From 7f9da3f4d6c19591c1a6b689b67e5ab0b37974a9 Mon Sep 17 00:00:00 2001 From: M Zidan Fatonie Date: Sun, 2 Aug 2026 00:09:21 +0700 Subject: [PATCH 1/2] feat(jurisdiction): add Indonesia OJK and Singapore MAS cards Gives the map its first ASEAN coverage, alongside the existing Hong Kong and China cards. Indonesia: supervision moved from Bappebti to OJK on 10 January 2025, crypto reclassified as a digital financial asset under POJK 27/2024 as amended by POJK 23/2025, with Law No. 4 of 2026 raising the taxonomy to primary law. The card leads on the listing criterion that requires traceability and bars assets whose features conceal ownership or transaction information, which is a direct restriction on on-chain confidentiality in a G20 market. Singapore: DTSP regime under the FSM Act live since 30 June 2025 with no transition window. The single-currency stablecoin framework is recorded as finalised policy that is not yet in force, since the implementing legislation has not been introduced in Parliament. --- CHANGELOG.md | 2 ++ jurisdictions/id-OJK.md | 33 +++++++++++++++++++++++++++++++++ jurisdictions/sg-MAS.md | 32 ++++++++++++++++++++++++++++++++ 3 files changed, 67 insertions(+) create mode 100644 jurisdictions/id-OJK.md create mode 100644 jurisdictions/sg-MAS.md diff --git a/CHANGELOG.md b/CHANGELOG.md index 3f29a37..e5207ee 100644 --- a/CHANGELOG.md +++ b/CHANGELOG.md @@ -4,6 +4,8 @@ All notable changes to the EthSystems Map are documented here. ## [Unreleased] +- feat(jurisdiction): [Indonesia / OJK (Digital Financial Assets)](jurisdictions/id-OJK.md) and [Singapore / MAS](jurisdictions/sg-MAS.md) -- adds ASEAN coverage, including the POJK 27/2024 listing criterion that bars assets whose features conceal ownership or transaction information + ## [0.4.0] - 2026-07-02 23 commits, 166 files changed since [v0.3.0](https://github.com/ethsystems/map/releases/tag/v0.3.0) (Apr 2026). Major additions: resilience use cases (civic participation, disbursement rails, identity continuity), I2U protection patterns, pattern/approach schema v2 (strict flip) with CROPS and post-quantum analysis, domain reframing beyond FIs, and a Q2 2026 content QA audit. diff --git a/jurisdictions/id-OJK.md b/jurisdictions/id-OJK.md new file mode 100644 index 0000000..66aca50 --- /dev/null +++ b/jurisdictions/id-OJK.md @@ -0,0 +1,33 @@ +--- +title: "Jurisdiction: Indonesia / OJK (Digital Financial Assets)" +status: ready +region: APAC +scope: + entities: [exchanges, traders, clearing institutions, custodians, issuers] + activities: [trading, custody, clearing, settlement, issuance] +key-regulations: + - P2SK Law (Law No. 4 of 2023) + - POJK 27/2024 as amended by POJK 23/2025 + - Law No. 4 of 2026 +last_reviewed: 2026-08-02 +--- + +> Developer orientation. Not legal advice. + +## At a Glance + +Regulatory authority over crypto assets moved from the commodity futures regulator, Bappebti, to the financial services authority, OJK, with effect from 10 January 2025 under Government Regulation 49/2024. The reclassification is the substantive change: crypto is no longer a tradable commodity but a "digital financial asset" inside the financial services perimeter, governed by POJK 27/2024 as amended by POJK 23/2025, which closed the transition phase in January 2026. Law No. 4 of 2026, effective 17 June 2026, raises that taxonomy to primary law. The point that matters for privacy engineering is a listing criterion: POJK 27/2024 requires traded assets to be traceable and bars assets whose features conceal ownership or transaction information. Indonesia is therefore permissive toward tokenised finance and explicitly restrictive toward on-chain confidentiality. Crypto also remains prohibited as a payment instrument, because the Currency Law makes the rupiah sole legal tender. + +## What to Watch + +- A draft OJK regulation on digital financial asset offerings would establish a primary market and issuance regime. +- How the anti-concealment listing criterion is read against privacy-preserving L2s and shielded pools, as distinct from privacy coins, remains