OJK Circular No. 21/SEOJK.07/2025 on Fit and Proper Assessment and Reassessment for Principal Parties in the Financial Technology Innovation Sector, Digital Financial Assets, and Crypto Assets

To:
Principal Parties of Financial Technology Innovation Sector, Digital Financial Assets, and Crypto Asset Organizers, At your location.

COPY
CIRCULAR LETTER OF THE FINANCIAL SERVICES AUTHORITY REPUBLIC OF INDONESIA NUMBER 21/SEOJK.07/2025 CONCERNING FIT AND PROPER ASSESSMENT AND REASSESSMENT FOR PRINCIPAL PARTIES IN THE FINANCIAL TECHNOLOGY INNOVATION SECTOR, AS WELL AS DIGITAL FINANCIAL ASSETS AND CRYPTO ASSETS

In light of the enforcement of Financial Services Authority Regulation Number 16 of 2025 concerning Fit and Proper Assessment and Reassessment for Principal Parties in the Financial Technology Innovation Sector, as well as Digital Financial Assets and Crypto Assets (State Gazette of the Republic of Indonesia Year 2025 Number 22/OJK, Supplement to the State Gazette of the Republic of Indonesia Number 152/OJK), it is necessary to regulate further regarding implementation provisions related to fit and proper assessment and reassessment for prospective controlling shareholders, prospective members of the Board of Directors, and prospective members of the Board of Commissioners in the financial technology innovation sector, as well as digital financial assets and crypto assets, in this Financial Services Authority Circular Letter as follows:

I. GENERAL PROVISIONS
In this Financial Services Authority Circular Letter, the following terms are defined as:

Financial Service Institution, hereinafter abbreviated as LJK, is an institution that conducts activities in the banking sector, capital market, insurance, pension funds, venture capital, microfinance institutions, financing institutions, and other financial service institutions.
Financial Technology Innovation, hereinafter abbreviated as ITSK, is technology-based innovation that impacts products, activities, services, and business models in the digital financial ecosystem.
Digital Financial Asset is a financial asset that is stored or represented digitally, including crypto assets.
Crypto Asset is a digital representation of value that can be stored and transferred using technology that enables the use of distributed ledgers such as blockchain to verify transactions and ensure the security and validity of stored information, is not guaranteed by central authorities such as central banks but is issued by private parties, can be traded, stored, and transferred or assigned electronically, and can be in the form of digital coins, tokens, or other asset representations including backed crypto-assets and unbacked crypto-assets.
Digital Financial Asset Trading Organizer is a Digital Financial Asset exchange including Crypto Assets, clearing, guarantee, and settlement institutions, custodian managers, Digital Financial Asset traders, and other parties designated by the Financial Services Authority.
ITSK, Digital Financial Assets, and Crypto Assets, hereinafter abbreviated as IAKD, are institutions that conduct activities in the IAKD sector.
IAKD Organizer is any party that conducts IAKD activities.
Controlling Shareholder, hereinafter abbreviated as PSP, is a legal entity, individual, and/or business group that holds 25% (twenty-five percent) or more of the shares of the IAKD Organizer issued and having voting rights, or holds less than 25% (twenty-five percent) of the shares issued and having voting rights of the IAKD Organizer but can be proven to have controlled the IAKD Organizer, directly or indirectly.
General Meeting of Shareholders, hereinafter abbreviated as RUPS, is a company organ that has authority not given to the Board of Directors or Board of Commissioners within the limits determined in the laws concerning limited liability companies and/or the articles of association for IAKD Organizers that are limited liability companies.
Board of Directors is the organ of the IAKD Organizer that has the authority and is fully responsible for the management of IAKD for the interests of IAKD, in accordance with the purpose and objectives of IAKD and represents IAKD, both inside and outside of court, in accordance with the provisions of the articles of association.
Board of Commissioners is the organ of the IAKD Organizer tasked with conducting general and/or specific supervision in accordance with the articles of association and providing advice to the Board of Directors.
Principal Party is a party that owns, manages, supervises, and/or has significant influence over the IAKD Organizer.

