Regulation of the Commodity Futures Trading Regulatory Agency Number 4 of 2025 Concerning Technical Guidelines for Approval Procedures as a Warehouse Receipt Registration Center

REGULATION OF THE COMMODITY FUTURES TRADING REGULATORY AGENCY REPUBLIC OF INDONESIA NUMBER 4 OF 2025 CONCERNING TECHNICAL GUIDELINES FOR THE APPROVAL PROCEDURE AS A REGISTRATION CENTER IN THE WAREHOUSE RECEIPT SYSTEM BY THE GRACE OF GOD THE ALMIGHTY

HEAD OF THE COMMODITY FUTURES TRADING REGULATORY AGENCY REPUBLIC OF INDONESIA,

Considering: a. in order to realize an institutional ecosystem in the Warehouse Receipt System that is transparent, efficient, effective, competitive, and trustworthy, while simultaneously increasing the effectiveness of supervision in the implementation of Warehouse Receipt System activities, it is necessary to establish procedures to obtain approval as a Registration Center; b. that based on considerations as referred to in letter a, it is necessary to establish a Regulation of the Commodity Futures Trading Regulatory Agency concerning Technical Guidelines for the Approval Procedure as a Registration Center in the Warehouse Receipt System;

Recalling: 1. Law Number 9 of 2006 concerning the Warehouse Receipt System (State Gazette of the Republic of Indonesia Year 2006 Number 59, Supplement to the State Gazette of the Republic of Indonesia Number 4630) as amended by Law Number 9 of 2011 concerning Amendments to Law Number 9 of 2006 concerning the Warehouse Receipt System (State Gazette of the Republic of Indonesia Year 2011 Number 78, Supplement to the State Gazette of the Republic of Indonesia Number 5231); 2. Government Regulation Number 36 of 2007 concerning the Implementation of Law Number 9 of 2006 concerning the Warehouse Receipt System (State Gazette of the Republic of Indonesia Year 2007 Number 79, Supplement to the State Gazette of the Republic of Indonesia Number 4735) as amended by Government Regulation Number 70 of 2013 concerning Amendments to Government Regulation Number 36 of 2007 concerning the Implementation of Law Number 9 of 2006 concerning the Warehouse Receipt System (State Gazette of the Republic of Indonesia Year 2013 Number 172, Supplement to the State Gazette of the Republic of Indonesia Number 5459); 3. Presidential Regulation Number 140 of 2024 concerning the Organization of State Ministries (State Gazette of the Republic of Indonesia Year 2024 Number 250); 4. Presidential Regulation Number 168 of 2024 concerning the Ministry of Trade (State Gazette of the Republic of Indonesia Year 2024 Number 364); 5. Minister of Trade Regulation Number 23 of 2024 concerning General Policy in the Warehouse Receipt System Field (State News of the Republic of Indonesia Year 2024 Number 620); 6. Minister of Trade Regulation Number 6 of 2025 concerning the Organization and Work Structure of the Ministry of Trade (State News of the Republic of Indonesia Year 2025 Number 53);

DECIDES: Establish: REGULATION OF THE COMMODITY FUTURES TRADING REGULATORY AGENCY CONCERNING TECHNICAL GUIDELINES FOR THE APPROVAL PROCEDURE AS A REGISTRATION CENTER IN THE WAREHOUSE RECEIPT SYSTEM.

CHAPTER I GENERAL PROVISIONS

Article 1 In this Regulation, the following terms are defined:

