Intelligence Brief: On December 4, 2025, OJK issued POJK No. 23/2025 amending POJK 27/2024—expanding the legal perimeter of Digital Financial Assets (AKD) to cover not only crypto assets, but also other DFAs and DFA derivatives. This is the moment Indonesia’s digital-asset market stops looking like “spot-only retail trading” and starts behaving like a regulated financial market: listed products, venue governance, margin controls, and investor suitability gates.
01. The Reframe: “AKD” Becomes a Product Class
POJK 23/2025 explicitly defines Aset Keuangan Digital as a broader class: crypto assets plus other DFAs (including DFA derivatives). The practical effect is simple: the market can evolve beyond spot trading—but only inside a regulated perimeter.
Key Operating Rule
Trading organizers are prohibited from facilitating DFAs that are not on the Exchange-issued Digital Financial Asset List. This creates a hard gate: no “listing-by-hype”, no shadow markets, no off-book products.
02. Derivatives: Allowed — But Gated
Derivatives are not “banned” or “free”. They are allowed with explicit approvals and consumer safeguards. In other words: OJK is opening the door, but installing a metal detector.
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Exchange Approval Required If the Exchange runs DFA derivatives, it must request OJK approval first (venue-level gate).
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Margin Segregation (Consumer Protection) Operators must implement mechanisms to place margin in a dedicated account (cash or DFA), preventing commingling and “balance-sheet” risk.
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Knowledge Tests Before Derivatives Consumers must pass a knowledge test before accessing DFA derivatives—an explicit attempt to reduce retail blow-ups.
03. Second-Order Effects: Winners and Costs
This is “clean market” architecture: better integrity, but higher fixed costs. Expect the ecosystem to consolidate around players who can afford compliance, cyber, surveillance, and product governance.
Likely Winners
Licensed exchanges, brokers, and custodians with strong governance. Institutional desks prefer regulated venues with clear product lists, margin rules, and enforceable consumer protections.
Likely Pain Points
Smaller operators and “feature factories” (leveraged products, aggressive staking wrappers) face longer launch cycles and tighter approval gates—innovation becomes permissioned.
Analyst Outlook
"POJK 23/2025 is OJK signaling a mature market design: curated listings, governed venues, and controlled derivatives. The bet is simple—if Indonesia wants institutional digital assets, it must look like a real market. Expect 2026 to be a licensing and consolidation year: fewer players, stronger rails, higher trust."