II. FIT AND PROPER ASSESSMENT

Scope of Parties Subject to Fit and Proper Assessment
a. Fit and proper assessment is conducted by the Financial Services Authority against prospective Principal Parties of IAKD Organizers. b. Prospective Principal Parties of IAKD Organizers as referred to in letter a include:
1) prospective controlling principal parties, namely PSPs of IAKD Organizers which are:
a) individuals and/or legal entities that will purchase, receive gifts, inherit, or other forms of transfer of rights over shares of the IAKD Organizer, resulting in the relevant party becoming a PSP; b) shareholders of the IAKD Organizer who are not classified as PSPs (non-PSPs) that purchase, receive gifts, inherit, or other forms of transfer of rights over shares of the IAKD Organizer, resulting in the relevant party becoming a PSP; c) non-PSPs that increase capital contributions, resulting in the relevant party becoming a PSP; d) individuals and/or legal entities that will become PSPs in an "IAKD Organizer resulting from a merger"; e) individuals and/or legal entities that will become PSPs in an "IAKD Organizer resulting from a consolidation"; and/or f) individuals and/or legal entities that will become PSPs in an IAKD Organizer to be established.
2) prospective managerial principal parties, namely prospective members of the Board of Directors or members of the Board of Commissioners which are:
a) individuals who have never served as members of the Board of Directors or members of the Board of Commissioners, who are nominated to become members of the Board of Directors, or members of the Board of Commissioners; b) individuals who are currently serving as members of the Board of Directors or members of the Board of Commissioners, who are nominated to become members of the Board of Directors or members of the Board of Commissioners, either in the same type of IAKD Organizer or in a different one; c) individuals who have previously served as members of the Board of Directors or members of the Board of Commissioners, who are nominated to become members of the Board of Directors or members of the Board of Commissioners, in the same IAKD Organizer or in another IAKD Organizer, examples:
(1) individuals who have previously served as members of the Board of Commissioners who are nominated to become independent commissioners in the same IAKD Organizer or another IAKD Organizer; and (2) individuals who have previously served as members of the Board of Directors who are nominated to become lead commissioners in the same IAKD Organizer or another IAKD Organizer. d) members of the Board of Directors or members of the Board of Commissioners, who will transfer positions in the same IAKD Organizer, examples:
(1) members of the Board of Commissioners who will transfer positions to become members of the Board of Directors in the same IAKD Organizer; (2) members of the Board of Directors who will transfer positions to become members of the Board of Commissioners in the same IAKD Organizer; or (3) members of the Board of Directors or members of the Board of Commissioners who will transfer positions to higher positions in the same IAKD Organizer, examples:
(a) members of the Board of Directors who will be appointed as Lead Directors, or equivalent, in the same IAKD Organizer; and/or (b) members of the Board of Commissioners who will be appointed as Lead Commissioners, or equivalent, in the same IAKD Organizer; e) members of the Board of Directors or members of the Board of Commissioners, who come from an IAKD Organizer that undergoes a merger or consolidation, examples:
(1) members of the Board of Directors or members of the Board of Commissioners, in an "IAKD Organizer resulting from a merger" who come from an "IAKD Organizer that undergoes a merger"; (2) members of the Board of Directors or members of the Board of Commissioners, in an "IAKD Organizer resulting from a merger" who come from an "IAKD Organizer that receives a merger" including extension of term of office; or (3) members of the Board of Directors or members of the Board of Commissioners, in an "IAKD Organizer resulting from a consolidation" who come from an "IAKD Organizer" that undergoes consolidation.
c. Fit and proper assessment is not conducted for the extension of term of office in the same IAKD Organizer for members of the Board of Directors or members of the Board of Commissioners, except for the extension of term of office as referred to in letter b number 2) letter e) number (2).
d. Extension of term of office as referred to in letter c is any reassignment in the same, equivalent, or lower position, examples:
1) same position is a Chief Information Officer appointed again as Chief Information Officer in the same IAKD Organizer;
2) equivalent position is a Chief Financial Officer appointed as Chief Risk Officer in the same IAKD Organizer; and
3) lower position is:
a) Lead Director appointed as Director in the same IAKD Organizer; or b) Lead Commissioner appointed as Commissioner in the same IAKD Organizer. e. Change of Controlling Principal Parties before Fit and Proper Assessment
1) In the event of a change in ownership, prospective controlling principal parties as referred to in letter b number 1) must first be submitted to the Financial Services Authority for fit and proper assessment before purchasing/taking over shares of the IAKD Organizer.
2) In the event that prospective controlling principal parties as referred to in number 1) already hold shares in the IAKD Organizer before obtaining approval from the Financial Services Authority, the relevant party is prohibited from taking actions as a controlling principal party even though they hold shares in the IAKD Organizer.
3) Actions as a controlling principal party as referred to in number 2) include, among others:
a) influencing the policies of the IAKD Organizer; b) proposing/placing members of the Board of Directors and members of the Board of Commissioners of the IAKD Organizer; and c) attending and/or voting in the RUPS in the capacity of a PSP. f. Appointment of Prospective Managerial Principal Parties before Fit and Proper Assessment
1) Prospective managerial principal parties as referred to in letter b number 2) must first be submitted to the Financial Services Authority for fit and proper assessment before being appointed by the RUPS.
2) Prospective managerial principal parties who have not obtained approval from the Financial Services Authority as referred to in number 1) are prohibited from taking actions, duties, and functions as managerial principal parties even though they have obtained approval and been appointed by the RUPS.
3) Actions, duties, and functions as members of the Board of Directors as referred to in number 2) include, among others:
a) acting on behalf of the IAKD Organizer in making decisions that legally bind the IAKD Organizer; b) making important decisions that affect the financial condition of the IAKD Organizer; c) having voting rights in IAKD Organizer meetings; d) representing the IAKD Organizer inside and outside of court; and e) other authorities attached to the functions of the Board of Directors.
4) Actions, duties, and functions as members of the Board of Commissioners as referred to in number 2) include, among others:
a) supervision over Board of Directors' policies; b) operational supervision of the IAKD Organizer; c) providing advice to the Board of Directors; and d) other authorities attached to the functions of the Board of Commissioners.
Requirements in Fit and Proper Assessment
a. Fit and proper assessment is conducted to assess prospective Principal Parties who meet the requirements:
1) integrity and financial feasibility for prospective controlling principal parties; and
2) integrity, financial reputation, and competence for prospective managerial principal parties.
b. Integrity Requirements
1) The assessment of integrity requirements is conducted to ensure the level of compliance and good faith of Principal Parties to manage, supervise, and/or conduct business processes so that the IAKD Organizer can fulfill its obligations to consumers.
2) Criteria for assessing integrity requirements for Principal Parties include:
a) having legal capacity as regulated in applicable legislation; b) having good ethics and morals, at least demonstrated by a attitude of complying with applicable regulations, including:
(1) maintaining the confidentiality and security of consumer data and information; and (2) never having been sentenced for proven criminal acts within a certain period before nomination, including:
(a) criminal acts in the financial services sector whose sentence has been completed within the last 20 (twenty) years before nomination; (b) criminal acts stipulated in the Criminal Code (KUHP) and/or similar to the KUHP abroad with a prison sentence threat of 1 (one) year or more whose sentence has been completed within the last 10 (ten) years before nomination; and/or (c) other criminal acts with a prison sentence threat of 1 (one) year or more, including corruption, money laundering, narcotics/psychotropics, smuggling, customs, excise, human trafficking, illegal arms trade, terrorism, counterfeiting money, in the field of taxation, in the field of forestry, in the field of environment, and in the field of marine and fisheries, whose sentence has been completed within the last 20 (twenty) years before nomination. What is meant by before nomination as referred to in letter (a), letter (b), and letter (c) is calculated from the time the relevant party has finished serving the criminal sentence until the date of the letter requesting fit and proper assessment from the IAKD Organizer to the Financial Services Authority; and In assessing "attitude of complying with applicable regulations," negative records of the relevant party found in law enforcement agencies and/or other authorities are considered. c) having a commitment to comply with applicable legislation and support Financial Services Authority policies, among others proven by a written statement containing at least:
(1) never having violated and willing to implement prudent principles in the financial services sector; and (2) never having violated and willing to comply with applicable legislation in the financial services sector, consumer protection, and anti-fraud regulations; d) having a commitment to the healthy development of the IAKD Organizer, among others proven by:
(1) submission of the prospective controlling principal party's plan for the operational development of the IAKD Organizer, containing at least:
(a) direction and strategy for the development of the IAKD Organizer; (b) strategy in the event that the IAKD Organizer to be owned and/or controlled experiences financial difficulties; and (c) capital plan for the IAKD Organizer for a minimum period of 3 (three) years; (2) never having violated commitments agreed upon with the supervising and regulating agency of IAKD, namely acts of not fulfilling part or all of the agreed commitments contained in meeting minutes, minutes of meeting, or stated in company commitment letters, including not implementing:
(a) recommendations from audit reports;
(b) programs for the rehabilitation of the IAKD Organizer; and (c) settlement of IAKD Organizer obligations to consumers that have been agreed upon; (3) having a commitment not to commit and/or repeat acts and/or actions that cause the relevant party to be listed in the list of parties prohibited from being Principal Parties, for prospects who have previously been listed in the list of parties prohibited from being Principal Parties; (4) never having committed acts that provide unfair benefits to shareholders, Principal Parties, employees, and/or other parties that can harm or reduce consumer rights; (5) never having committed acts that are not in accordance with their authority or beyond their authority; (6) never having been declared unable to exercise their authority; and (7) having a commitment in handling and resolving consumer complaints specifically for Principal Parties who oversee the consumer protection function; e) not being included as a party prohibited from becoming a prospective Principal Party in LJK and/or IAKD Organizers.
c. Financial Reputation Assessment Requirements
1) The assessment of financial reputation requirements is conducted to assess financial capability and evaluate the involvement of managerial principal parties in the criteria for assessing financial reputation requirements.
2) Criteria for assessing financial reputation requirements for managerial principal parties as referred to in number 1) include:
a) not having non-performing loans and/or financing; and b) never having been declared bankrupt and/or never having been a shareholder, member of the Board of Directors, or member of the Board of Commissioners who was declared guilty causing a company to be declared bankrupt within the last 5 (five) years before nomination.
3) The definition of non-performing loans as referred to in number 2) letter a) does not include non-performing loans arising from annual fee credit card bills, credit card administrative fees, and/or other credit card bills not arising from credit card usage transactions.
d. Financial Feasibility Requirements
1) The assessment of financial feasibility requirements is conducted to assess the financial capability of prospective controlling principal parties in the financial reputation factor criteria.
2) Criteria for assessing financial feasibility requirements include:
a) having financial reputation as referred to in number 2 letter c; b) having financial capability that can support the business development of the IAKD Organizer, namely:
(1) the financial position of individual controlling principal parties capable of supporting the business development of the IAKD Organizer, demonstrated by a statement letter from the individual controlling principal party that they have financial capability, accompanied by supporting evidence such as tax Annual Information Return (SPT) for the last 2 (two) years and/or bank statements for at least the last 3 (three) months containing capital receipt or transfer transactions; and (2) the position of the latest audited annual financial report by a public accountant (if available) or financial reports audited internally by the competent party overseeing the finance or audit function at the IAKD Organizer, for legal entity controlling principal parties, including: liquidity position, solvency position, investment placement position, return on assets position, and return on equity position; and (3) having a commitment to take necessary measures if the IAKD Organizer faces financial difficulties in the form of a statement letter. e. Competence Requirements
1) The assessment of the competence factor is conducted to assess the knowledge, ability, experience, and expertise possessed by prospective managerial principal parties, to ensure they are adequate and relevant to their positions.
2) Criteria for assessing the competence factor for prospective managerial principal parties include assessment of:
a) knowledge and/or experience in fields relevant to the target position at the IAKD Organizer, among others proven by:
(1) experience at LJK and/or relevant IAKD Organizers; (2) experience in positions relevant to the plan for the relevant party to be appointed or employed; and/or (3) expertise in the field of IAKD Organizers and/or other relevant industries. b) ability to manage and develop the IAKD Organizer strategically, conducted to ensure that:
(1) prospective managerial principal parties have adequate and relevant knowledge for their positions, among others proven by:
(a) knowledge regarding organizational structure, management, job descriptions, and responsibilities; (b) potential ability to analyze business processes, lead organizations, and manage human resources, including understanding risk management to achieve organizational objectives; (c) basic supervision knowledge including internal controls, specifically for members of the Board of Commissioners; (d) basic knowledge related to leadership and conflict management specifically for members of the Board of Commissioners and members of the Board of Directors; and (e) ability to evaluate company obligations or other technical aspects; (2) prospective managerial principal parties have understanding of applicable legislation, among others proven by:
(a) understanding of applicable legislation in the financial services sector, prioritized over applicable legislation in the industry where the prospective managerial principal party will serve; and (b) basic understanding of other relevant applicable legislation including understanding of applicable legislation in the field of limited liability companies, Financial Services Authority, bankruptcy, money laundering criminal acts, and their implementing regulations. (3) prospective managerial principal parties have the ability to conduct strategic management for healthy business development, among others proven by:
(a) for prospective members of the Board of Directors, namely:
i. formulating the vision and mission of the IAKD Organizer;
ii. conducting analysis of the IAKD Organizer's situation;
iii. conducting analysis of the internal condition development of the IAKD Organizer;
iv. setting targets to be achieved regarding the position held; and
v. designing short-term, medium-term, and long-term strategies to achieve IAKD Organizer objectives, including the ability to anticipate future developments, such as the ability to prepare annual business plans and medium-term and long-term corporate plans using realistic and measurable assumptions;
(b) for prospective members of the Board of Commissioners, namely:
i. conducting basic analysis of the IAKD Organizer's situation;
ii. conducting analysis of the internal condition development of the IAKD Organizer, including health conditions

financial Service Provider for Digital Financial Assets, human resources, and information technology; and
iii. analyze the policies of the Board of Directors members.
3. Application Procedures and Administrative Requirements
a. Application Procedures
1) An application for approval to become a Principal Party is submitted by the applicant, namely:
a) prospective owners, founders, or Board of Directors members when the Digital Financial Asset Service Provider is applying for a business license; or b) Board of Directors members, when the Digital Financial Asset Service Provider has obtained a business license.
2) In the event that the Board of Directors members referred to in item 1) cannot perform their functions or have a conflict of interest with the Digital Financial Asset Service Provider, the application is submitted by:
a) other Board of Directors members who do not have a conflict of interest with the Digital Financial Asset Service Provider; b) Board of Commissioners members if all Board of Directors members cannot perform their functions or have a conflict of interest with the Digital Financial Asset Service Provider; or c) other parties appointed by the General Meeting of Shareholders if all management Principal Parties cannot perform their functions or have a conflict with the Digital Financial Asset Service Provider.
3) The application for approval to become a Principal Party as referred to in item 1) or item 2) is submitted to the Financial Services Authority using the format in Appendix I Part A, which is an integral part of this Financial Services Authority Circular.
4) The submission of the application letter for approval to become a Principal Party as referred to in item 3) must be accompanied by administrative requirement documents.
5) The applicant Digital Financial Asset Service Provider fills out the administrative requirement compliance list using the format in Appendix I Part B, which is an integral part of this Financial Services Authority Circular.
6) Specifically for the assessment of the competence and propriety of management Principal Parties, the application is accompanied by a self-assessment form for prospective management Principal Parties using the format in Appendix I Part C, which is an integral part of this Financial Services Authority Circular.
7) The self-assessment as referred to in item 6) is conducted and signed by:
(1) the compliance and internal audit function for Digital Financial Asset Trading Service Providers; or

