Stablecoin issuer / redeemer in Indonesia
Issues a fiat-pegged stablecoin to the public, operates redemption, and holds reserves backing the float.
Stablecoin issuer is conditionally permitted in Indonesia with a local entity, subject to AML obligations and high licensing burden.
Verdict Details
- Permitted
- conditional
- Local entity required
- Yes
- Licensing burden
- High
- Last updated
- 2026-07-13
AML Obligations
- Mandatory robust AML/KYC systems including customer identification, transaction monitoring, cryptographic protocols, and security controls (id.licensing.amlkyc-mandatory-robust-systems-including)
- Reporting of Suspicious Transaction Reports (STRs) within 3 working days and Currency Transaction Reports (CTRs) to PPATK (id.aml.receiving-and-analyzing-strs-within)
- Conducting risk assessments and supporting national AML strategies (id.aml.conducting-risk-assessments-and-supporting)
- Compliance with OJK Regulation No. 27/2024 AML mandates, capital requirements, and consumer protection rules by July 2025 (id.aml.ojk-regulation-no-27-of)
- OJK enforces licensing, governance, capital requirements, KYC/AML under a 'same activity, same risk, same regulation' principle (id.aml.financial-services-authority-ojk-primary)
- Adherence to PPATK guidelines for suspicious transactions and compliance (id.aml.issuing-guidelines-for-suspicious-transactions)
Key Restrictions
- Crypto cannot be used as a payment instrument — Currency Law prohibits crypto payments; rupiah is sole legal tender (id.aml.currency-law-prohibits-crypto-payments)
- Bank Indonesia prohibits crypto for payments (id.aml.bank-indonesia-bi-central-bank)
- Must establish an Indonesian entity (PT/PT PMA) with local directors, business plans, and technical infrastructure readiness (id.licensing.local-presence-indonesian-incorporation-eg)
- Must pass OJK sandbox or direct licensing (6-12 months estimated timeline) (id.licensing.vasp)
- A OJK whitelist of 29 licensed digital asset platforms exists; unlisted operators restricted (id.aml.ojk-regulation-no-232025-introduces)
- 0.21% final income tax (PPh 22 Final) on gross transaction value for domestic exchanges, collected by approved exchanges (id.tax)
- VAT at 12% applies to exchange services/commissions; crypto-to-crypto trades may be VAT-taxable under 2025 rules (id.tax.vat-12-up-from-11)
Key Risks
- No explicit stablecoin-specific framework exists — stablecoin issuance is not directly addressed by current crypto-asset regulations, creating legal classification ambiguity
- Stablecoin issuance may be interpreted as e-money issuance (requiring BI licensing) or unlicensed deposit-taking, creating material regulatory and criminal risk
- Currency Law prohibits crypto payments, which may conflict with the payment-use case of stablecoins
- Regulatory transition from BAPPEBTI to OJK (Jan 2025) means OJK requirements for VASP licensing are still being finalized, creating timeline uncertainty
- MUI halal debate on crypto creates reputational and PR risk for local adoption (id.licensing.exchange)
- OJK's POJK 27/2024 and POJK 23/2025 impose asset whitelisting and user testing requirements that may not contemplate stablecoins as a distinct asset class
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.
OJK — Financial services authority — VASP oversight (from Jan 2025)
Local Presence: Indonesian incorporation (e.g., via Ministry of Investments portal); local directors, business plans proving viability, and technical infrastructure readiness.
AML/KYC: Mandatory robust systems, including customer identification, transaction monitoring, cryptographic protocols, and security controls; integrated into operating procedures.
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.
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.
OJK Regulation No. 23/2025: Introduces a whitelist of 29 licensed digital asset platforms/exchanges; restricts unlisted operators, requires segregated margin accounts, user knowledge tests for derivatives, and approved asset listings.
Currency Law: Prohibits crypto payments; rupiah-only legal tender (pre-2017 BI ban on payments).
Bank Indonesia (BI): Central bank enforcing the Currency Law, prohibiting crypto use for payments and upholding the rupiah as sole legal tender.
Receiving and analyzing STRs (within 3 working days) and CTRs.
Conducting risk assessments and supporting national AML strategies.
Issuing guidelines for suspicious transactions and compliance.
Capital: As above; OJK enforces ongoing equity maintenance and can demand extras.
Other: Risk management, consumer protection, periodic/incidental reporting to OJK; NIB (Business ID) and KBLI 62014 for blockchain activities.
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]
Evidence fact id.tax not found (may have been renamed).
Trading gains and sales are subject to final income tax (PPh 22 Final) at 0.21% of the gross transaction value for domestic exchanges (up from 0.1%, effective around August 2025).
VAT (12%, up from 11%) applies to exchange services (commissions/fees), with base at 11/12 of fees to maintain effective burden; miners face 2.2% VAT.
EXCHANGE: Physical trader registration. National crypto bourse (Bursa Kripto Indonesia) launched 2023. Islam-related considerations (MUI halal debate) affect adoption.
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- low
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Conditional — stablecoin issuance is not explicitly regulated under Indonesia's crypto-asset framework (post-transition to OJK), and attempting it under a VASP license carries high uncertainty because the model may be treated as unlicensed e-money issuance or unauthorized payment instrument activity, with no clear reserve, redemption, or segregation rules specifically for stablecoins.
Questions this verdict aims to answer
- What e-money or banking license is required to issue?
- What reserve composition, segregation, and audit rules apply?
- What redemption rights must be granted to holders?
- Are foreign-issued stablecoins permitted for use locally?