unsettled. +- Industry pressure to recognise stablecoins for payments runs against the Currency Law restriction. +- Derivatives, segregated accounts, and licensing thresholds were all touched by the POJK 23/2025 amendments. + +## See also + +- [Digital Financial Assets and Crypto Assets – OJK](https://ojk.go.id/en/fungsi-utama/itsk/informasi-iakd/publikasi-dan-kajian/default.aspx) +- [Jurisdiction: Singapore / MAS](./sg-MAS.md) +- [Jurisdiction: Hong Kong SAR (HK)](./hk-crypto-licensing.md) +- [Jurisdiction: China (CN)](./cn-crypto-ban.md) diff --git a/jurisdictions/sg-MAS.md b/jurisdictions/sg-MAS.md new file mode 100644 index 0000000..0ef02f8 --- /dev/null +++ b/jurisdictions/sg-MAS.md @@ -0,0 +1,32 @@ +--- +title: "Jurisdiction: Singapore / MAS" +status: ready +region: APAC +scope: + entities: [DPT service providers, DTSPs, stablecoin issuers, custodians, exchanges] + activities: [trading, custody, stablecoins, cross-border transfers, tokenisation] +key-regulations: + - Payment Services Act 2019 + - Financial Services and Markets Act 2022 (DTSP regime) + - MAS Single-Currency Stablecoin framework (2023) +last_reviewed: 2026-08-02 +--- + +> Developer orientation. Not legal advice. + +## At a Glance + +Singapore is permissive toward digital asset activity and heavily licensed in how it permits it. Digital payment token services fall under the Payment Services Act 2019, and since 30 June 2025 a separate Digital Token Service Provider regime under the Financial Services and Markets Act 2022 has captured Singapore-incorporated firms serving customers wholly outside Singapore. That regime commenced without a transition window, and MAS indicated it would rarely license firms whose substantive activity sits entirely abroad, because it cannot supervise them. The stablecoin position is easy to overstate: MAS finalised the policy features of its single-currency stablecoin framework in August 2023, covering tokens pegged to the Singapore dollar or a G10 currency, but the implementing legislation has not yet been introduced in Parliament, so the "MAS-regulated stablecoin" label has no statutory basis yet. Tokenisation pilots run in parallel, including tokenised MAS bills settled in wholesale central bank digital currency. + +## What to Watch + +- The stablecoin bill and an expected public consultation, which determine when the single-currency framework acquires legal force. +- Treatment of tokens that fall outside the single-currency scope, including foreign-issued and multi-currency stablecoins, which stay under the general digital payment token rules. +- Travel rule application to transfers involving unhosted wallets. +- Whether wholesale central bank digital currency settlement pilots produce durable market infrastructure. + +## See also + +- [Monetary Authority of Singapore](https://www.mas.gov.sg/) +- [Jurisdiction: Indonesia / OJK (Digital Financial Assets)](./id-OJK.md) +- [Jurisdiction: Hong Kong SAR (HK)](./hk-crypto-licensing.md) From 16c5a428dff7e52c024ac5c421766e7a741eb32b Mon Sep 17 00:00:00 2001 From: M Zidan Fatonie Date: Sun, 2 Aug 2026 09:35:50 +0700 Subject: [PATCH 2/2] docs: reference PR number in CHANGELOG entry --- CHANGELOG.md | 2 +- 1 file changed, 1 insertion(+), 1 deletion(-) diff --git a/CHANGELOG.md b/CHANGELOG.md index e5207ee..c4e1203 100644 --- a/CHANGELOG.md +++ b/CHANGELOG.md @@ -4,7 +4,7 @@ All notable changes to the EthSystems Map are documented here. ## [Unreleased] -- feat(jurisdiction): [Indonesia / OJK (Digital Financial Assets)](jurisdictions/id-OJK.md) and [Singapore / MAS](jurisdictions/sg-MAS.md) -- adds ASEAN coverage, including the POJK 27/2024 listing criterion that bars assets whose features conceal ownership or transaction information +- feat(jurisdiction): [Indonesia / OJK (Digital Financial Assets)](jurisdictions/id-OJK.md) and [Singapore / MAS](jurisdictions/sg-MAS.md) -- adds ASEAN coverage, including the POJK 27/2024 listing criterion that bars assets whose features conceal ownership or transaction information ([#182](https://github.com/ethsystems/map/pull/182)) ## [0.4.0] - 2026-07-02