(2) the nomination and remuneration function for Digital Financial Asset Service Providers other than Digital Financial Asset Trading Service Providers. b. Administrative Requirement Documents
1) Completeness of administrative requirement documents as referred to in letter a item 4) for prospective controlling Principal Parties who are individual persons of the Digital Financial Asset Service Provider, namely digital copies (softcopy):
a) a completed questionnaire using the format in Appendix I Part D item 1, which is an integral part of this Financial Services Authority Circular, accompanied by:
(1) a copy of identity documents in the form of an Identity Card (KTP) or valid passport; (2) Taxpayer Identification Number (NPWP) for Indonesian citizens or equivalent valid documents for foreign citizens; and (3) a completed, properly stamped, and signed statement letter by the prospective party using the format in Appendix I Part E, which is an integral part of this Financial Services Authority Circular, containing a statement of meeting integrity aspects, financial viability aspects, and not undergoing a competence and propriety assessment at another Financial License Holder or Digital Financial Asset Service Provider. (4) Annual Tax Returns (SPT) for the last 2 (two) years; (5) Police Record Certificate (SKCK)/Police Clearing or equivalent documents for foreign citizens; and (6) information regarding the source of funds used as capital contribution to the Digital Financial Asset Service Provider in the form of capital deposit proof and/or a 3 (three) month bank statement containing capital receipt or transfer transactions; b) a completed resume using the format as stated in Appendix I Part F, which is an integral part of this Financial Services Authority Circular; and
2) Completeness of administrative requirement documents as referred to in letter a item 4) for prospective controlling Principal Parties who are legal entities, namely digital copies (softcopy):
a) a completed questionnaire using the format in Appendix I Part D, which is an integral part of this Financial Services Authority Circular, containing legal entity data, accompanied by:
(1) a copy of establishment documents in the form of the legal entity establishment deed, including the latest amended articles of association approved by the competent authority or equivalent documents for foreign businesses according to regulations in the country of origin; and (2) a copy of the Taxpayer Identification Number (NPWP) for Indonesian legal entities or equivalent valid documents for foreign legal entities; b) a statement letter from the legal entity represented by the Board of Directors, which has been completed and properly stamped, using the format in Appendix I Part E item 1, which is an integral part of this Financial Services Authority Circular, containing a statement of meeting integrity aspects, financial viability aspects, and not undergoing a competence and propriety assessment at a Financial License Holder; c) the latest audited annual financial report audited by a public accountant or a financial report audited internally by the competent party overseeing the finance or audit function at the Digital Financial Asset Service Provider; d) resumes of the Board of Directors and Board of Commissioners members, as well as owners and ultimate shareholders, which have been completed using the format in Appendix I Part F, which is an integral part of this Financial Services Authority Circular, accompanied by digital copies (softcopy):
(1) personal data:
(a) a copy of identity documents in the form of an Identity Card (KTP) or valid passport; (b) a copy of the Taxpayer Identification Number (NPWP) for Indonesian citizens or equivalent valid documents for foreign citizens; and (2) Police Record Certificate (SKCK)/Police Clearing or equivalent documents for foreign citizens; e) the ownership structure of the ultimate shareholder; f) information regarding the source of funds used as capital contribution to the Digital Financial Asset Service Provider in the form of capital deposit proof and/or a 3 (three) month bank statement containing capital receipt or transfer transactions; g) a statement letter from the ultimate shareholder, which has been prepared and properly stamped, containing a detailed explanation regarding the nature of the relationship between the ultimate shareholder and the prospective controlling shareholder; h) a statement letter from the ultimate shareholder, which has been prepared and properly stamped, containing a statement of not practicing nominee practices, loaned share names, or acting in concert, which could potentially cause negative impacts on the Digital Financial Asset Service Provider; and i) other documents related to indirect shareholders up to the ultimate shareholder (if required by the Financial Services Authority).
3) Completeness of requirement documents for parties nominated as Board of Directors members or Board of Commissioners members, namely digital copies (softcopy):
a) a completed, properly stamped, and signed statement letter by the party nominated as a Board of Directors member or Board of Commissioners member, using the format in Appendix I Part E item 2, which is an integral part of this Financial Services Authority Circular, containing a statement of meeting integrity aspects, financial reputation aspects, and not undergoing a competence and propriety assessment at another Financial License Holder or Digital Financial Asset Service Provider; b) a completed resume using the format in Appendix I Part F, which is an integral part of this Financial Services Authority Circular, accompanied by:
(1) personal data:
(a) a copy of identity documents in the form of an Identity Card (KTP) or valid passport; and (b) a copy of the Taxpayer Identification Number (NPWP) for Indonesian citizens or equivalent valid documents for foreign citizens; (2) formal education history documents:
(a) copy of the highest diploma;
(b) copy of expertise certificates (if any);
(c) documents of training and seminars attended (if any); (d) copy of training completion certificates or attendance certificates previously attended; and (e) copy of seminar attendance certificates previously attended; (3) work history documents:
(a) letter of work experience certificate; and (b) letter of recommendation and/or letter of statement to resign from the previous Digital Financial Asset Service Provider; (4) awards relevant to the financial industry previously achieved (if any); (5) skills mastered in managing the Digital Financial Asset Service Provider and/or foreign language proficiency; and

(6) Police Record Certificate (SKCK)/Police Clearing or equivalent documents for foreign citizens. c) documents regarding plans to be carried out after being appointed to the targeted position, including:
(1) vision and mission;
(2) programs to be carried out during the term; (3) targets to be achieved during the term; and (4) a statement letter of non-affiliation with the Digital Financial Asset Service Provider, for prospective independent commissioners using the format in Appendix I Part E item 3.
c. Administrative Requirement Compliance List
1) Before the applicant as referred to in letter a item 1) or item 2) submits administrative requirement documents to the Financial Services Authority, the Digital Financial Asset Service Provider must first fill out the administrative requirement compliance list as referred to in letter a item 5).
2) The applicant as referred to in letter a item 1) or item 2) must submit the results of the administrative requirement compliance list as referred to in item 1) to the Financial Services Authority, signed by the party submitting the application.
3) The submission of the results of the administrative requirement document compliance list as referred to in item 2) is accompanied by an explanation stating that the submitted administrative requirement documents:
a) are complete and correct in terms of quantity, format, and substance; and b) state that the administrative requirement documents in the form of "statements" and "questionnaires" are true and have been filled out and signed by the prospective party submitted.
4) The administrative requirement compliance list as referred to in item 2) is submitted together with the submission of the administrative requirement documents of the prospective party submitted.
d. Self-Assessment
1) Self-assessment of Board of Directors members and Board of Commissioners members, as referred to in letter a item 6), is conducted by the Digital Financial Asset Service Provider or prospective Digital Financial Asset Service Provider before being submitted to the relevant Financial Services Authority, concerning:
a) assessment of meeting integrity, financial reputation, and competence requirements for prospective Board of Directors members to be submitted. The assessment covers at least the assessment of track record including sanctions previously given by the Digital Financial Asset Service Provider, educational background both formal and informal, and achievements achieved in performing duties, the prospective party's ability to hold the position to be held, concurrent positions, and ownership of credit and/or non-performing financing; and b) meeting requirements in accordance with applicable legislation.
2) The results of the self-assessment as referred to in item 1) are submitted to the Financial Services Authority at the time of submitting the application.
4. Procedures for Conducting Competence and Propriety Assessment
a. Administrative Assessment
1) Administrative assessment is conducted to assess whether the application for approval to become a Principal Party has met integrity, financial reputation or financial viability, and/or competence requirements.
2) In the event that the administrative requirement documents received by the Financial Services Authority are incomplete and incorrect, additional supporting data is needed, or there are administrative errors in data entry, the Financial Services Authority returns the application and requests the Digital Financial Asset Service Provider or prospective Digital Financial Asset Service Provider to complete the administrative requirement documents as referred to in item 3 letter b as the basis for administrative assessment within a maximum period of 20 (twenty) working days from the date of the Financial Services Authority letter.
3) In the event that the Digital Financial Asset Service Provider or prospective Digital Financial Asset Service Provider does not submit the missing administrative requirement documents within the maximum period of 20 (twenty) working days as referred to in item 2), the Digital Financial Asset Service Provider or prospective Digital Financial Asset Service Provider is deemed to have cancelled the application for approval to become a Principal Party.
4) The Financial Services Authority issues a rejection letter for the application letter for approval to become a Principal Party submitted by the Digital Financial Asset Service Provider if the administrative requirement documents are declared untrue.
5) In the context of administrative assessment in the implementation of the competence and propriety assessment as referred to in item 1), the Financial Services Authority may request information and/or recommendation letters regarding Principal Parties from other competent parties.
b. Presentation or Exposition by Prospective Controlling Principal Parties
1) In the context of administrative assessment, the prospective controlling Principal Party concerned must conduct a presentation or exposition.
2) In the event that the prospective controlling Principal Party is the central government or local government, the presentation or exposition as referred to in item 1) is conducted if deemed necessary.
3) The presentation or exposition must be conducted by the prospective controlling Principal Party in the context of administrative assessment as referred to in item 1), at least regarding:
a) the prospective controlling Principal Party's plans for the development of the Digital Financial Asset Service Provider to be owned and/or controlled for the shortest period of 3 (three) years since ownership; and b) the prospective controlling Principal Party's strategy in the event that the Digital Financial Asset Service Provider to be owned and/or controlled experiences financial difficulties.
4) The implementation of the presentation or exposition as referred to in item 1) is conducted in person directly at the Financial Services Authority office or another place designated by the Financial Services Authority.
5) The Financial Services Authority notifies the schedule for the implementation of the presentation or exposition as referred to in item 1) in writing to the Board of Directors of the Digital Financial Asset Service Provider or the Board of Directors of the prospective Digital Financial Asset Service Provider at the latest 10 (ten) working days after the application for approval to become a Principal Party as referred to in item 3 letter a item 3) and administrative requirement documents as referred to in item 3 letter a item 4) are received completely and correctly by the Financial Services Authority.
6) Prospective controlling Principal Parties who cannot attend the scheduled implementation of the presentation or exposition as referred to in item 5) must submit a written notification accompanied by valid reasons to the Financial Services Authority at the latest 1 (one) working day before the implementation of the competence and propriety assessment.
7) Based on the written notification as referred to in item 6), the Financial Services Authority may grant 1 (one) opportunity for presentation or exposition and submit a new schedule for the implementation of the presentation or exposition to the prospective controlling Principal Party.
8) In the event that:
a) the prospective controlling Principal Party does not attend the implementation of the presentation or exposition without notification or with notification but the reason for absence is not accepted by the Financial Services Authority; b) the Financial Services Authority does not grant the opportunity for presentation or exposition to the prospective controlling Principal Party as referred to in item 7); or c) the prospective controlling Principal Party does not attend the implementation of the presentation or exposition according to the new schedule without notification, the Financial Services Authority cancels the application for approval to become a controlling Principal Party through a notification of cancellation of the controlling Principal Party application.
9) The presentation or exposition as referred to in item 1) is conducted in the Indonesian language.

