Indonesia's Financial Derivatives Market Awaits a New Regulation for Securities Underlying
Introduction
In January 2025, Indonesia's Financial Services Authority (Otoritas Jasa Keuangan or “OJK”) issued OJK Regulation No. 1 of 2025 on Financial Derivatives with Underlying Assets in the Form of Securities (“OJK Reg. 1/2025”), the first step in transferring regulatory and supervisory authority over financial derivatives from the Commodity Futures Trading Regulatory Agency (Badan Pengawas Perdagangan Berjangka Komoditi or “Bappebti”) to OJK and Bank Indonesia. That transfer was mandated by Law No. 4 of 2023 on the Development and Strengthening of the Financial Sector (as amended by Law No. 4 of 2026) (“P2SK Law”), which required the handover to be completed within 24 months. The recitals of the draft regulation discussed below describe OJK Reg. 1/2025 as the initial-stage legal basis for that process.
In August 2026, OJK published on its website a draft regulation on Financial Derivatives with Underlying Assets in the Form of Securities (“Draft Regulation”) for public consultation. Once enacted, the Draft Regulation will replace the currently effective OJK Reg. 1/2025 governing the same subject matter.
The Draft Regulation appears to expand and refine several provisions of OJK Reg. 1/2025. Although it remains a draft that has not yet been finalized and may be subject to further revision, this alert summarizes the changes currently proposed under the Draft Regulation.
Regulatory and Supervisory Scope
OJK Reg. 1/2025 limits the regulatory and supervisory scope for securities derivatives to the products, (business) actors, and operation of financial derivatives market infrastructure. However, the Draft Regulation lists the following subjects expressly in its scope clause:
securities derivatives transactions;
licensing;
reporting and supervision;
consumer protection;
implementation of anti-money laundering, counter-terrorism financing, and counter-proliferation financing measures relating to weapons of mass destruction;
implementation of the anti-fraud strategy;
exit policy mechanisms; and
coordination
Several of these subjects are not new in substance: OJK Reg. 1/2025 already covered supervision, reporting, consumer protection and licensing, although outside its scope clause.
The Draft Regulation also provides a detailed regime for channeling customer orders to foreign brokers (Penyaluran Amanat Luar Negeri, “PALN”), which OJK Reg. 1/2025 does not address.
Products
Development of New Products
Product approval itself is not new: OJK Reg. 1/2025 already required OJK approval for every traded product. What the Draft Regulation adds is a preliminary assessment step for market-initiated proposals and a separate process, with a report to OJK at least 10 working days before trading or participation starts, for expanding the underlying or participants of an existing product. Before a new securities derivative product may be traded, the relevant securities exchange or securities derivatives exchange, together with the relevant clearing institution, must obtain approval from the OJK. If the initiative to develop a new product originates from a market participant, the proposal must first be submitted to the relevant exchange and/or clearing institution for a preliminary assessment before being submitted to OJK for approval.
Types of Products
There are several changes to the types of products between OJK Reg. 1/2025 and Draft Regulation as may be seen below:
OJK Reg. 1/2025 | Draft Regulation |
Futures contracts, sharia derivative contracts, and/or other derivative contracts with the following underlying:
| Futures contracts over securities, which include:
with underlying securities issued in Indonesian or foreign jurisdictions. |
Options contracts on Securities | Options contracts on equity securities (equity options) with underlying securities issued in Indonesian or foreign jurisdictions. |
Other financial derivative contracts as determined by OJK. | Swap contracts on securities, which include:
with underlying securities issued in Indonesian or foreign jurisdictions. |
| Sharia securities derivative contracts with underlying securities issued in Indonesian or foreign jurisdictions |
| Other securities derivative contracts as determined by OJK, including:
with underlying securities issued in Indonesian or foreign jurisdictions. |
The Draft Regulation provides greater specificity regarding the types of securities derivatives that may be offered by expressly recognizing securities-based swap contracts and CFDs conducted through an ATS.[2] Further, the Draft Regulation specifies which securities may be used as underlying assets for securities derivatives and the criteria they must satisfy, including, (i) equity securities, (ii) foreign single stock, and, (iii) domestic debt securities..
A new PALN regime for channeling orders to foreign brokers
The Draft Regulation introduces a defined framework for PALN, the forwarding of customer orders to a foreign exchange or foreign broker for execution abroad. It provides some specific requirements for the foreign broker counterparty, as discussed below. Unlike OJK Reg. 1/2025, which contains no PALN provision, it sets out concrete eligibility criteria for the foreign brokers to which Indonesian intermediaries may forward orders.