1. Warehouse Receipt System is an activity related to the issuance, transfer, guarantee, and settlement of Warehouse Receipt transactions.
2. Warehouse Receipt Supervisory Agency, hereinafter referred to as the Supervisory Agency, is an organizational unit under the Minister, authorized to conduct development, regulation, and supervision of the implementation of the Warehouse Receipt System.
3. Commodity Futures Trading Regulatory Agency, hereinafter referred to as Bappebti, is a government agency authorized as regulated in statutory regulations to carry out the tasks, functions, and authorities of the Supervisory Agency.
4. Clearing and Guarantee Institution, hereinafter referred to as Clearing Institution, is a business entity that organizes and provides systems and/or facilities for the implementation of clearing and guarantee settlement of Commodity Futures Trading and Physical Commodity Market transactions.
5. Warehouse Receipt Registration Center, hereinafter referred to as Registration Center, is a legal entity business that has obtained approval from the Supervisory Agency to conduct bookkeeping of Warehouse Receipts and Warehouse Receipt Derivatives, which includes recording, storage, transfer of ownership, encumbrance of guarantee rights, reporting, and provision of information systems and networks.
6. Warehouse Manager is a party conducting warehouse business, whether owning the warehouse or using another's, which conducts storage, maintenance, and supervision of goods stored by the goods owner and is entitled to issue Warehouse Receipts.
7. Warehouse Receipt is a document evidencing ownership of goods stored in a Warehouse issued by the Warehouse Manager.
8. Warehouse Receipt Derivative is a derivative of a Warehouse Receipt that can be in the form of Warehouse Receipt futures contracts, options on Warehouse Receipts, indices on Warehouse Receipts, discounted Warehouse Receipt securities, Warehouse Receipt units, or other derivatives of Warehouse Receipts as financial instruments issued by banks, non-bank financial institutions, and futures traders.
9. Guarantee Right Recipient is a party holding or entitled to Guarantee Rights over Warehouse Receipts in accordance with the Deed of Encumbrance of Guarantee Rights.

Article 2 (1) The Registration Center is required to conduct bookkeeping of Warehouse Receipts and Warehouse Receipt Derivatives, which includes: a. recording; b. storage; c. transfer of ownership; d. encumbrance of guarantee rights; e. reporting; and f. provision of information systems and networks, for Warehouse Receipts and Warehouse Receipt Derivatives. (2) The transfer of ownership of Warehouse Receipts and/or Warehouse Receipt Derivatives as referred to in paragraph (1) letter c is conducted when there is a transfer of ownership of Warehouse Receipts and/or Warehouse Receipt Derivatives. (3) The encumbrance of guarantee rights as referred to in paragraph (1) letter d includes: a. recording and confirmation of notification of encumbrance of guarantee rights; b. confirmation of notification of changes in encumbrance of guarantee rights and changes in records of encumbrance of guarantee rights; c. confirmation of deletion of encumbrance of guarantee rights; and d. sale of guarantee right objects. (4) Regulations concerning the bookkeeping of Warehouse Receipts and Warehouse Receipt Derivatives as referred to in paragraph (1) letters a through f are regulated in a separate Bappebti Regulation.

Article 3 (1) The Registration Center is located in the Capital City of the Republic of Indonesia. (2) The Registration Center is prohibited from being controlled, directly or indirectly, by an individual who: a. has previously been declared bankrupt or served as a director or commissioner who was declared guilty causing a company to be declared bankrupt within the last 5 (five) years; b. has previously been sentenced based on a final court decision for committing economic or financial criminal offenses with a penalty threat above 5 (five) years; c. is proven to have violated regulations in the Warehouse Receipt System field; d. does not have good ethics and morals; and/or e. does not have knowledge in the Warehouse Receipt System field. (3) The Registration Center conducts bookkeeping of Warehouse Receipts and Warehouse Receipt Derivatives only for goods that have been designated as goods that can be stored in the Warehouse Receipt System. (4) The Registration Center may only conduct bookkeeping of Warehouse Receipts and Warehouse Receipt Derivatives issued by Warehouse Managers or parties issuing Warehouse Receipt Derivatives that have obtained approval from the Head of Bappebti and have cooperated with the respective Registration Center. (5) Cooperation between the Registration Center and Warehouse Managers or parties issuing Warehouse Receipt Derivatives that have obtained approval from Bappebti as referred to in paragraph (4) must at least contain: a. scope of cooperation; b. rights and obligations of the parties; c. costs for bookkeeping of Warehouse Receipts and/or Warehouse Receipt Derivatives; d. data and information confidentiality; e. prohibited matters; f. transfer of agreement; g. force majeure; h. dispute resolution; and i. termination of cooperation. (6) In the event there is more than one (1) Registration Center that has obtained approval from the Head of Bappebti, Warehouse Managers or parties issuing Warehouse Receipt Derivatives may only cooperate with one (1) Registration Center. (7) Warehouse Managers or parties issuing Warehouse Receipt Derivatives may transfer or change cooperation with the Registration Center subject to the following conditions: a. having no valid Warehouse Receipts and/or Warehouse Receipt Derivatives at the previous Registration Center; b. having settled all obligations, including obligations regarding Warehouse Receipts and/or Warehouse Receipt Derivatives or financial obligations to the previous Registration Center; c. the cooperation agreement between the Warehouse Manager or party issuing Warehouse Receipt Derivatives and the Registration Center has ended; and d. reporting to Bappebti at the latest 14 (fourteen) working days before conducting the transfer or change of cooperation, accompanied by reasons for the transfer or change of cooperation.

