licensing, approved assets, mandatory KYC/AML procedures, and specific tax obligations. The use of crypto as payment remains prohibited. The regulatory landscape is actively evolving, with oversight recently transferred to the OJK, indicating a move towards integrating crypto more deeply within the formal financial regulatory framework.

**3. Specific Relevant Text Excerpts:**

*   **On Legality and Commodity Status:** "Yes, crypto is legal in Indonesia, but it can only be traded as a commodity. It is not accepted as a payment instrument." (Source: Sumsub, Feb 2024) [2] "Cryptocurrencies are recognized as commodities in Indonesia, not as fiat currency. This distinction is upheld under Indonesian Law No. 4 of 2023..." (Source: Murzal & Partners, Nov 2024) [5]
*   **On Regulatory Oversight Transition:** "As of 2023, the key crypto regulator in Indonesia is the Commodity Futures Trading Regulatory Agency, known as Bappebti... However, with the enactment of Law 4/2023, regulatory authority over crypto-assets will be transferred to the Financial Services Authority, or OJK, by 12 January 2025." (Source: Sumsub, Feb 2024) [2] "On 10 January 2025, Indonesia's Financial Services Authority (Otoritas Jasa Keuangan (“OJK”)) Regulation No. 27 of 2024 on Trading in Digital Financial Assets, Including Crypto Assets (“OJK Regulation No. 27” or “Regulation”) came into force. It transitions the regulatory and supervisory duties for digital financial assets (“DFA”), including crypto assets... from the Commodity Futures Trading Authority (Badan Pengawas Perdagangan Berjangka Komoditi (“Bappebti”)) to OJK." (Source: AGI Legal, Jan 2025) [3]
*   **On Prohibition as Payment:** "In 2017, Bank Indonesia issued a statement in which it prohibited the use of cryptocurrencies as a means of payment." (Source: Google Grounding API Source [1], Sep 2024) [1] "...the Indonesian monetary authority (Bank Indonesia/“BI”) has stated that Cryptocurrency is prohibited from use as payment instrument. It is stated that the only legal instrument of payment in Indonesia is the Rupiah..." (Source: Journal of Central Banking Law and Institutions, Dec 2021) [23]
*   **On Licensing and Requirements:** "Activities concerning cryptocurrency are required to obtain approval from BAPPEBTI [now OJK] to be conducted legally in Indonesia." (Source: Sumsub, Feb 2024) [2] "Crypto Asset Physical Traders registration obligation is applicable for crypto businesses. Key requirements include: Minimum paid-up capital: IDR 50 billion; Minimum equity: IDR 40 billion..." (Source: Coinfomania, Apr 2025) [4] (Note: Capital requirements might differ based on specific license type and OJK regulations).
*   **On KYC/AML:** "Indonesia enforces strict AML/KYC rules: Mandatory appointment of a Money Laundering Reporting Officer (MLRO); Customer Due Diligence (CDD) for both individuals and legal entities; Sanctions screening, transaction monitoring, and risk assessments..." (Source: Coinfomania, Apr 2025) [4] "Prior to engaging a customer, it is mandatory for a trader to conduct KYC and Customer Due Diligence." (Source: Arkananta Vennootschap) [12]
*   **On Taxation:** "Since 1 Mei 2022, perdagangan aset kripto di Indonesia resmi dikenakan pajak. Hal ini tertuang dalam PMK 68/PMK.03/2022 tentang Pajak Pertambahan Nilai (PPN) atas Penyerahan Aset Kripto dan Pajak Penghasilan (PPh) atas Penghasilan dari Transaksi Penjualan Aset Kripto." (Translation: Since May 1, 2022, crypto asset trading in Indonesia is officially subject to tax. This is stated in MoF Regulation 68/PMK.03/2022 concerning Value Added Tax (VAT) on the Delivery of Crypto Assets and Income Tax (PPh) on Income from Crypto Asset Sales Transactions.) (Source: BINUS University, Apr 2024) [15] "Setiap transaksi kripto dikenakan PPN sebesar 0,11% dan PPh sebesar 0,1% dari nilai transaksi bruto." (Translation: Every crypto transaction is subject to 0.11% VAT and 0.1% PPh of the gross transaction value.) (Source: INDODAX, Sep 2024) [18]

**4. Direct URL Links to Sources:**

*   **BAPPEBTI (Former Regulator, regulations may still be referenced during transition):** [http://bappebti.go.id/](http://bappebti.go.id/) (Specific regulations like No. 8/2021, 11/2022, 2/2024, 9/2024 might be found under 'Peraturan' or 'Regulasi' sections, though primary focus should now be OJK).
*   **OJK (Current Regulator):** [https://www.ojk.go.id/](https://www.ojk.go.id/)
    *   OJK Regulation No. 27 of 2024 Press Release: [https://www.ojk.go.id/en/berita-dan-kegiatan/info-terkini/Pages/OJK-Issues-Regulation-Concerning-the-Implementation-of-Digital-Financial-Asset-Trading-including-Cryptocurrency.aspx](https://www.ojk.go.id/en/berita-dan-kegiatan/info-terkini/Pages/OJK-Issues-Regulation-Concerning-the-Implementation-of-Digital-Financial-Asset-Trading-including-Cryptocurrency.aspx) [9] (Note: Full text of POJK 27/2024 may require searching the OJK legal database).
*   **Bank Indonesia (Central Bank - Stance on Payment):** [https://www.bi.go.id/](https://www.bi.go.id/) (Search for press releases or regulations regarding cryptocurrency or virtual currency).
*   **Ministry of Finance (Tax Regulations):** [https://www.kemenkeu.go.id/](https://www.kemenkeu.go.id/)
    *   PMK 68/PMK.03/2022 (Tax Regulation): Searchable on the Ministry's legal database (JDIH Kemenkeu).
*   **Law No. 4 of 2023 (UU P2SK):** Searchable on Indonesian government legal databases (e.g., JDIH National).
*   **Secondary Sources Summarizing Regulations:**
    *   Sumsub (Feb 2024): [https://sumsub.com/blog/crypto-regulations-in-indonesia/](https://sumsub.com/blog/crypto-regulations-in-indonesia/) [2]
    *   AGI Legal (Jan 2025): [https://www.agilegal.com/insights/indonesia-financial-services-authority-sets-out-framework-for-trading-of-digital-financial-assets-in-new-regulation/](https://www.agilegal.com/insights/indonesia-financial-services-authority-sets-out-framework-for-trading-of-digital-financial-assets-in-new-regulation/) [3]
    *   Coinfomania (Apr 2025): [https://coinfomania.com/guides/cryptocurrency-regulations-in-indonesia/](https://coinfomania.com/guides/cryptocurrency-regulations-in-indonesia/) [4]
    *   SSEK Law Firm (Dec 2024): [https://www.ssek.com/blog/legal-framework-governing-cryptoassets-in-indonesia](https://www.ssek.com/blog/legal-framework-governing-cryptoassets-in-indonesia) [20]
    *   ARMA Law (Feb 2025): [https://arma-law.com/news-updates/ojk-takes-the-lead-in-regulating-digital-financial-assets-and-crypto-assets/](https://arma-law.com/news-updates/ojk-takes-the-lead-in-regulating-digital-financial-assets-and-crypto-assets/) [14]

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**End of Report**