The Draft Regulation also specifies similar conditions for tradable products and introduces additional requirements on the determination of reference prices and, where the underlying asset consists of foreign securities, on currency conversion.
Participants
The Draft Regulation generally adopts the same participant structure as OJK Reg. 1/2025, while introducing a more comprehensive framework specifically tailored to the securities derivatives activities. The Draft Regulation categorizes the participants into the following:
Securities Derivatives Broker-Dealers (Perantara Pedagang Derivatif Efek, “PPE Derivatif Efek”) which consists of:
Securities Broker Dealer (Perantara Pedagang Efek), being an OJK-licensed securities company that conducts business as a broker-dealer and is classified as PEKU 2 or PEKU 3 (Perusahaan Efek Kegiatan Usaha, the grouping of securities companies by business activity and capital);
Securities Derivative Trader, who has obtained a license from Bappebti as Futures Trader and a license as Securities Derivative Trader from OJK; and
Securities Derivative Broker, who has obtained a license from Bappebti as Futures Broker and a license as Securities Derivative Broker from OJK.
Securities Derivatives Investment Advisors (Penasihat Investasi Derivatif Efek) which consists of investment advisors or securities derivatives advisors;
Representatives of Securities Derivatives Market Participants (Wakil Pelaku Derivatif Efek) which consists of representatives of securities broker-dealers, representatives of securities derivatives broker-dealers, representatives of securities derivatives advisors and other representatives as may be determined by OJK;
Other parties holding a business license or approval from OJK; and
Investors which consist of professional and retail investors.
In the Draft Regulation, OJK introduces a dedicated category of representatives (wakil) and expressly classifies the categories of investors. The Draft Regulation also contains more detailed provisions governing market participants than OJK Reg. 1/2025. For example, OJK Reg. 1/2025 primarily regulates the obligations of Financial Securities Derivatives Broker-Dealers (Perantara Pedagang Efek Derivatif Keuangan). While the Draft Regulation contains similar provisions for Securities Derivatives Broker-Dealers, it goes further by also prescribing the obligations and prohibitions applicable to Securities Derivatives Investment Advisors, Representatives of Securities Derivatives Market Participants, and investors.
Specifically for PPE Derivatif Efek, depending on the type of entity, the scope of securities derivatives-related activities may vary:
Securities Broker Dealer (PEKU 3) | Securities Broker Dealer (PEKU 2) | Securities Derivative Trader | Securities Derivative Broker |
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For Securities Broker Dealer and Securities Derivative Broker carrying out PALN activities, certain requirements must be fulfilled, including cooperating with licensed overseas broker with equity of > USD 1 billion.
Transactions
Draft POJK outlines the transaction mechanism for securities derivatives products as follows:
Mechanism | Contract Types | Eligible Investors | Remarks |
| |||
Multilateral (Exchange Traded Derivatives) | Futures contracts and option contracts, with underlying domestic or foreign securities and/or securities index | Professional and retail investors. | Retail investors must comply with the maximum leverage limit. |
Bilateral – through ATS Organizer | CFD | Professional investors.
Retail investors’ involvement will trigger a leverage limit (Article 71(b)). In our view, this appears inconsistent with Article 71(a), which allows only professional investors to transact CFDs through an ATS. Further clarification from OJK may be required. |
|
Bilateral – through PPA | Standardized securities derivatives contracts on securities tradable on the PPA | Professional and retail investors. | Retail investors must comply with the maximum leverage limit. |
Bilateral – between financial services institutions | Non-standardized securities derivatives contracts | Financial services institutions | Must use standard global derivatives documentation. |
| |||
PALN | Fractional contracts and futures contracts | Not explicitly specified.
The Draft Regulation applies the maximum leverage limit to retail investors, but the Draft Regulation does not state which categories of investors may use PALN, including whether professional investors may. Further clarification from OJK may be required.
| Requires cooperation with a foreign exchange or foreign broker.
Retail investors must comply with the maximum leverage limit.
Total PALN transaction value is capped relative to the total value of domestic buy transactions facilitated by the PPE Derivatif Efek (Article 74(6)); the Draft Regulation does not specify the ratio. |
Transitional Provisions
The Draft Regulation also contains transitional provisions. Holders of approval in principle (persetujuan prinsip) under OJK Reg. 1/2025, in the five capacities listed in the Draft Regulation, will be deemed to hold a business license or approval from OJK under the Draft Regulation. It then sets staggered compliance deadlines of 6 months, 1 year, 2 years and 3 years after it takes effect, covering, among other things, product conformity, customer due diligence, risk management and governance, leverage limits, the anti-fraud strategy, minimum capital and infrastructure standards.
