The Indonesian Financial Services Authority (“OJK“) has issued OJK Board Member Regulation (Peraturan Anggota Dewan Komisaris or “PADK”) No. 3 of 2026 on the Operation of Digital Financial Asset Trading Including Crypto Assets (“PADK 3/2026“), which sets out updated technical guidelines and reporting formats for market participants in Indonesia’s digital financial asset and crypto asset industry. PADK 3/2026 was enacted on 30 June 2026 and takes effect on 1 September 2026.
PADK 3/2026 was issued to implement OJK Regulation No. 23 of 2025, which amends OJK Regulation No. 27 of 2024 on the Operation of Digital Financial Asset Trading Including Crypto Assets (“OJK Reg. 27/2024“). The amendment required adjustments to the mechanism and reporting formats applicable to digital financial asset trading operators. With the issuance of PADK 3/2026, OJK Circular Letter No. 20/SEOJK.07/2024 on the Operation of Digital Financial Asset Trading Including Crypto Assets (“SEOJK 20/2024“), which previously served as the main technical guidance under OJK Reg. 27/2024, is revoked, save for certain provisions subject to separate revocation dates.
In this article, we set out the key highlights of PADK 3/2026 and its interaction with SEOJK 20/2024.
1. Revocation of SEOJK 20/2024 and Transitional Arrangements: PADK 3/2026 revokes SEOJK 20/2024 in two stages. Specifically, the provisions under Section VI, points 6 and 7, and Appendix VIII, Part A, of SEOJK 20/2024 will be revoked with effect from 1 January 2027. Meanwhile, Section VI, points 1 to 5, and Appendix V of SEOJK 20/2024 were revoked with effect from 1 July 2026.
This staggered revocation means that digital financial asset trading operators (“Operators“) should closely track which specific provisions of SEOJK 20/2024 remain applicable and until when, to avoid relying on requirements that have already lapsed.
2. Streamlined Periodic Reporting Structure: PADK 3/2026 simplifies the periodic reporting structure previously set out under SEOJK 20/2024. Under SEOJK 20/2024, Operators were required to submit daily, monthly, quarterly, and annual reports. Under PADK 3/2026, the daily reporting obligation is no longer included in the periodic reporting structure, which now consists of monthly, quarterly, and annual reports (Appendix I, Section III.5.a of PADK 3/2026).
This is a welcome development for Operators, particularly Exchanges, Clearing Guarantee and Settlement Institutions, Custodians, and Traders, as it is expected to reduce the operational and administrative burden previously associated with daily report submissions.
3. Monthly Reports: PADK 3/2026 restructures the monthly reporting obligations by dividing them into financial and non-financial components for each type of Operator, namely Exchanges, Clearing Guarantee and Settlement Institutions, Custodians, and Traders (Appendix I, Section III.c.1 to 4) of PADK 3/2026).
Financial components consist of a statement of financial position, a profit and loss statement, and an administrative account form. The statement of financial position and administrative account form must reflect the closing balance as at the end of the relevant reporting month. In contrast, the profit and loss statement must reflect the cumulative balance from 1 January of the current year to the end of that month (Appendix I, Section III.5.c of PADK 3/2026).
Non-financial components may vary depending on the type of Operator. For Traders, these now expressly include, among others, a recapitulation of the 20 (twenty) largest consumers by transaction value, fund top-up value, fund withdrawal value, digital financial asset transfer-out value, and digital financial asset transfer-in value, as well as a recapitulation of over-the-counter (OTC) transactions and digital financial asset derivative transactions (Appendix I, Section III.5.c.4).a). (2) of PADK 3/2026).
Monthly reports must be submitted no later than 10 (ten) business days after the end of the relevant reporting period, consistent with the timeline previously set out under SEOJK 20/2024 (Appendix I, Section III.5.b.1) of PADK 3/2026.
4. Quarterly and Annual Reports: The quarterly reporting obligation continues to comprise a business plan realisation report and a risk management self-assessment report, to be submitted no later than 15 (fifteen) business days after the end of the relevant quarter. The annual reporting obligation continues to comprise an annual activity report and an annual financial report, to be submitted no later than 30 April of the following year (Appendix I, Sections III.5.b.2) and 3), III.5.d.1), and III.5.e.1) of PADK 3/2026).
Notably, PADK 3/2026 relaxes the publication requirement for the annual financial report. Under SEOJK 20/2024, Operators were required to publish their annual financial report in at least 2 (two) national daily newspapers, at least one of which had national circulation. Under PADK 3/2026, this obligation is replaced with publication on the Operator’s official website within 30 (thirty) days from the date of the relevant public accountant’s report (Appendix I, Section III.5.e.5 and 6 of PADK 3/2026).