Article 4 (1) Bookkeeping of Warehouse Receipts and Warehouse Receipt Derivatives as referred to in Article 2 paragraph (1) is implemented through the Warehouse Receipt and Warehouse Receipt Derivative bookkeeping system. (2) In the event the Warehouse Receipt and Warehouse Receipt Derivative bookkeeping system experiences disturbances, bookkeeping is conducted manually while adhering to the principles of safety, trustworthiness, and reliability.

CHAPTER II REGISTRATION CENTER REQUIREMENTS

Article 5 (1) Bookkeeping of Warehouse Receipts and Warehouse Receipt Derivatives as referred to in Article 2 paragraph (1) may only be conducted by a limited liability company legal entity business that has obtained approval as a Registration Center from the Head of Bappebti. (2) To obtain approval as a Registration Center as referred to in paragraph (1), the limited liability company legal entity business must meet the following requirements: a. having paid-up capital of at least IDR 250,000,000,000.00 (two hundred fifty billion rupiah) from the total paid-up capital of the company; b. having a Warehouse Receipt and Warehouse Receipt Derivative bookkeeping system that has been audited by an independent institution, evidenced by a valid audit result; c. having standard operating procedures at least regulating:

1. cooperation mechanisms with Warehouse Managers or parties issuing Warehouse Receipt Derivatives;
2. services and processes for bookkeeping of Warehouse Receipts and/or Warehouse Receipt Derivatives;
3. management and maintenance of the Warehouse Receipt and Warehouse Receipt Derivative bookkeeping system;
4. internal audit management;
5. data and information management; and
6. complaint handling services. d. having sufficient workforce with the knowledge, skills, and competence to carry out bookkeeping activities of Warehouse Receipts and Warehouse Receipt Derivatives; and e. having at least 3 (three) years of experience in recording commodity futures contract transactions and clearing. (3) The Warehouse Receipt and Warehouse Receipt Derivative bookkeeping system as referred to in paragraph (2) letter b must meet at least the following requirements: a. accurate, current, safe, trustworthy, and technically having system connection specifications that can be used to communicate with Bappebti's supervision system, Warehouse Manager systems, Conformity Assessment Institution systems, Guarantee Right Recipient systems, and/or other systems owned or provided by relevant ministries/agencies in accordance with statutory regulations; b. having functions capable of protecting the security and accuracy of access to Warehouse Receipt and Warehouse Receipt Derivative bookkeeping data; c. having an up-to-date business continuity plan; d. having a disaster recovery center:
7. located within the country at a minimum distance of 20 km (twenty kilometers) from the main server location;
8. using adequate servers or cloud servers; and
9. having an official representative office in Indonesia. e. having configuration specifications:
10. ensuring maintenance of communication with Bappebti's supervision system, Warehouse Manager systems, Conformity Assessment Institution systems, Guarantee Right Recipient systems, and/or other systems owned or provided by relevant ministries/agencies as referred to in letter a in real-time; and
11. having good system security levels to overcome internal and external system disturbances. f. meeting database requirements functioning to manage Warehouse Receipt and Warehouse Receipt Derivative bookkeeping as follows:
12. storing Warehouse Receipt and Warehouse Receipt Derivative bookkeeping data for at least the last 5 (five) consecutive years;
13. maintaining Warehouse Receipt and Warehouse Receipt Derivative bookkeeping records for a duration of at least the last 6 (six) months; and
14. after the 6 (six) month period, the Warehouse Receipt and Warehouse Receipt Derivative bookkeeping records as referred to in item 2 must be copied and stored in data storage media. g. servers or cloud servers used have good technical specifications to facilitate the use of online supervision and reporting systems and/or facilities, namely:
15. servers or cloud servers, including backups (mirroring), must be located within the country;
16. servers or cloud servers must have backup (mirroring) servers; and
17. servers or cloud servers are supported by adequate infrastructure and facilities to guarantee operational continuity. h. In the event servers or cloud servers use cloud services, they must implement International Organization for Standardization (ISO) 27001 (information security management system), ISO 27017 (cloud security), and ISO 27018 (cloud privacy), evidenced by certificates issued by authorized certification bodies; and i. having secured open application programming interfaces with determined procedures, such as encryption-decryption processes, internet protocol whitelists, tunnels, and certificates. (4) The Warehouse Receipt and Warehouse Receipt Derivative bookkeeping system as referred to in paragraph (2) letter b must be examined or audited by an independent institution. (5) In the event the audit results of the Warehouse Receipt and Warehouse Receipt Derivative bookkeeping system as referred to in paragraph (4) prove to be incompatible, both in system and application, with Bappebti's supervision system, Warehouse Manager systems, Conformity Assessment Institution systems, Guarantee Right Recipient systems, and/or other systems owned or provided by relevant ministries/agencies in accordance with statutory regulations, and/or do not meet the minimum specification and function standards as regulated in this Regulation, the applicant for approval as a Registration Center is required to adjust or replace with a compatible system. (6) Adjustments or replacements as referred to in paragraph (5) must be completed within a maximum of 3 (three) months after being declared incompatible based on audit results by an independent institution competent in information systems. (7) The Warehouse Receipt and Warehouse Receipt Derivative bookkeeping system as referred to in paragraph (2) letter b, including its changes, must obtain approval from the Head of Bappebti.