ABNR Commentary
The overall direction is continuity, not rupture: OJK is completing the transfer of authority mandated by the P2SK Law and begun under OJK Reg. 1/2025, and existing holders of approval in principle are deemed to hold a business license or approval under the Draft Regulation without having to reapply. The practical impact falls more heavily on firms that have not yet completed the approval-in-principle process under OJK Reg. 1/2025, on any business already engaged in or planning foreign order channeling (PALN), and on infrastructure providers that will need to meet the new capital requirements (and, for securities derivatives clearing institutions, the global-standards and qualifying central counterparty requirements) within the three-year transitional window.
We view the Draft Regulation as a meaningful attempt by OJK to establish a more comprehensive and structured regulatory framework for securities derivatives in Indonesia. This is evident in, among other things, the wider scope clause, broader product coverage, and clearer categorization of market participants and transaction mechanisms. OJK Reg. 1/2025 contains no express provision on PALN, whereas the Draft Regulation addresses it in several places. We appreciate OJK's effort to bring greater clarity to this area, though how the new framework plays out in practice will still benefit from further guidance, for example on the ratio for the PALN transaction cap, which the Draft Regulation does not specify.
This assessment is based on the Draft Regulation as currently published for consultation. Its provisions remain subject to revision following OJK's review and public feedback, and the final regulation may differ materially from this draft.
ABNR Counsellors at Law, with extensive experience advising participants and infrastructure providers in the Indonesian financial derivatives markets, in both OTC and exchange-traded contexts, continues to monitor this Draft Regulation closely. If you have any questions, please feel free to contact us.
TL;DR
Aspect | Details |
Instrument and status | Draft OJK regulation on Financial Derivatives with Underlying Assets in the Form of Securities (the Draft Regulation), published for public consultation. It remains a draft and may change. |
Effect on OJK Reg. 1/2025 | Once enacted, it replaces OJK Reg. 1/2025 (issued January 2025), the first step in transferring authority over financial derivatives from Bappebti to OJK and Bank Indonesia. |
Scope | The scope clause lists transactions, licensing, reporting and supervision, consumer protection, anti-money laundering and counter-terrorism and counter-proliferation financing measures, the anti-fraud strategy, exit policy mechanisms and coordination. |
Products | Product types now expressly include swaps and CFDs through an ATS, with eligibility criteria for the underlying. |
PALN | A new, detailed regime for channeling customer orders to foreign brokers |
Participants | Retains the existing participant structure while introducing dedicated representative categories, investor classifications, and more detailed obligations for market participants. |
Transitional | Holders of approval in principle under OJK Reg. 1/2025 are deemed to hold a business license or approval under the Draft Regulation. |
By partners Emir Nurmansyah (enurmansyah@abnrlaw.com), Chandrawati Dewi (cdewi@abnrlaw.com), Meitiara Bakrie (dbakrie@abnrlaw.com), and associate Gladyne Mesepy (gmesepy@abnrlaw.com)
This ABNR client alert is intended solely to provide a general overview, for informational purposes, of selected recent developments in Indonesian law. It does not constitute legal advice and should not be relied upon as such. ABNR accepts no liability of any kind in respect of any statement, opinion, view, error or omission that may be contained in this update. You are strongly advised to consult a licensed Indonesian legal practitioner before taking any action that could affect your rights and obligations under Indonesian law.
[1] A PPA (Penyelenggara Pasar Alternatif) is a party that operates and provides, or uses, an electronic system to match transactions in debt securities and/or sukuk among users on a continuous basis outside the stock exchange (Article 1(7) of OJK Reg. 1/2025; Article 1(19) of the Draft Regulation). Under the Draft Regulation, a PPA may also provide an electronic trading platform for securities derivatives outside the exchange (Article 43(2)(a)).
[2] An ATS is the alternative trading system regulated under the commodity futures trading law (Article 1(8) of OJK Reg. 1/2025; Article 1(20) of the Draft Regulation). An ATS organizer must be a Securities Derivative Trader and/or a PPE Derivatif Efek that operates and provides the ATS. To clarify with footnote #1 above, a PPA and an ATS organizer are separate categories of operators (Article 42A).
