Self-custodial wallet / non-custodial software in Indonesia
Publisher of software where users hold their own private keys. The publisher never holds, controls, or has access to user funds.
Self-custodial wallet is conditionally permitted in Indonesia without local incorporation, subject to AML obligations and none licensing burden.
Verdict Details
- Permitted
- conditional
- Local entity required
- No
- Licensing burden
- None
- Last updated
- 2026-07-13
AML Obligations
- None — non-custodial wallet software publishing does not trigger VASP/licensing obligations under current Indonesian regulations (OJK/Bappebti frameworks target exchanges, custodians, and traders holding or controlling crypto assets).
- If the software is distributed via a mechanism involving custody, exchange, or trading services, those additional activities would trigger AML obligations under OJK Regulation No. 27/2024 and PPATK supervision.
Key Restrictions
- Cannot use the software to process crypto payments — Currency Law prohibits crypto payments; rupiah is sole legal tender (BI enforcement).
- If the publisher also offers any custodial, exchange, or trading features alongside the wallet software, VASP licensing with OJK would be required (6-12 months, IDR 50B+ capital under prior Bappebti regime; OJK requirements being finalized).
- No restriction on mere software distribution — publishing open-source or commercial non-custodial wallet software does not constitute a regulated activity under current rules.
Key Risks
- Regulatory ambiguity: OJK's post-January 2025 framework is still being finalized; the 'same activity, same risk, same regulation' principle could theoretically be extended to non-custodial wallet publishers in the future.
- Enforcement risk if software includes any features that could be construed as facilitating crypto payments (prohibited by Currency Law).
- Data privacy risk: Indonesian authorities (Kominfo) actively scrutinize data practices in crypto/biometric projects (Worldcoin precedent). Wallet publishers collecting any user telemetry or data could face consumer-protection scrutiny under OJK No. 27/2024.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
VASP: VASP Registration/License with OJK (post-Jan 2025 transfer). Previously IDR 50B (~$3.2M USD) minimum capital under Bappebti. OJK requirements being finalized. Must establish Indonesian entity (PT). 6-12 months.
CUSTODY: Included under VASP license; customer asset segregation required
EXCHANGE: Physical trader registration. National crypto bourse (Bursa Kripto Indonesia) launched 2023. Islam-related considerations (MUI halal debate) affect adoption.
OJK — Financial services authority — VASP oversight (from Jan 2025)
Bappebti — Former crypto commodity regulator (authority transferred to OJK Jan 2025)
Financial Services Authority (OJK): Primary regulator since January 10, 2025, supervising trading, exchanges, settlement, clearinghouses, custodians, and asset dealers. It enforces licensing, governance, capital requirements, KYC/AML, and a "same activity, same risk, same regulation" principle aligned with global standards.
Bank Indonesia (BI): Central bank enforcing the Currency Law, prohibiting crypto use for payments and upholding the rupiah as sole legal tender.
Currency Law: Prohibits crypto payments; rupiah-only legal tender (pre-2017 BI ban on payments).
OJK Regulation No. 27 of 2024: Classifies crypto as digital financial assets; mandates compliance on capital, consumer protection, and AML by July 2025. Effective post-January 2025 transition.
Case Context: Kominfo probed Worldcoin's data practices amid global concerns (e.g., similar actions in Kenya, Germany). Emphasized protecting digital rights under Indonesian law.
POJK 27/2024: OJK rules on DFA trading, storage, risk, consumer protection (covers exchanges/custodians/traders). [https://www.legal500.com/guides/chapter/indonesia-blockchain-crypto-assets/?export-pdf]
POJK on ITSK Implementation (Article 23): Licensing for tech innovation/DFA providers via OJK. [https://ojk.go.id/en/fungsi-utama/itsk/perizinan-itsk-aset-keuangan-digital-aset-kripto/default.aspx]
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- medium
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Conditional — publishing non-custodial wallet software in Indonesia does not trigger VASP licensing or AML obligations (since no custody or control of user funds), but any payment-related features are prohibited under the Currency Law, and the regulatory landscape is evolving under OJK's new oversight framework.
Questions this verdict aims to answer
- Does software publishing trigger VASP / MSB classification?
- Do AML obligations attach when no custody exists?
- What disclosure or consumer-protection rules apply?