Article 6 (1) Bappebti issues a list of independent institutions that must be chosen by applicants for approval as Registration Centers to conduct audits of Warehouse Receipt and Warehouse Receipt Derivative bookkeeping systems. (2) Independent institutions for conducting audits of Warehouse Receipt and Warehouse Receipt Derivative bookkeeping systems as referred to in paragraph (1) must have at least the following criteria: a. having conducted business activities for at least 2 (two) years and having audit experience in non-banking finance or information systems; b. having auditors with competence in information systems; and c. having permits and certifications from relevant authorized ministries, institutions, or authorities. (3) All costs arising from the implementation of system audits or examinations are the responsibility of the applicant for approval as a Registration Center. (4) In the event Bappebti has not yet issued the list of independent institutions as referred to in paragraph (1), the audit of Warehouse Receipt and Warehouse Receipt Derivative bookkeeping systems may be conducted by information system audit service providers that have permits and certifications from relevant authorized ministries, institutions, or authorities.

CHAPTER III LICENSING MECHANISM

Article 7 (1) Applications to obtain approval as a Registration Center are submitted to the Head of Bappebti, accompanied by documents as attached in the Appendix of this Regulation. (2) In processing the application for approval as a Registration Center as referred to in paragraph (1), Bappebti conducts verification, research, or assessment of the documents as referred to in paragraph (1) and conducts examinations of physical facilities and infrastructure supporting the operation of Warehouse Receipt and Warehouse Receipt Derivative bookkeeping at the applicant's office. (3) In conducting examinations of physical facilities and infrastructure at the applicant's office as referred to in paragraph (2), Bappebti creates an examination report. (4) Bappebti conducts interviews regarding ethics, morals, and knowledge in the Warehouse Receipt System field with the management of the applicant company as a completeness of the approval process after the requirements as referred to in paragraph (2) and paragraph (3) are met. (5) Within a period of 5 (five) working days after conducting verification or research on document validity and examination of physical facilities and infrastructure as referred to in paragraph (2) and paragraph (3) and interviews as referred to in paragraph (4), Bappebti provides responses or notes to the applicant, indicating that the results are compliant or that further completion is needed by the applicant. (6) In the event there are responses or notes as referred to in paragraph (5), Bappebti provides a period of 5 (five) working days for the applicant to complete and/or adjust requirements, calculated from when Bappebti provides the response or note. (7) If within the 5 (five) working day period as referred to in paragraph (6) the applicant does not complete and/or adjust the requirements, Bappebti submits a rejection of the application submitted by the applicant. (8) Bappebti provides approval for the application as a Registration Center as referred to in paragraph (1) at the latest 5 (five) working days after all requirements are declared complete and correct. (9) Bappebti submits rejection of the application as a Registration Center as referred to in paragraph (1) at the latest 5 (five) working days after the period as referred to in paragraph (7) has expired. (10) In the context of licensing processing, the technical unit at Bappebti with the task and function of development in the Warehouse Receipt System field drafts standard operating procedures for licensing processing as a Registration Center in the Warehouse Receipt System, which subsequently becomes technical guidelines for licensing processing.