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NEWS DETAIL
22 Oct 2026
Indonesia's Financial Derivatives Market Awaits a New Regulation for Securities Underlying
Introduction
In January 2025, Indonesia's Financial Services Authority (Otoritas Jasa Keuangan or “OJK”) issued OJK Regulation No. 1 of 2025 on Financial Derivatives with Underlying Assets in the Form of Securities (“OJK Reg. 1/2025”), the first step in transferring regulatory and supervisory authority over financial derivatives from the Commodity Futures Trading Regulatory Agency (Badan Pengawas Perdagangan Berjangka Komoditi or “Bappebti”) to OJK and Bank Indonesia. That transfer was mandated by Law No. 4 of 2023 on the Development and Strengthening of the Financial Sector (as amended by Law No. 4 of 2026) (“P2SK Law”), which required the handover to be completed within 24 months. The recitals of the draft regulation discussed below describe OJK Reg. 1/2025 as the initial-stage legal basis for that process.
In August 2026, OJK published on its website a draft regulation on Financial Derivatives with Underlying Assets in the Form of Securities (“Draft Regulation”) for public consultation. Once enacted, the Draft Regulation will replace the currently effective OJK Reg. 1/2025 governing the same subject matter.
The Draft Regulation appears to expand and refine several provisions of OJK Reg. 1/2025. Although it remains a draft that has not yet been finalized and may be subject to further revision, this alert summarizes the changes currently proposed under the Draft Regulation.
Regulatory and Supervisory Scope
OJK Reg. 1/2025 limits the regulatory and supervisory scope for securities derivatives to the products, (business) actors, and operation of financial derivatives market infrastructure. However, the Draft Regulation lists the following subjects expressly in its scope clause:
securities derivatives transactions;
licensing;
reporting and supervision;
consumer protection;
implementation of anti-money laundering, counter-terrorism financing, and counter-proliferation financing measures relating to weapons of mass destruction;
implementation of the anti-fraud strategy;
exit policy mechanisms; and
coordination
Several of these subjects are not new in substance: OJK Reg. 1/2025 already covered supervision, reporting, consumer protection and licensing, although outside its scope clause.
The Draft Regulation also provides a detailed regime for channeling customer orders to foreign brokers (Penyaluran Amanat Luar Negeri, “PALN”), which OJK Reg. 1/2025 does not address.
Products
Development of New Products
Product approval itself is not new: OJK Reg. 1/2025 already required OJK approval for every traded product. What the Draft Regulation adds is a preliminary assessment step for market-initiated proposals and a separate process, with a report to OJK at least 10 working days before trading or participation starts, for expanding the underlying or participants of an existing product. Before a new securities derivative product may be traded, the relevant securities exchange or securities derivatives exchange, together with the relevant clearing institution, must obtain approval from the OJK. If the initiative to develop a new product originates from a market participant, the proposal must first be submitted to the relevant exchange and/or clearing institution for a preliminary assessment before being submitted to OJK for approval.
Types of Products
There are several changes to the types of products between OJK Reg. 1/2025 and Draft Regulation as may be seen below:
OJK Reg. 1/2025 | Draft Regulation |
Futures contracts, sharia derivative contracts, and/or other derivative contracts with the following underlying:
| Futures contracts over securities, which include:
with underlying securities issued in Indonesian or foreign jurisdictions. |
Options contracts on Securities | Options contracts on equity securities (equity options) with underlying securities issued in Indonesian or foreign jurisdictions. |
Other financial derivative contracts as determined by OJK. | Swap contracts on securities, which include:
with underlying securities issued in Indonesian or foreign jurisdictions. |
| Sharia securities derivative contracts with underlying securities issued in Indonesian or foreign jurisdictions |
| Other securities derivative contracts as determined by OJK, including:
with underlying securities issued in Indonesian or foreign jurisdictions. |
The Draft Regulation provides greater specificity regarding the types of securities derivatives that may be offered by expressly recognizing securities-based swap contracts and CFDs conducted through an ATS.[2] Further, the Draft Regulation specifies which securities may be used as underlying assets for securities derivatives and the criteria they must satisfy, including, (i) equity securities, (ii) foreign single stock, and, (iii) domestic debt securities..
A new PALN regime for channeling orders to foreign brokers
The Draft Regulation introduces a defined framework for PALN, the forwarding of customer orders to a foreign exchange or foreign broker for execution abroad. It provides some specific requirements for the foreign broker counterparty, as discussed below. Unlike OJK Reg. 1/2025, which contains no PALN provision, it sets out concrete eligibility criteria for the foreign brokers to which Indonesian intermediaries may forward orders.