10) Prospective controlling Principal Parties who cannot speak Indonesian must provide their own interpreter services during the implementation of the presentation or exposition.
11) In the event that the prospective controlling Principal Party is a legal entity, the presentation or exposition as referred to in item 1) may be conducted by the directors of that legal entity or directors of other legal entities in its business group or the owners and ultimate shareholders of that legal entity.
12) In the event that the directors of other legal entities in its business group or the owners and ultimate shareholders of that legal entity as referred to in item 11) are unable to attend, they may be represented by another official 1 (one) level below the director based on an appointment letter (power of attorney).
13) The presentation or exposition of prospective controlling Principal Parties, in addition to being conducted in person as referred to in item 4), may be conducted online with certain considerations.
14) Certain considerations as referred to in item 13) include: distance factors, government policies restricting offline activities, and/or readiness factors of the Digital Financial Asset Service Provider submitted to the Financial Services Authority.
15) Readiness factors of the Digital Financial Asset Service Provider as referred to in item 14) are:
a) having reliable infrastructure to be able to follow the implementation of online presentations, expositions, or clarifications via video conference media; b) the prospective Principal Party participating in the implementation of clarification is the prospective Principal Party and not represented; and c) maintaining the confidentiality of information used in the implementation of presentations, expositions, or clarifications.
16) The technical readiness factors of the Digital Financial Asset Service Provider are accompanied as referred to in item 15) with a statement letter from the Board of Directors of the Digital Financial Asset Service Provider or prospective Digital Financial Asset Service Provider.
c. Clarification of Prospective Management Principal Parties
1) Based on the results of the administrative assessment conducted as referred to in letter a and information and/or recommendation letters obtained by the Financial Services Authority regarding prospective management Principal Parties from other competent parties as referred to in letter a item 5), the Financial Services Authority may determine prospective management Principal Parties requiring a clarification process, if among others:
a) there is negative information regarding the prospective management Principal Party; b) the prospective management Principal Party does not yet have experience at a Financial License Holder or Digital Financial Asset Service Provider relevant to the targeted position and considering the position, size, complexity, and/or problems of the Digital Financial Asset Service Provider where the party will be nominated; and/or c) the prospective management Principal Party was previously determined not to be approved in nominations at a Financial License Holder or Digital Financial Asset Service Provider previously.
2) The provisions regarding the need for clarification implementation for prospective management Principal Parties of Digital Financial Asset Service Providers other than those referred to in item 1) may also be implemented based on the criteria table for management Principal Parties requiring a clarification process as stated in Appendix II, which is an integral part of this Financial Services Authority Circular.
3) The Financial Services Authority conducts clarification of prospective management Principal Parties as referred to in item 1) to obtain explanations from the concerned party regarding information obtained by the Financial Services Authority or to assess the party's experience or expertise.
4) Prospective management Principal Parties must attend the implementation of clarification as referred to in item 1) in person directly at the Financial Services Authority office or another place designated by the Financial Services Authority.
5) The Financial Services Authority notifies the schedule for the implementation of clarification as referred to in item 1) in writing to the Board of Directors at the latest 10 (ten) working days after the application for approval to become a Principal Party as referred to in item 3 letter a item 3) along with administrative requirement documents as referred to in item 3 letter a item 4) are received completely and correctly by the Financial Services Authority.
6) Prospective management Principal Parties who cannot attend the scheduled implementation of clarification as referred to in item 5) must submit a written notification accompanied by valid reasons to the Financial Services Authority at the latest 1 (one) working day before the clarification.
7) Based on the written notification as referred to in item 6), the Financial Services Authority may grant 1 (one) opportunity for clarification and submit a new schedule for the implementation of clarification to the prospective management Principal Party.
8) In the event that:
a) the prospective management Principal Party does not attend the implementation of the presentation or exposition as referred to in item 5) without notification or with notification but the reason for absence is not accepted by the Financial Services Authority; b) the Financial Services Authority does not grant the opportunity for clarification with a new schedule to the prospective management

Principal Party;

Main managers as referred to in number 7); or c) prospective Principal Manager parties are absent from the presentation or briefing according to the new schedule without notification as referred to in number 7), The Financial Services Authority cancels the application to obtain approval as a prospective Principal Manager party through notification of the cancellation of the prospective Principal Manager party's application.
9) Clarification as referred to in number 1) is conducted in Indonesian.
10) Prospective Principal Manager parties who cannot speak Indonesian must provide their own interpreter services during the clarification process.
11) Clarification as referred to in number 1), in addition to being conducted face-to-face as referred to in number 4), may be conducted online with certain considerations.
12) The provisions regarding certain considerations in the implementation of online presentations and briefings for prospective Principal Controlling Parties as referred to in letter b numbers 14) through 16) apply mutatis mutandis in providing considerations for the implementation of clarification for prospective Principal Manager parties.

