On 17 June 2026, the Indonesian government enacted Law No. 4 of 2026 to amend Indonesia's Financial Services Omnibus Law (Law No. 4 of 2023) (the 2026 Financial Services Omnibus Law). Among the most significant reforms introduced by the 2026 Financial Services Omnibus Law is a series of targeted enhancements to the legal framework governing the digital asset industry including crypto assets, which are expected to increase the attractiveness and competitiveness of the Indonesian digital assets sector and strengthen the public's trust in the sector.

In this legal update, we explain how the 2026 Financial Services Omnibus Law reshapes Indonesia's digital asset and cryptocurrency framework. We will also discuss a new regulation issued by Indonesia's Financial Services Authority (Otoritas Jasa Keuangan or OJK) setting out a new reporting framework for digital financial asset operators.

Key changes

Crypto and digital asset operators' financial services institutions status

The 2026 Financial Services Omnibus Law creates two categories of financial services institutions: Crypto Asset Financial Services Institutions (LJK Aset Kripto) and Financial Services Institutions for Digital Financial Assets other than Crypto Assets (LJK AKD selain Aset Kripto). Previously, digital asset players were not formally classified as financial services institutions (Lembaga Jasa Keuangan or LJK) although they have been subject to key financial services sector requirements, including licensing, fit-and-proper test assessments, anti-money laundering controls, consumer protection, and anti-fraud measures.  

Path to recognition of wider range of crypto asset activities

The 2026 Financial Services Omnibus Law contains several examples of digital asset activities that fall within the category of financial sector technological innovation (Inovasi Teknologi Sektor Keuangan or ITSK). These include tokenisation, initial offering, use of stablecoins as transaction instruments, staking, and crypto-based lending and pledging. Interestingly, the payment system activities that fall under ITSK now include the use of crypto assets as transaction instruments, fund sources, and underlying transactions in relation to payment in IDR or foreign currencies.

The 2026 Financial Services Omnibus Law states that stablecoins cannot be used directly as payment instruments, noting that their use as transaction instruments does not mean they are recognised as payment instruments.

The next development to watch will be OJK’s implementing regulations on this topic, and any amendments to Bank Indonesia's payment regulations, which currently prohibit the use of virtual currencies in payment transaction processing. 

Increased oversight of non-compliant crypto activity

The 2026 Financial Services Omnibus Law gives OJK the authority, in coordination with relevant ministries and agencies, to freeze or block crypto and other digital asset transactions and trading that violate Indonesian law. This power covers both the activities of domestic and foreign parties within Indonesia and the offering of crypto and digital assets to Indonesian citizens or legal entities.

The reference to foreign parties gives this measure clear cross-border reach. OJK may therefore act against non-compliant activity involving Indonesian users even where the operator has no physical presence in Indonesia.

The 2026 Financial Services Omnibus Law also imposes criminal sanctions on any party conducting business as a Crypto-Asset Financial Services Institution or Financial Services Institution for Digital Financial Assets other than Crypto Assets without an OJK business licence. The offence carries up to ten years’ imprisonment and/or a maximum fine of IDR50 billion (category VIII).

Insider trading and market manipulation

The 2026 Financial Services Omnibus Law introduces market-manipulation and insider-trading prohibitions for crypto activities. Prohibited conduct includes making false or misleading statements that influence prices, creating a false appearance of market activity, artificially moving or maintaining prices, trading on inside information or encouraging other parties to transact using that information.

Crypto institutions and other parties involved in crypto-asset offerings are also prohibited from providing false or fabricated documents or information. Breaches may attract up to five years’ imprisonment and/or a maximum fine of IDR50 billion (category VIII).

OJK takes control of crypto bankruptcy filings

The 2026 Financial Services Omnibus Law makes OJK the sole party authorised to file bankruptcy or suspension of debt payment obligations (penundaan kewajiban pembayaran utang or PKPU) proceedings against crypto-asset traders, bourses (bursa), clearing and settlement institutions, central custodians and issuers. Creditors, consumers and other third parties can therefore no longer commence bankruptcy or PKPU proceedings directly against those entities.

The same applies to equivalent institutions dealing with digital financial assets other than crypto assets, and to certain other OJK-supervised financial institutions. An explanatory note states that this centralised approach is intended to strengthen public confidence, given the role these institutions play in collecting, channelling and managing consumer and public funds.

New reporting framework for digital financial asset trading

Separately, OJK has issued Board of Commissioners Regulation No. 3 of 2026 on the Operation of Digital Financial Asset Trading Including Crypto Assets (PADK 3/2026), which introduces a revised reporting framework for digital financial asset operators. PADK 3/2026 replaces the reporting regime established under OJK Circular Letter No. 20/SEOJK.07/2024 (SEOJK 20/2024) and simplifies certain obligations by removing the requirement to submit annual business plans and consolidating periodic reporting into monthly, quarterly and annual submissions.

At the same time, PADK 3/2026 expands the scope of reporting to cover digital asset derivative transactions, an area not previously addressed. Clearing houses must now submit written notifications to OJK at least three working days before commencing any clearing activities for crypto asset derivative transactions. PADK 3/2026 also introduces new reporting forms to accommodate the broader scope of digital financial asset activities, including a dedicated framework for crypto asset derivative transactions covering consumer's leverage levels, position data, and margin activity.

PADK 3/2026 took effect on 1 September 2026, at which time SEOJK 20/2024 will be revoked. However, the obligation to submit business plans ceases on 1 July 2026.

Transitional provisions and key deadlines

The changes introduced by the 2026 Financial Services Omnibus Law generally came into effect on 17 June 2026, subject to certain transitional provisions.

Notably, bourses (bursa) for crypto assets and other digital financial assets are given one year (ie until 17 June 2027) to institute trading facilities and bring together third-party buy and sell orders.

Existing implementing regulations remain in force during the transition to the extent they do not conflict with the 2026 Financial Services Omnibus Law.

Key takeaway

The 2026 Financial Services Omnibus Law strengthens Indonesia’s crypto and digital asset framework while opening up opportunities for new business models and products. Market players should look out for the implementing regulations issued by OJK and Bank Indonesia to clarify how these changes will be implemented.

This bulletin is part of a series of legal updates on the 2026 Financial Services Omnibus Law. Please contact us if you have any questions about the implications of these changes for your business.

Michelle Virgiany photo

Michelle Virgiany

Partner, Herbert Smith Freehills Kramer Prolegis Alliance, Singapore

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Michelle Virgiany photo

Michelle Virgiany

Partner, Herbert Smith Freehills Kramer Prolegis Alliance, Singapore

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Financial services Michelle Virgiany