CHAPTER IV RIGHTS AND OBLIGATIONS

Article 8 (1) The Registration Center is required to: a. conduct bookkeeping of Warehouse Receipts and Warehouse Receipt Derivatives; b. conduct verification and validation of data and documents submitted by Warehouse Managers, parties issuing Warehouse Receipt Derivatives, Conformity Assessment Institutions, Guarantee Right Recipients, and subsidy distributor parties of the Warehouse Receipt System, if any, quickly, accurately, completely, and correctly; c. have a Warehouse Receipt and Warehouse Receipt Derivative bookkeeping system integrated with Bappebti's supervision system, Warehouse Manager systems, Conformity Assessment Institution systems, Guarantee Right Recipient systems, and/or other systems provided by relevant ministries/agencies in accordance with statutory regulations; d. create, store accounting books and records related to the Warehouse Receipt System; e. provide data and information regarding Warehouse Receipt and Warehouse Receipt Derivative bookkeeping whenever requested by Bappebti and/or authorized parties in accordance with statutory regulations; f. maintain data and information confidentiality in accordance with statutory regulations; g. submit written or electronic confirmation to Warehouse Receipt holders and/or Guarantee Right Recipients at the latest 2 (two) days after the end of the calendar month, whether changes in ownership records occurred or not, in the event of:

1. issuance of Warehouse Receipts;
2. issuance of Replacement Warehouse Receipts;
3. transfer of Warehouse Receipts; or
4. encumbrance, change, or deletion of Guarantee Rights. h. provide confirmation regarding the status of Warehouse Receipts and their ownership to Warehouse Managers on the same day Warehouse Managers verify the status of Warehouse Receipts and holders in the context of receiving requests from Warehouse Receipt holders for partial delivery of goods; i. notify in writing or electronically regarding Warehouse Receipts that will mature, at the latest 5 (five) days before the maturity date of the Warehouse Receipt, to:
5. Warehouse Managers and Warehouse Receipt holders in the event Warehouse Receipts are not encumbered with Guarantee Rights; or
6. Warehouse Managers, grantors of guarantee rights, and Guarantee Right Recipients in the event Warehouse Receipts are encumbered with guarantee rights. j. implement ISO 27001 (information security management system), evidenced by an ISO 27001 certificate for the Warehouse Receipt and Warehouse Receipt Derivative bookkeeping system issued by a certification body registered or recognized by the government agency handling information security affairs, within a maximum period of 1 (one) year from obtaining approval as a Registration Center; k. submit monthly, quarterly, and annual reports to Bappebti in accordance with statutory regulations using report formats further established through a Circular Letter from the Head of Bappebti; l. have an ISO 9001 quality management certificate at the latest 2 (two) years from the issuance of approval as a Registration Center; m. report to Bappebti every occurrence of planned changes in management, share ownership, address changes, and company name, Warehouse Receipt and Warehouse Receipt Derivative bookkeeping systems, and/or owned standard operating procedures to obtain Bappebti approval; and n. fulfill regulations as regulated in statutory regulations in the Warehouse Receipt System field. (2) Records as referred to in paragraph (1) letter d include: a. security codes; b. names and addresses of Warehouse Managers or parties issuing Warehouse Receipt Derivatives; c. issuance numbers of Warehouse Receipts issued, including Replacement Warehouse Receipts, destroyed Warehouse Receipts, and Warehouse Receipts encumbered with guarantee rights; d. description of stored goods, including type, quality level, quantity, and grade of goods, if any; e. delivery of goods including date, quality, quantity, name, and address of the recipient of goods; f. names and addresses of Warehouse Receipt holders, including transfer records; g. types and specifications...