Termination of Fit and Proper Assessment of Principal Parties
a. The Financial Services Authority terminates the fit and proper assessment of prospective Principal Parties of Digital Financial Assets (DFA) Institutions (IAKD) if the prospective party is undergoing:
1) legal proceedings;
2) fit and proper assessment proceedings at the Financial Services Authority; and/or
3) reassessment proceedings due to indications of integrity, financial viability, financial reputation, and/or competence issues at a DFA Institution (LJK) or DFA Institution (IAKD).
b. The term "undergoing legal proceedings" as referred to in letter a number 1) means that the prospective Principal Party is undergoing bankruptcy proceedings, investigation proceedings, or judicial proceedings (including appeals and cassation) in cases involving:
1) criminal offenses in the financial services sector;
2) criminal offenses stipulated in the Criminal Code (KUHP) and/or similar foreign criminal codes with a prison sentence penalty of 1 (one) year or more; and/or
3) other criminal offenses with a prison sentence penalty of 1 (one) year or more, including but not limited to corruption, money laundering, narcotics/psychotropics, smuggling, customs, excise, human trafficking, illegal arms trade, terrorism, counterfeiting currency, tax offenses, forestry offenses, environmental offenses, and maritime and fisheries offenses;
c. The term "undergoing fit and proper assessment proceedings at the Financial Services Authority" as referred to in letter a number 2) means that the prospective Principal Party has submitted an application for fit and proper assessment to the Financial Services Authority as a prospective Principal Party at a DFA Institution (LJK) or DFA Institution (IAKD).
d. The Financial Services Authority terminates the fit and proper assessment of prospective Principal Parties undergoing fit and proper assessment proceedings at the Financial Services Authority as referred to in letter a number 2) regarding the most recent nomination submitted by the DFA Institution (IAKD) to the Financial Services Authority. e. The term "undergoing reassessment proceedings due to indications of integrity, financial viability, financial reputation, and/or competence issues at a DFA Institution (IAKD) or DFA Institution (LJK)" as referred to in letter a number 3) means that the prospective Principal Party is in the process of reassessment due to indications of integrity, financial viability, financial reputation, and/or competence issues in the capacity:
1) of the person as a party who owns, manages, oversees, and/or has significant influence over the DFA Institution (IAKD) or DFA Institution (LJK); or
2) of the person who no longer owns, manages, oversees, and/or has significant influence over the DFA Institution (IAKD) or DFA Institution (LJK).
f. The Financial Services Authority notifies in writing the termination of the fit and proper assessment to the DFA Institution (IAKD) that submitted the nomination. g. A prospective Principal Party whose fit and proper assessment has been terminated by the Financial Services Authority may be nominated again to the Financial Services Authority to become a Principal Party if the person has completed the proceedings as referred to in letter a. h. The term "having completed the proceedings" as referred to in letter g includes:
1) having completed legal proceedings, evidenced by:
a) a letter of order to stop investigation (SP3); b) a court decision that has obtained permanent legal force stating that the person is declared not guilty; c) information/court decision that has obtained permanent legal force proving that the prospective Principal Party is not declared bankrupt/declared guilty regarding the bankruptcy of the company; or d) other relevant documents.
2) having completed fit and proper assessment proceedings at the Financial Services Authority; and/or
3) having completed reassessment proceedings due to indications of integrity, financial viability/reputation, and/or competence issues at a DFA Institution (IAKD) if the person is declared by the Financial Services Authority not to have proven issues regarding integrity, financial viability, financial reputation, and/or competence.
Procedures for Determining Fit and Proper Assessment Results and Consequences for Principal Parties
a. Classification of Assessment Results
1) The results of the fit and proper assessment are determined as:
a) approved; or b) not approved.
2) Prospective Principal Parties who are approved as referred to in number 1) letter a) are declared to meet the requirements and obtain approval from the Financial Services Authority to become Principal Parties at a DFA Institution (IAKD).
3) Prospective Principal Parties who are not approved as referred to in number 1) letter b) are declared not to meet the requirements and do not obtain approval from the Financial Services Authority to become Principal Parties at a DFA Institution (IAKD).
b. Determination and Submission of Fit and Proper Assessment Results
1) The Financial Services Authority determines the results of the fit and proper assessment of prospective Principal Parties within a maximum of 30 (thirty) working days after all application documents are received completely.
2) In the event that the fit and proper assessment of prospective Principal Parties is conducted during the application for establishment, merger, and/or consolidation of a DFA Institution (IAKD), the Financial Services Authority provides the determination of the fit and proper assessment results within a timeframe in accordance with regulations governing the issuance of licenses for the establishment, merger, and/or consolidation of DFA Institutions (IAKD).
3) The term "establishment license" as referred to in number 2) refers to the business license of a DFA Institution (IAKD).
4) The results of the fit and proper assessment, being approved or not approved for the application of prospective Principal Parties as referred to in letter a number 1), are submitted in writing to the DFA Institution (IAKD) that submitted the nomination.
5) The Financial Services Authority may notify the results of the fit and proper assessment to interested parties in the implementation of the functions, duties, and authorities of the Financial Services Authority or as required by legislation.
c. Consequences of Fit and Proper Assessment Results for Controlling Principal Parties
1) For prospective Controlling Principal Parties who are shareholders approved as referred to in letter a number 1) letter a) by the Financial Services Authority, the person may purchase shares of the DFA Institution (IAKD).
2) The share purchase as referred to in number 1) must be conducted no later than 3 (three) months from the date the Fit and Proper Assessment results were determined.
3) In the event that the prospective Controlling Principal Party does not purchase shares within the timeframe as referred to in number 2), the Financial Services Authority may cancel the approval as referred to in letter a number 1) letter a).
4) For prospective Controlling Principal Parties who are shareholders not approved as referred to in letter a number 1) letter b) or whose approval has been cancelled by the Financial Services Authority but who already hold shares in the DFA Institution (IAKD), then:
a) the person must transfer their share ownership in the relevant DFA Institution (IAKD) and cease control; and b) restrictions are placed on the shareholder rights at the relevant DFA Institution (IAKD). The restrictions referred to mean that shareholder rights are only recognized up to the amount of shares held initially before the addition of shares that caused the person to become a Principal Shareholder (PSP).
5) The term "transferring share ownership in the relevant DFA Institution (IAKD)" as referred to in number 4) letter a) means transferring share ownership in the relevant DFA Institution (IAKD) so that the person no longer meets the criteria as a Principal Shareholder (PSP).
6) The transfer of share ownership as referred to in number 4) letter a) must be conducted no later than 1 (one) year from the date of disapproval or cancellation by the Financial Services Authority.
7) The term "shareholder rights" as referred to in number 4) letter b) includes, for example, the right to attend, quorum calculation, voting in the General Meeting of Shareholders (RUPS), and the right to receive distributed dividends.
8) In the event that a prospective Controlling Principal Party who is a shareholder does not transfer share ownership within the timeframe as referred to in number 6), the shareholder rights as referred to in number 7) for all shares owned are not recognized until the person transfers the share ownership.
9) The Financial Services Authority may designate parties not permitted to receive share transfers as referred to in number 4) letter a).
10) Parties not permitted to receive share transfers as referred to in number 9) are parties affiliated with the prospective Controlling Principal Party who is a shareholder, consisting of:
a) parties having a family relationship up to the second degree with the prospective Controlling Principal Party who is a shareholder, including their business group; b) parties who are controllers of the prospective Controlling Principal Party who is a shareholder; c) parties where the prospective Controlling Principal Party who is a shareholder acts as a controller; and d) parties having financial interdependence with the prospective Controlling Principal Party who is a shareholder.
11) The term "family relationship up to the second degree" as referred to in number 10) letter a) refers to both vertical and horizontal relationships, including parents-in-law, children-in-law, and siblings-in-law, covering:
a) biological/step/adopted parents; b) biological/step/adopted siblings and their spouses; c) biological/step/adopted children; d) biological/step/adopted grandparents; e) biological/step/adopted grandchildren; f) biological/step/adopted siblings of parents and their spouses; g) spouses; h) parents-in-law; i) siblings-in-law; j) spouses of biological/step/adopted children; k) grandparents of spouses; l) spouses of biological/step/adopted grandchildren; and/or m) biological/step/adopted siblings of spouses and their spouses.
12) In the event that the transfer of share ownership as referred to in number 4) letter a) is conducted by transferring shares to parties not permitted to receive share transfers as referred to in number 10), then:
a) the transfer is not considered as a transfer of ownership as referred to in number 4) letter a); b) the DFA Institution (IAKD) is prohibited from recording the party receiving the transfer in the shareholder list of the DFA Institution (IAKD); and c) the party receiving the transfer does not obtain their rights as a shareholder.
13) The Financial Services Authority cancels the approval as referred to in letter a number 1) letter a) if, after approval is granted:
a) it is discovered that information or documents submitted during the fit and proper assessment process were incorrect, causing the approved Principal Party to no longer meet the fit and proper requirements; and/or b) information obtained from other authorities causes the approved party to no longer meet the fit and proper requirements.
14) Cancellation of approval by the Financial Services Authority as referred to in number 3) and number 13) is communicated via a cancellation letter.
d. Consequences of Fit and Proper Assessment Results for Managerial Principal Parties
1) For prospective Managerial Principal Parties approved by the Financial Services Authority, they must be appointed to their positions according to the positions submitted during the fit and proper assessment application no later than 3 (three) months from the date the fit and proper assessment results were determined.
2) In the event that after the timeframe as referred to in number 1) has passed, the Principal Party approved by the Financial Services Authority as referred to in number 1) has not yet been appointed, the DFA Institution (IAKD) submitting the nomination must notify the Financial Services Authority of the reasons for the non-appointment of the said Managerial Principal Party no later than 10 (ten) working days from the timeframe as referred to in number 1).
3) For prospective Managerial Principal Parties not approved by the Financial Services Authority but who have already been appointed as Principal Parties, the DFA Institution (IAKD) must convene a General Meeting of Shareholders (RUPS) to cancel the appointment of the person within a maximum of 3 (three) months from the date the person was declared to have their application not approved.
4) For prospective Managerial Principal Parties not approved by the Financial Services Authority, they may be nominated again to the Financial Services Authority no sooner than 6 (six) months from the date of the disapproval determination by the Financial Services Authority.
5) In the event that a prospective Principal Party is not approved due to competence requirements, the person may be nominated before 6 (six) months, namely no shorter than 1 (one) month after being declared not approved, in:
(1) a different position at the same level or lower within the same DFA Institution (IAKD); (2) a position at a similar DFA Institution (IAKD) with lower size and complexity; or (3) a position at a different DFA Institution (IAKD).
6) The re-nomination of a Managerial Principal Party not approved due to competence requirements as referred to in number 5) must be accompanied by supporting documents proving that the re-nominated candidate has improved their competence, for example: certification of competence improvement required according to the job level at the DFA Institution (IAKD) targeted by the prospective Principal Party.

