01 Jul 2026
Indonesia’s P2SK Law Amendment: What Law 4/2026 Changes for Crypto and Digital Financial Assets

Over the past few years, Indonesia's crypto and digital financial asset framework has moved from a commodities-based regime under Bappebti toward an OJK-supervised financial sector framework. That transition was mandated by Law No. 4 of 2023 on the Development and Strengthening of the Financial Sector, the omnibus law of the financial sector (the “P2SK Law”). OJK has since implemented the trading framework through OJK Regulation No. 27 of 2024 on the Trading of Digital Financial Assets including Crypto Assets, as amended by OJK Regulation No. 23 of 2025 (“OJK Reg. 27/2024”).¹ Law No. 4 of 2026, effective 17 June 2026 (the “Amendment” or “Law 4/2026”), further develops this architecture at primary-law level, including through a new statutory taxonomy of digital financial asset financial institutions.

The Amendment is an omnibus touching seventeen subject areas, from the institutional strengthening of the Deposit Insurance Agency (LPS), OJK and Bank Indonesia, to the expansion of bank business lines, stock-exchange demutualisation, transfer-of-title margin, and a new Indonesia International Financial Centre. Crypto and digital assets are one of those areas. This alert focuses only on the digital financial asset provisions and what they change for our clients.

The key digital financial asset changes

1.  Crypto firms become statutory “financial institutions.”

The Law introduces a new taxonomy: Digital Financial Asset Financial Institutions (Lembaga Jasa Keuangan Aset Keuangan Digital / “LJK AKD”), comprising Crypto-Asset Financial Institutions (LJK Aset Kripto) and Digital Financial Asset Institutions other than Crypto (LJK AKD selain Aset Kripto). Why it matters: crypto is brought squarely within OJK's “financial services institution” regime, carrying the governance, fit-and-proper test, consumer-protection and prudential expectations that attach to regulated financial institutions.

2.  A statutory category for stablecoins and tokenised assets: the one to watch.

The Law expressly recognises a class of “digital financial assets other than crypto assets,” with its own exchange, traders, clearing-and-settlement institutions and custodians. The Amendment further materially expands the statutory description of crypto and digital financial asset activities not only stablecoins and tokenisation, but also initial offerings, staking, crypto-asset-based lending and borrowing, crypto as collateral (gadai aset kripto), spot transactions, derivatives and other crypto-underlying activities. This does not mean, however, that the Amendment gives a complete classification rule for every digital-asset structure: product-by-product analysis remains necessary and expected to be shaped by the OJK implementing regulations to follow. Importantly, while a stablecoin may be used as a means of transaction (after a recommendation from the exchange and OJK approval), it cannot be used as a means of payment: the amended elucidation expressly provides that a stablecoin cannot serve as a direct means of payment, and that its use as a means of transaction is not construed as use as a means of payment. It should therefore never be described as a lawful means of payment in Indonesia.

3.  OJK board-level crypto supervision is retained

Law 4/2026 retains the OJK Board-level supervisory function for ITSK (Technological Innovation in the Financial Sector),² digital financial assets and crypto assets that already existed under the previous regime, and separately introduces a new Chief Executive for the Mineral and Strategic Commodity Exchange.

4.  The market structure was already named at regulation level.

The existing OJK trading framework already names the core trading infrastructure: crypto exchanges (bursa), traders (pedagang), clearing-and-settlement institutions and centralised custodians, and Law 4/2026 now sits above that framework as part of the primary-law architecture. The term “issuers”³ also appears, aligning with the OJK draft offering regime.

5.  Stated policy direction: transparency, consumer protection and competitiveness.

The Government framed the crypto provisions as strengthening the transparency, disclosure, consumer protection and global competitiveness of Indonesia's crypto industry, a notably pro-industry tone, consistent with OJK's recent steps on derivatives and offerings.

6.  The implementing regulations are still to come.

The Law sets the architecture; it does not, by itself, change day-to-day licensing or conduct obligations. Further OJK implementing regulations to align with the new Law are expected for areas not yet fully addressed. Timing is not yet fixed and, until those rules land, the existing OJK frameworks continue to govern. We will follow up as the OJK regulations emerge.

ABNR commentary

For players that are already licensed or building toward a licence, this is continuity rather than rupture: the Amendment cements the regime they are already preparing for. The genuinely new development is forward-looking; an express statutory category for digital financial assets other than crypto opens a clearer path for stablecoins and tokenisation, the segments where much of the market's ambition now sits.

Where an activity constitutes a regulated onshore trading or public-offering activity in Indonesia, local licensing and local-incorporation requirements are likely to be triggered. Foreign participants' regulatory exposure should be analysed by activity, audience, distribution channel and product structure. The specific requirements applicable to a foreign entity, including whether a locally incorporated PT and Indonesian leadership are required, will depend on the nature of the regulated activity and should be confirmed once the draft offering regulation is enacted in final form.

TL;DR

By partners Mr. Emir Nurmansyah (enurmansyah@abnrlaw.com), Ms. Chandrawati Dewi (cdewi@abnrlaw.com), Ms. Monic Devina (mdevina@abnrlaw.com), and Ms. Meitiara Bakrie (dbakrie@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   Read our coverage: “Indonesia – Starting Off the Year With a New Era for Crypto Trading Under OJK's Helm” — abnrlaw.com/news/indonesia-starting-off-the-year-with-a-new-era-for-crypto-trading-under-ojks-helm; and “Indonesia Greenlights Crypto Derivatives: A Look at the New OJK Framework” — abnrlaw.com/en/news/indonesia-greenlights-crypto-derivatives-a-look-at-the-new-ojk-framework

2   See our coverage: “Indonesia’s FSA Amends Fintech ‘Sandbox’ and Licensing Rules, Prepares for New Crypto-Asset Regulatory Role” — https://www.abnrlaw.com/news/indonesias-fsa-amends-fintech-sandbox-and-licensing-rules-prepares-for-new-crypto-asset-regulatory-role   

3   See our coverage: “At Long Last: Indonesia Is Set to Issue a Landmark Crypto Offering Regime” — abnrlaw.com/en/news/at-long-last-indonesia-is-set-to-issue-a-landmark-crypto-offering-regime