The Draft Regulation also specifies similar conditions for tradable products and introduces additional requirements on the determination of reference prices and, where the underlying asset consists of foreign securities, on currency conversion.
Participants
The Draft Regulation generally adopts the same participant structure as OJK Reg. 1/2025, while introducing a more comprehensive framework specifically tailored to the securities derivatives activities. The Draft Regulation categorizes the participants into the following:
Securities Derivatives Broker-Dealers (Perantara Pedagang Derivatif Efek, “PPE Derivatif Efek”) which consists of:
Securities Broker Dealer (Perantara Pedagang Efek), being an OJK-licensed securities company that conducts business as a broker-dealer and is classified as PEKU 2 or PEKU 3 (Perusahaan Efek Kegiatan Usaha, the grouping of securities companies by business activity and capital);
Securities Derivative Trader, who has obtained a license from Bappebti as Futures Trader and a license as Securities Derivative Trader from OJK; and
Securities Derivative Broker, who has obtained a license from Bappebti as Futures Broker and a license as Securities Derivative Broker from OJK.
Securities Derivatives Investment Advisors (Penasihat Investasi Derivatif Efek) which consists of investment advisors or securities derivatives advisors;
Representatives of Securities Derivatives Market Participants (Wakil Pelaku Derivatif Efek) which consists of representatives of securities broker-dealers, representatives of securities derivatives broker-dealers, representatives of securities derivatives advisors and other representatives as may be determined by OJK;
Other parties holding a business license or approval from OJK; and
Investors which consist of professional and retail investors.
In the Draft Regulation, OJK introduces a dedicated category of representatives (wakil) and expressly classifies the categories of investors. The Draft Regulation also contains more detailed provisions governing market participants than OJK Reg. 1/2025. For example, OJK Reg. 1/2025 primarily regulates the obligations of Financial Securities Derivatives Broker-Dealers (Perantara Pedagang Efek Derivatif Keuangan). While the Draft Regulation contains similar provisions for Securities Derivatives Broker-Dealers, it goes further by also prescribing the obligations and prohibitions applicable to Securities Derivatives Investment Advisors, Representatives of Securities Derivatives Market Participants, and investors.
Specifically for PPE Derivatif Efek, depending on the type of entity, the scope of securities derivatives-related activities may vary:
Securities Broker Dealer (PEKU 3) | Securities Broker Dealer (PEKU 2) | Securities Derivative Trader | Securities Derivative Broker |
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|
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|
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|
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For Securities Broker Dealer and Securities Derivative Broker carrying out PALN activities, certain requirements must be fulfilled, including cooperating with licensed overseas broker with equity of > USD 1 billion.
Transactions
Draft POJK outlines the transaction mechanism for securities derivatives products as follows:
Mechanism | Contract Types | Eligible Investors | Remarks |
| |||
Multilateral (Exchange Traded Derivatives) | Futures contracts and option contracts, with underlying domestic or foreign securities and/or securities index | Professional and retail investors. | Retail investors must comply with the maximum leverage limit. |
Bilateral – through ATS Organizer | CFD | Professional investors.
Retail investors’ involvement will trigger a leverage limit (Article 71(b)). In our view, this appears inconsistent with Article 71(a), which allows only professional investors to transact CFDs through an ATS. Further clarification from OJK may be required. |
|
Bilateral – through PPA | Standardized securities derivatives contracts on securities tradable on the PPA | Professional and retail investors. | Retail investors must comply with the maximum leverage limit. |
Bilateral – between financial services institutions | Non-standardized securities derivatives contracts | Financial services institutions | Must use standard global derivatives documentation. |
| |||
PALN | Fractional contracts and futures contracts | Not explicitly specified.
The Draft Regulation applies the maximum leverage limit to retail investors, but the Draft Regulation does not state which categories of investors may use PALN, including whether professional investors may. Further clarification from OJK may be required.
| Requires cooperation with a foreign exchange or foreign broker.
Retail investors must comply with the maximum leverage limit.
Total PALN transaction value is capped relative to the total value of domestic buy transactions facilitated by the PPE Derivatif Efek (Article 74(6)); the Draft Regulation does not specify the ratio. |
Transitional Provisions
The Draft Regulation also contains transitional provisions. Holders of approval in principle (persetujuan prinsip) under OJK Reg. 1/2025, in the five capacities listed in the Draft Regulation, will be deemed to hold a business license or approval from OJK under the Draft Regulation. It then sets staggered compliance deadlines of 6 months, 1 year, 2 years and 3 years after it takes effect, covering, among other things, product conformity, customer due diligence, risk management and governance, leverage limits, the anti-fraud strategy, minimum capital and infrastructure standards.