III. REASSESSMENT OF PRINCIPAL PARTIES

Scope of Reassessment of Principal Parties
a. Principal Parties Subject to Reassessment
1) Principal Parties subject to reassessment include:
a) Controlling Principal Parties, namely Principal Shareholders (PSP); b) Managerial Principal Parties, namely:
(1) members of the Board of Directors; and
(2) members of the Board of Commissioners.
2) Reassessment of Principal Parties is conducted against:
a) Principal Parties indicated to be involved and/or responsible for integrity, financial viability, financial reputation, and/or competence issues; or b) Principal Parties who no longer own, manage, oversee, and/or have influence over the DFA Institution (IAKD) at the time of reassessment, who are indicated to be involved and/or responsible for integrity, financial viability, financial reputation, and/or competence issues. b. Scope of Reassessment of Principal Parties
1) The implementation of reassessment of Principal Parties is conducted at any time if, based on evidence, data, and/or information obtained from indirect supervision (off-site supervision), direct supervision (on-site supervision), and/or other information obtained by supervisors, there are indications of involvement and/or responsibility for:
a) integrity and/or financial viability issues at Controlling Principal Parties; or b) integrity, financial reputation, and/or competence issues at Managerial Principal Parties.
2) Integrity and/or financial viability issues for Controlling Principal Parties as referred to in number 1) letter a) are issues related to:
a) actions, whether directly or indirectly, such as:
(1) influencing and/or ordering Principal Parties and/or employees of the DFA Institution (IAKD) to conceal and/or obscure violations of certain regulations or financial conditions and/or transactions, including but not limited to:
(1) false recording and/or fictitious transactions, whether on the asset or liability side of the DFA Institution (IAKD), including transactions in administrative accounts; (2) embezzlement or manipulation; (3) incorrect bookkeeping and/or financial reporting practices of the DFA Institution (IAKD); (4) hacking of the DFA Institution (IAKD)'s information technology systems; and (5) concealing, destroying, and/or eliminating bookkeeping records and/or transaction supporting documents or bookkeeping records of the DFA Institution (IAKD); (2) influencing and/or ordering Principal Parties and/or employees of the DFA Institution (IAKD) to provide unfair benefits to shareholders, Principal Parties, employees of the DFA Institution (IAKD), and/or other parties that can harm or reduce the profits of the DFA Institution (IAKD), including but not limited to:
(a) sale and/or purchase of assets, including assets in the form of investment instruments owned by the DFA Institution (IAKD), at prices unfair compared to market prices; (b) provision of facilities and/or salaries not in accordance with legislation and/or unfair to members of the Board of Commissioners, members of the Board of Directors, employees, and/or other parties; (c) provision of commissions to other parties unfairly in connection with the conduct of business activities; (d) receipt of fees unfairly in connection with the conduct of business activities; and (e) actions utilizing the DFA Institution (IAKD) to finance personal interests and/or business groups illegally; (3) influencing and/or ordering Principal Parties and/or employees of the DFA Institution (IAKD) to commit acts violating prudential principles in the financial services sector and/or good management principles of the DFA Institution (IAKD), including but not limited to:
(a) unhealthy debt and/or liability management practices; (b) marketing products and/or conducting activities without approval from the Financial Services Authority; (c) purchase or disposal of assets, including assets in the form of investment instruments, without adhering to prudential principles and risk management; and (d) provision of funds to parties, sectors, and/or activities prohibited by legislation; (4) influencing and/or ordering Principal Parties and/or employees of the DFA Institution (IAKD) conducting business based on Sharia principles to commit acts violating Sharia principles in the Sharia financial services sector; b) proven to have committed criminal offenses decided by a court and having permanent legal force, namely:
(1) criminal offenses in the financial services sector; (2) criminal offenses stipulated in the Criminal Code (KUHP) and/or similar foreign criminal codes with a prison sentence penalty of 1 (one) year or more; and/or (3) other criminal offenses with a prison sentence penalty of 1 (one) year or more, including but not limited to corruption, money laundering, narcotics/psychotropics, smuggling, customs, excise, human trafficking, illegal arms trade, terrorism, counterfeiting currency, tax offenses, forestry offenses, environmental offenses, and maritime and fisheries offenses; c) causing the DFA Institution (IAKD) to experience difficulties endangering the continuity of the DFA Institution (IAKD) and/or endangering the financial services industry, including but not limited to actions violating legislation that can cause the DFA Institution (IAKD)'s business activities to be suspended and/or business license revoked; d) failing to execute orders from the Financial Services Authority to take and/or not take certain actions; e) having a history of non-performing loans and/or financing at DFA Institutions (LJK) and/or being a controller, member of the Board of Directors, member of the Board of Commissioners, or equivalent of a company with non-performing loans and/or financing, excluding non-performing loans and/or financing originating from annual fees, administrative fees, and/or other charges not originating from credit card usage transactions; f) proven to be declared bankrupt and/or being a shareholder, member of the Board of Directors, member of the Board of Commissioners, or equivalent, who is declared guilty causing a company to be declared bankrupt or have its business license revoked; g) failing to take necessary measures when the DFA Institution (IAKD) faces financial difficulties, including but not limited to:
(1) failing to take measures to increase capital contributions; or (2) failing to take measures to find new investors; h) refusing to provide commitments and/or failing to meet commitments agreed upon with the Financial Services Authority and/or the government, including but not limited to commitments agreed upon for

fulfilled by the Digital Financial Assets Institution Organizer as reflected in the direct examination results report of the Digital Financial Assets Institution Organizer;

i) hindering or interfering:
(1) efforts and implementation of the authority of the Financial Services Authority; and/or (2) efforts by the Principal Parties of the Digital Financial Assets Institution Organizer and/or other parties, in handling problems of the Digital Financial Assets Institution Organizer; and/or

j) integrity and/or financial feasibility problems other than letters a) to i) that contradict statutory regulations, including receiving sanctions from associations for violations of the code of ethics or being sued civilly for breach of contract related to violations committed by the Principal Parties based on findings of the Financial Services Authority.

3) Integrity, financial reputation, and/or competence problems for the management Principal Parties as referred to in item 1) letter b) are problems related to:

a) actions, whether direct or indirect, such as:
(1) concealing and/or obscuring violations of certain regulations or financial conditions and/or actual transactions, including:
(a) false recording and/or fictitious transactions, whether on the asset or liability side of the Digital Financial Assets Institution Organizer, including transactions in administrative accounts; (b) embezzlement or manipulation; (c) incorrect bookkeeping and/or financial reporting practices of the Digital Financial Assets Institution Organizer; (d) hacking of the information system technology of the Digital Financial Assets Institution Organizer; and (e) concealing, destroying, and/or eliminating bookkeeping records and/or supporting transaction documents or bookkeeping records of the Digital Financial Assets Institution Organizer;

(2) providing undue benefits to shareholders, Principal Parties, employees of the Digital Financial Assets Institution Organizer, and/or other parties that can harm or reduce the profits of the Digital Financial Assets Institution Organizer, including:
(a) sale and/or purchase of assets, including assets in the form of investment instruments owned by the Digital Financial Assets Institution Organizer, at prices that are unreasonable compared to market prices; (b) provision of facilities and/or salaries that do not comply with statutory regulations and/or are unreasonable to members of the Board of Commissioners, members of the Board of Directors, employees, and/or other parties; (c) receipt of fees that are unreasonable in connection with the conduct of business activities; and (d) actions that utilize the Digital Financial Assets Institution Organizer to finance personal interests and/or their business group's interests illegally;

(3) committing acts that violate prudential principles in the financial services sector and/or good management principles of the Digital Financial Assets Institution Organizer, including:
(a) unhealthy debt and/or obligation management practices; (b) marketing products and/or conducting activities that have not received approval from the Financial Services Authority; (c) purchase or disposal of assets, including assets in the form of investment instruments, without regard to prudential principles and risk management; and (d) provision of funds to parties, sectors, and/or activities prohibited by statutory regulations;

(4) violating Sharia principles in the Sharia financial services sector;

b) proven to have committed criminal offenses that have been decided by a court and have permanent legal force, namely:
(1) criminal offenses in the financial services sector; (2) criminal offenses listed in the Criminal Code (KUHP) and/or similar to the KUHP in foreign countries with a prison sentence threat of 1 (one) year or more; and/or (3) other criminal offenses with a prison sentence threat of 1 (one) year or more, including corruption, money laundering, narcotics/psychotropics, smuggling, customs, excise, human trafficking, illegal arms trafficking, terrorism, counterfeiting money, in the field of taxation, in the field of forestry, in the field of the environment, in the field of marine and fisheries;

c) causing the Digital Financial Assets Institution Organizer to experience difficulties that endanger the continuity of the Digital Financial Assets Institution Organizer's business and/or may endanger the financial services industry, including actions that violate statutory regulations that can cause the Digital Financial Assets Institution Organizer's business activities to be frozen and/or its business license to be revoked;

d) not implementing orders from the Financial Services Authority to carry out and/or not carry out certain actions;

e) having non-performing loans and/or financing at Financial Service Institutions and/or being a controller, member of the Board of Directors, member of the Board of Commissioners, or equivalent of a company that has non-performing loans and/or financing, excluding non-performing loans and/or financing arising from annual fees, administrative fees, and/or other charges that do not originate from credit card usage transactions;

f) proven to be declared bankrupt and/or being a shareholder, member of the Board of Directors, member of the Board of Commissioners, or equivalent, who is declared guilty causing a company to be declared bankrupt or have its business license revoked;

g) not conducting strategic management for the healthy development of the Digital Financial Assets Institution Organizer, including the ability to interpret the vision and mission of the Digital Financial Assets Institution Organizer, anticipate economic and financial services sector developments, analyze the situation of the Digital Financial Assets Institution Organizer's industry and industries directly related to the business activities of the Digital Financial Assets Institution Organizer; and

h) refusing to provide commitment and/or not fulfilling commitments agreed upon with the Financial Services Authority and/or the government, including those agreed to be fulfilled by the Digital Financial Assets Institution Organizer as reflected in the direct examination results report of the Digital Financial Assets Institution Organizer;

j) integrity, financial reputation, and/or competence problems other than letters a) to i) that contradict statutory regulations.