In addition, the annual financial report must be prepared in accordance with the applicable Indonesian accounting standards and audited by a Public Accountant registered with OJK. Where the Public Accountant issues an audit opinion other than an unqualified opinion, OJK may summon the Operator’s Board of Directors and/or examine to obtain further information (Appendix I, Section III.5.e of PADK 3/2026).
5. Incidental Reports: Appendix I Section III.6 of PADK 3/2026 requires Operators to submit incidental reports in relation to various events, including changes in name or address, the opening of branch offices, or other offices outside the head office, additional paid-up capital, changes in ownership composition, the appointment of directors or commissioners who have obtained OJK approval, and irregular digital financial asset transactions. Other reports requested by OJK must also be submitted.
Incidental reports must be submitted no later than 5 (five) business days from the occurrence of the relevant event. They must be accompanied by supporting documents, as applicable, including relevant amendment deeds. For irregular digital financial asset transactions, the supporting documents include a chronology of events, an impact analysis, and mitigation measures (Appendix I, Sections III.6.a and III. 6.c of PADK 3/2026).
6. Reporting Channels and Fallback Mechanisms: Consistent with the approach under SEOJK 20/2024, reports and evaluation results under PADK 3/2026 must primarily be submitted online through the OJK Reporting System. Where the OJK Reporting System is unavailable or experiencing technical disruption, submissions may be made electronically or, as a last resort, offline by hand delivery or through a courier service, following a similarly tiered fallback mechanism to that under SEOJK 20/2024.
More specifically, where the OJK Reporting System is unavailable, submissions must be made by email to the OJK address designated for such circumstances. Where the system experiences technical disruption, submissions must instead be sent to a separate designated OJK email address, with the relevant OJK department copied. If the relevant OJK email service also experiences technical disruption, submissions may be made offline by direct delivery or through a courier service (Appendix I, Section IV of PADK 3/2026).
7. Evaluation of Digital Financial Assets in the List: PADK 3/2026 continues to require Exchanges to evaluate the digital financial assets included in the Digital Financial Asset List at least once every 3 (three) months and/or at any time. The results must be reported to OJK no later than 5 (five) business days from the date the evaluation is established, using the format under Appendix II, Part A of PADK 3/2026 (Appendix I, Section II.1 to 4 of PADK 3/2026).
In addition, Exchanges must appoint a member of their Board of Directors responsible for preparing and presenting the evaluation report. The report must be signed by the responsible Board member (Appendix I, Section II.5 and 6 of PADK 3/2026).
8. Notification of Derivative Transaction Clearing Activities: PADK 3/2026 introduces specific notification requirements for Clearing Guarantee and Settlement Institutions that support the clearing and settlement guarantee of digital financial asset derivative transactions. Such institutions must notify OJK in writing no later than 3 (three) business days before the commencement of trading in the relevant derivative transactions (Appendix I, Section V.1 of PADK 3/2026).
The notification must contain, at a minimum:
- an explanation of the clearing and settlement guarantee systems and/or facilities, risk management, information technology infrastructure, and operational arrangements;
- an organisational structure showing the reporting lines and responsibilities of the relevant functions, including the duties of the person in charge or the relevant Board member;
- evidence of system readiness, including a responsive, accurate and real-time Margin management system and an accurate, fair, transparent and integrated matching engine;
- a dedicated account for the clearing and settlement guarantee of the relevant derivative transactions; and
- standard operating procedures and a code of ethics.
The notification must follow the submission procedures applicable to evaluation reports, periodic reports, and incidental reports under Appendix I, Section IV of PADK 3/2026 (Appendix I, Section V.3 of PADK 3/2026).
Concluding Remarks
PADK 3/2026 reflects OJK’s continued efforts to refine the technical and reporting infrastructure that supports Indonesia’s digital financial asset and crypto asset ecosystem, building on the foundation established earlier under OJK Reg. 27/2024 and SEOJK 20/2024. While the core reporting obligations remain largely consistent in substance, the removal of the daily reporting requirement, the restructured monthly reporting components, and the relaxed annual financial report publication mechanism are expected to ease the administrative burden on Exchanges, Clearing Guarantee and Settlement Institutions, Custodians, and Traders.
Among the key changes introduced by PADK 3/2026 are the removal of daily periodic reporting, the restructuring of monthly reporting requirements, and the simplification of the annual financial report publication mechanism. PADK 3/2026 also sets out specific notification requirements for Clearing Guarantee and Settlement Institutions that support the clearing and settlement guarantee for digital financial asset derivative transactions.
Operators should nonetheless take note of the staggered revocation of SEOJK 20/2024, particularly the differing cut-off dates of 1 July 2026 and 1 January 2027 applicable to certain provisions, to ensure a smooth transition to the new reporting formats under PADK 3/2026 ahead of its effective date on 1 September 2026.
Disclaimer: The information herein is of general nature and should not be treated as legal advice, nor shall it be relied upon by any party for any circumstance. Specific legal advice should be sought by interested parties to address their circumstances.