ABNR Commentary
The overall direction is continuity, not rupture: OJK is completing the transfer of authority mandated by the P2SK Law and begun under OJK Reg. 1/2025, and existing holders of approval in principle are deemed to hold a business license or approval under the Draft Regulation without having to reapply. The practical impact falls more heavily on firms that have not yet completed the approval-in-principle process under OJK Reg. 1/2025, on any business already engaged in or planning foreign order channeling (PALN), and on infrastructure providers that will need to meet the new capital requirements (and, for securities derivatives clearing institutions, the global-standards and qualifying central counterparty requirements) within the three-year transitional window.
We view the Draft Regulation as a meaningful attempt by OJK to establish a more comprehensive and structured regulatory framework for securities derivatives in Indonesia. This is evident in, among other things, the wider scope clause, broader product coverage, and clearer categorization of market participants and transaction mechanisms. OJK Reg. 1/2025 contains no express provision on PALN, whereas the Draft Regulation addresses it in several places. We appreciate OJK's effort to bring greater clarity to this area, though how the new framework plays out in practice will still benefit from further guidance, for example on the ratio for the PALN transaction cap, which the Draft Regulation does not specify.
This assessment is based on the Draft Regulation as currently published for consultation. Its provisions remain subject to revision following OJK's review and public feedback, and the final regulation may differ materially from this draft.
ABNR Counsellors at Law, with extensive experience advising participants and infrastructure providers in the Indonesian financial derivatives markets, in both OTC and exchange-traded contexts, continues to monitor this Draft Regulation closely. If you have any questions, please feel free to contact us.
TL;DR
Aspect | Details |
Instrument and status | Draft OJK regulation on Financial Derivatives with Underlying Assets in the Form of Securities (the Draft Regulation), published for public consultation. It remains a draft and may change. |
Effect on OJK Reg. 1/2025 | Once enacted, it replaces OJK Reg. 1/2025 (issued January 2025), the first step in transferring authority over financial derivatives from Bappebti to OJK and Bank Indonesia. |
Scope | The scope clause lists transactions, licensing, reporting and supervision, consumer protection, anti-money laundering and counter-terrorism and counter-proliferation financing measures, the anti-fraud strategy, exit policy mechanisms and coordination. |
Products | Product types now expressly include swaps and CFDs through an ATS, with eligibility criteria for the underlying. |
PALN | A new, detailed regime for channeling customer orders to foreign brokers |
Participants | Retains the existing participant structure while introducing dedicated representative categories, investor classifications, and more detailed obligations for market participants. |
Transitional | Holders of approval in principle under OJK Reg. 1/2025 are deemed to hold a business license or approval under the Draft Regulation. |
By partners Emir Nurmansyah (enurmansyah@abnrlaw.com), Chandrawati Dewi (cdewi@abnrlaw.com), Meitiara Bakrie (dbakrie@abnrlaw.com), and associate Gladyne Mesepy (gmesepy@abnrlaw.com)
This ABNR client alert is intended solely to provide a general overview, for informational purposes, of selected recent developments in Indonesian law. It does not constitute legal advice and should not be relied upon as such. ABNR accepts no liability of any kind in respect of any statement, opinion, view, error or omission that may be contained in this update. You are strongly advised to consult a licensed Indonesian legal practitioner before taking any action that could affect your rights and obligations under Indonesian law.
[1] A PPA (Penyelenggara Pasar Alternatif) is a party that operates and provides, or uses, an electronic system to match transactions in debt securities and/or sukuk among users on a continuous basis outside the stock exchange (Article 1(7) of OJK Reg. 1/2025; Article 1(19) of the Draft Regulation). Under the Draft Regulation, a PPA may also provide an electronic trading platform for securities derivatives outside the exchange (Article 43(2)(a)).
[2] An ATS is the alternative trading system regulated under the commodity futures trading law (Article 1(8) of OJK Reg. 1/2025; Article 1(20) of the Draft Regulation). An ATS organizer must be a Securities Derivative Trader and/or a PPE Derivatif Efek that operates and provides the ATS. To clarify with footnote #1 above, a PPA and an ATS organizer are separate categories of operators (Article 42A).