Reassessment Procedure
a. The Financial Services Authority conducts reassessment through the following stages:
1) implementation of clarification of evidence, data, and/or information to the Principal Parties being reassessed;
2) determination and transmission of the preliminary results of the reassessment to the Principal Parties being reassessed;
3) provision of responses from the Principal Parties being reassessed regarding the preliminary results of the reassessment; and
4) determination and notification of the final results of the reassessment to the Principal Parties being reassessed.

b. The Financial Services Authority sends a letter requesting clarification of evidence, data, and/or information as referred to in letter a item 1) to the Principal Parties being reassessed.

c. For Principal Parties who no longer own, manage, supervise, and/or have influence on the Digital Financial Assets Institution Organizer at the time of reassessment, notification for clarification requests can be done by correspondence through contactable parties and/or summons through mass media.

d. The Principal Parties being reassessed are given the opportunity to submit responses to the request for clarification of evidence, data, and/or information as referred to in letter a item 1), no later than 10 (ten) working days calculated from the date of the written request for clarification from the Financial Services Authority.

e. In the event that the party being reassessed is a controlling Principal Party in the form of a legal entity, responses to requests for clarification of evidence, data, and/or information are made by members of the Board of Directors or other parties in the legal entity authorized to represent the legal entity according to the articles of association or equivalent for foreign legal entities, or the ultimate shareholder of the legal entity.

f. In the event that the Principal Parties being reassessed do not use their right to submit clarification of evidence, data, and/or information in letter d, the Financial Services Authority determines and transmits the preliminary results of the reassessment to the Principal Parties being reassessed.

g. Based on the results of clarification of evidence, data, and/or information, the Financial Services Authority determines and transmits the preliminary results of the reassessment to the Principal Parties being reassessed.

h. The Principal Parties being reassessed are given the opportunity to submit responses to the preliminary results of the reassessment as referred to in letter f or letter g, no later than 10 (ten) working days calculated from the date of the Financial Services Authority's letter.

i. In the event that the Principal Parties being reassessed do not use their right to submit responses to the preliminary results of the reassessment within the established period as referred to in letter h, the Financial Services Authority determines the preliminary results of the reassessment as the final results of the reassessment.

j. In the event that the Financial Services Authority obtains new evidence, data, and/or information before the determination and notification of the final results of the reassessment as referred to in letter a item 4), the Financial Services Authority determines the final results of the reassessment by considering the new evidence, data, and/or information obtained.

k. The determination of the final results of the reassessment as referred to in letter i or letter j is done while still referring to the process as referred to in letter a items 1) to 3).

l. The Financial Services Authority may summon Principal Parties for clarification of evidence, data, and/or information in the reassessment of Principal Parties face-to-face.

m. The Financial Services Authority may conduct face-to-face clarification in the Reassessment of Principal Parties as referred to in letter l online with certain considerations.

n. The provisions regarding certain considerations in the implementation of presentations and explanations of candidate controlling Principal Parties online as referred to in Roman II item 4 letter b item 14) to item 16) apply mutatis mutandis in the implementation of interviews as referred to in letter m.

Final Results of Reassessment of Principal Parties
a. The Financial Services Authority determines the final results of the reassessment of Principal Parties with the predicate:
1) pass; or
2) fail.

b. The determination of the final results of the reassessment as referred to in letter a is based on the level of involvement and/or responsibility of the Principal Parties being reassessed, categorized as perpetrators.

c. The term perpetrator refers to:
1) a person who orders, instructs to do, or proposes the occurrence of an act;
2) a person who approves, jointly approves, or signs;
3) a person who carries out or jointly carries out an act based on orders, whether with or without pressure, and who ought to know or ought to suspect that the order contradicts statutory regulations, including:
a) a person who executes proposals/orders in the form of providing analysis/recommendation support for the occurrence of an act/decision and who ought to know or ought to suspect that the proposal/order contradicts statutory regulations and does not attempt to refuse to carry out the act or order; and b) a person who executes a decision and who ought to know or ought to suspect that the decision contradicts statutory regulations and does not attempt to refuse to carry out the act or order; and/or
4) a person who carries out an act due to a specific promise or reward.

d. The Financial Services Authority notifies the final results of the reassessment of Principal Parties in writing to controlling Principal Parties, Digital Financial Assets Institution Organizers, Principal Parties being reassessed, and other interested parties.

Consequences of Final Results of Reassessment of Principal Parties and Request for Judicial Review
a. Consequences of Final Results of Reassessment of Principal Parties
1) Principal Parties established with the predicate pass meet the requirements to remain as PSPs, members of the Board of Directors, and members of the Board of Commissioners.
Principal Parties established with the predicate pass meet the requirements to remain as controlling Principal Parties or management Principal Parties.

2) Controlling Principal Parties established with the predicate fail due to:
a) integrity problems, are prohibited from being:
(1) controlling Principal Parties at Financial Service Institutions or Digital Financial Assets Institution Organizers; (2) holding shares at Financial Service Institutions or Digital Financial Assets Institution Organizers; and/or (3) management Principal Parties at Financial Service Institutions or Digital Financial Assets Institution Organizers.

b) financial feasibility problems, are prohibited from being:
(1) controlling Principal Parties or holding shares at Digital Financial Assets Institution Organizers, for example, a controlling Principal Party at PT XYZ who is established to fail the reassessment due to financial feasibility problems is prohibited from holding shares at any Digital Financial Assets Institution Organizer; and/or (2) management Principal Parties at Digital Financial Assets Institution Organizers, for example, a management Principal Party at PT XYZ who is established to fail the reassessment due to financial reputation problems is prohibited from becoming a member of the Board of Directors, member of the Board of Commissioners at any Digital Financial Assets Institution Organizer.

3) Management Principal Parties established with the predicate fail due to:
a) integrity problems, are prohibited from being:
(1) controlling Principal Parties at Financial Service Institutions or Digital Financial Assets Institution Organizers; (2) holding shares at Financial Service Institutions or Digital Financial Assets Institution Organizers; and/or (3) management Principal Parties at Financial Service Institutions or Digital Financial Assets Institution Organizers.

b) financial reputation problems, are prohibited from being:
(1) controlling Principal Parties or holding shares at Digital Financial Assets Institution Organizers; and/or (2) management Principal Parties at Digital Financial Assets Institution Organizers.

c) competence problems, are prohibited from being management Principal Parties at Digital Financial Assets Institution Organizers.

4) The imposition of prohibition periods on Principal Parties established with the predicate fail as referred to in item 2) and/or item 3) is established:
a) for a period of 3 (three) years:
(1) for controlling Principal Parties in the event of proven actions as referred to in item 1 letter b item 2) letter a) item (3), item 2) letter a) item (4), item 2) letter d), item 2) letter e), item 2) letter g), item 2) letter h), item 2) letter i), or item 2) letter j); or (2) for management Principal Parties in the event of proven actions as referred to in item 1 letter b item 3) letter a) item (3), item 3) letter a) item (4), item 3) letter d), item 3) letter e), item 3) letter g), item 3) letter h), item 3) letter i), or item 3) letter j;

b) for a period of 5 (five) years:
(1) for controlling Principal Parties in the event:
(a) proven to have committed actions as referred to in item 1 letter b item 2) letter a) item (1) or item (2); or (b) proven to have committed actions as referred to in item 1 letter b item 2) letter a) item (3), item 2) letter a) item (4), item 2) letter d), item 2) letter e), item 2) letter g), item 2) letter h), item 2) letter i), or item 2) letter j), and the said actions:
i. are committed repeatedly;
ii. are committed cumulatively; and/or
iii. are proven to benefit oneself or other parties;
(2) for members of management Principal Parties in the event:
(a) proven to have committed actions as referred to in item 1 letter b item 3) letter a) item (1) or item (2); (b) proven to have committed actions as referred to in item 1 letter b item 3) letter a) item (3), item 3) letter a) item (4), item 3) letter d), item 3) letter e), item 3) letter g), item 3) letter h), item 3) letter i), or item 3) letter j, and the said actions:
i. are committed repeatedly;
ii. are committed cumulatively; and/or
iii. are proven to benefit oneself or other parties; or

c) for a period of 20 (twenty) years:
(1) for controlling Principal Parties in the event of proven actions as referred to in item 1 letter b item 2) letter b), letter c), and letter f); or (2) for management Principal Parties in the event of proven actions as referred to in item 1 letter b item 3) letter b), letter c), and letter f).

5) The prohibition period as referred to in item 4) is calculated from:
a) the date of the Financial Services Authority's determination letter as referred to in item 2 letter a item 4), in the event it is the final result of the Financial Services Authority's reassessment; or b) the date of the court decision that has permanent legal force stating that the Principal Parties being reassessed are proven to have committed criminal offenses as referred to in item 1 letter b item 2) letter b) and item 1 letter b item 3) letter b) or proven to be declared bankrupt and/or cause bankruptcy as referred to in item 1 letter b item 2) letter f) item 1 letter b item 3) letter f).

6) Principal Parties prohibited from becoming controlling Principal Parties or holding shares at Financial Service Institutions or Digital Financial Assets Institution Organizers as referred to in item 2) letter a) item (1), item (2), letter b) item (1), item 3) letter a) item (1), item (2), and/or letter b) item (1):
a) are prohibited from taking actions as controlling Principal Parties at Financial Service Institutions or Digital Financial Assets Institution Organizers; b) are prohibited from exercising rights as shareholders and the shares are not counted in the RUPS quorum; and c) are required to transfer all share ownership within a maximum period of 1 (one) year, from the date established with the predicate fail.

7) Digital Financial Assets Institution Organizers are required to include an explanation in the shareholder list of the Digital Financial Assets Institution Organizer regarding the status of Principal Parties as referred to in item 6).

8) The Financial Services Authority may establish a separate period for the share transfer obligation as referred to in item 6) letter c) in the event Principal Parties are subject to the obligation to transfer all share ownership in more than 1 (one) Digital Financial Assets Institution Organizer.

9) In the event that Principal Parties being reassessed as referred to in item 6) letter c) do not transfer all share ownership within the established period:
a) the prohibition period for Principal Parties is extended by 20 (twenty) years and does not eliminate the obligation to transfer shares; and b) dividend payments are postponed until the controlling Principal Parties transfer their share ownership.

10) The transfer of share ownership as referred to in item 6) letter c) or item 8) can be done through donation or sale to parties who do not have family relations up to the second degree and/or outside the business group.

11) In the event that the transfer of share ownership is done by transferring shares to parties who have family relations up to the second degree and/or business groups as referred to in item 10) from Principal Parties established with the predicate fail:
a) the transfer is not considered as a transfer of share ownership as referred to in item 6) letter c) or item 8); b) Digital Financial Assets Institution Organizers are prohibited from recording the receiving party in the shareholder list of the Digital Financial Assets Institution Organizer; and c) the receiving party does not obtain shareholder rights, namely:
(1) voting rights are not counted in the RUPS; (2) voting rights are not counted in determining the RUPS quorum; and (3) dividends are not delivered until the share ownership is transferred to parties who do not have family relations up to the second degree and/or outside the business group.

12) Principal Parties prohibited from becoming management Principal Parties at Financial Service Institutions or Digital Financial Assets Institution Organizers as referred to in item 2) letter a) item (3), item 2) letter b) item (2), item 3) letter a) item (3), item 3) letter b) item (2), and/or item 3) letter c):
a) are prohibited from taking actions as management Principal Parties at Financial Service Institutions or Digital Financial Assets Institution Organizers; and b) are required to cease being management Principal Parties at Financial Service Institutions or Digital Financial Assets Institution Organizers.

13) Digital Financial Assets Institution Organizers are required to follow up the provisions as referred to in item 12) no later than 3 (three) months from the date of notification from the Financial Services Authority.

14) In the event that management Principal Parties at Financial Service Institutions or Digital Financial Assets Institution Organizers as referred to in item 13) still take actions as management Principal Parties at Financial Service Institutions or Digital Financial Assets Institution Organizers, the prohibition period for management Principal Parties is extended by 20 (twenty) years.

15) Controlling Principal Parties who intentionally allow management Principal Parties who failed to take actions as management Principal Parties are given the predicate fail with a prohibition period of 20 (twenty) years, after prior reassessment as referred to in item 2 letter a.

16) Controlling Principal Parties established with the predicate fail as referred to in item 15) are subject to fail consequences for integrity problems as referred to in item 2).

b. Request for Judicial Review
1) Principal Parties established with the predicate fail as referred to in letter a item 2) and item 3) may submit a request for judicial review of the predicate fail before the prohibition period as referred to in letter a item 4) expires.

2) The request for reconsideration referred to in item 1) may be submitted if it meets the following criteria:
a) there is new evidence, data, and/or information regarding the absence, or failure to provide clarification or response during the reassessment; b) there is a final and binding court decision stating that the party designated with a "failed" predicate as referred to in letter a) is not proven to have committed the criminal offense as referred to in item 1) letter b) item 2) letter b) or item 3) letter b), is not proven to have been declared bankrupt and/or become a shareholder, member of the Board of Directors, or member of the Board of Commissioners, or equivalent, who is declared guilty causing a company to be declared bankrupt or have its business license revoked as referred to in item 1) letter b) item 2) letter f) or item 3) letter f); c) as a consequence of the implementation of statutory regulations; and/or d) having served ¾ (three-quarters) of the consequence period, and the Principal Party:
(1) has no negative records during the period of being declared failed; and (2) is committed to contributing significantly to the strengthening or rescue of the industry in the financial services sector, which is realized within a timeframe determined by the Financial Services Authority.

3) New evidence, data, and/or information regarding absence, or failure to provide clarification or response as referred to in item 2) letter a) must include strong and relevant reasons or considerations regarding the evidence of absence or failure to provide clarification or response, including:
a) illness that prevents the party being reassessed from functioning normally; and b) other reasons causing the party being reassessed to be unable to provide clarification or response within the timeframe determined by the Financial Services Authority.

4) The term "consequence of the implementation of statutory regulations" as referred to in item 2) letter c) includes, among others, the implementation of Law of the Republic of Indonesia Number 11 of 2016 concerning Tax Amnesty.

5) The term "having no negative records" as referred to in item 2) letter d) item (1) means not committing legal violations with a threat of criminal imprisonment/confinement of more than 1 (one) year, not causing bankruptcy, and/or becoming a shareholder, member of the Board of Directors, or member of the Board of Commissioners, or equivalent, who is declared guilty causing a company to be declared bankrupt or have its business license revoked.

6) The commitment to contribute significantly to the strengthening or rescue of the Digital Financial Assets Institution (IAKD) Industry as referred to in item 2) letter d) item (2) is stated, among others, in a written document containing a specific action plan to be realized or the provision of funds in the form of an escrow account.

7) The request for reconsideration as referred to in item 1) must be accompanied by the following documents:
a) identity documents, at least consisting of:
(1) copy of the electronic identity card (KTP); (2) curriculum vitae; (3) copy of the taxpayer identification number (NPWP); b) copy of the final decision of the Principal Party's reassessment result stating that the applicant failed; c) evidence documents according to the reconsideration request criteria, including:
(1) new evidence, data, and/or information regarding absence or failure to provide clarification or response during reassessment, such as an official letter from the hospital where the applicant was treated; (2) copy of a final and binding court decision stating that the applicant is not proven to have committed a criminal offense or is not proven to have been declared bankrupt and/or become a shareholder, member of the Board of Directors, or member of the Board of Commissioners, or equivalent, who is declared guilty causing a company to be declared bankrupt or have its business license revoked; and (3) official and valid evidence of consequences from the implementation of laws; d) evidence of having no negative records during the period of being declared failed, including:
(1) a stamped statement letter stating that the applicant:
(a) is not proven to have been declared bankrupt and/or become a shareholder, member of the Board of Directors, or member of the Board of Commissioners, or equivalent, who is declared guilty causing a company to be declared bankrupt or have its business license revoked; and (b) has never been sentenced for being proven to commit legal violations with a threat of sanctions of more than 1 (one) year; and (2) police record certificate (SKCK).

8) If necessary, the Financial Services Authority is authorized to request other supporting documents and/or information related to the reconsideration request documents as referred to in item 7).

9) The Financial Services Authority grants approval or rejection of the reconsideration request submitted by the Principal Party designated with a "failed" predicate based on:
a) examination of the completeness and truthfulness of documents; b) analysis of the reconsideration documents; and c) other considerations, such as the impact on the condition of the Digital Financial Assets Institution (IAKD) both individually and industrially.

10) If, based on the analysis results, it is found that there is a mismatch with the reconsideration request criteria and/or the submitted documents are incomplete, the Financial Services Authority notifies the applicant that the reconsideration request is rejected.

11) The applicant may submit a reconsideration request again if the reconsideration request criteria are met and/or the owned documents are complete.

12) If the criteria are met, the reconsideration request approved by the Financial Services Authority is carried out through the following steps:
a) clarification of evidence, data, and/or information to the Principal Party submitting the reconsideration request; b) determination and submission of the interim result of the reconsideration to the Principal Party submitting the reconsideration request; c) response from the Principal Party submitting the reconsideration request regarding the interim result of the reconsideration; and d) determination and notification of the final result of the reconsideration to the Principal Party submitting the reconsideration request.

13) Principal Parties declared passed in the reconsideration process may become Principal Parties through the fit and proper assessment process as referred to in Roman II of this Financial Services Authority Circular.

IV. SUBMISSION OF DOCUMENTS AND REPORTING

Submission of Fit and Proper Assessment Documents and Reassessment of Principal Parties
a. Submission of documents:
1) a request letter to obtain approval to become a Principal Party along with administrative requirement documents as referred to in Roman II item 3 letter a) item 3), item 4), and item 4 letter a) item 2), and the self-assessment result as referred to in Roman II item 3 letter d) item 2); and
2) clarification, and/or response from the Principal Party being assessed in the reassessment process as referred to in Roman III item 2 letter d), letter h), and/or documents related to the reconsideration request as referred to in Roman III item 4 letter b).
are submitted to the Financial Services Authority online via the Financial Services Authority's electronic system. b. Documents as referred to in letter a) submitted through the electronic system are original documents and/or color scans of original documents.
c. In the event that the Financial Services Authority's electronic system as referred to in letter b) is not yet available or experiences technical difficulties, the submission of documents as referred to in letter a) is submitted in the form of electronic documents via email through the address:
1) mailingroomsoemitro@ojk.go.id and pendaftaraniakd@ojk.go.id; or
2) other addresses determined by the Financial Services Authority.
d. In the event that the Financial Services Authority's email as referred to in letter c) experiences technical difficulties, the submission of documents is submitted to the Financial Services Authority offline by:
1) direct handover; or
2) sending through a courier service company.
e. Offline report submission as referred to in letter d) is addressed to:
Head of the Department of Regulation and Licensing of Financial Technology Innovation, Digital Financial Assets and Crypto Assets Soemitro Djojohadikusumo Building Jalan Lapangan Banteng Timur 2-4 Jakarta 10710, Indonesia

f. Documents are deemed received by the Financial Services Authority with the following conditions:
1) submission through the Financial Services Authority's electronic system is proven by a receipt proof from the Financial Services Authority's system;
2) submission via email is proven by a receipt from the Financial Services Authority's email; or
3) offline submission is proven by a receipt from the Financial Services Authority.

Reporting related to Fit and Proper Assessment Results and Reassessment of Principal Parties
a. Reporting related to Fit and Proper Assessment of Controlling Principal Parties, including:
1) Digital Financial Assets Institution (IAKD) Operators must report the transfer of share ownership as referred to in Roman II item 6 letter c) item 4) to the Financial Services Authority in accordance with statutory regulations governing the reporting of articles of association changes related to ownership changes applicable to each type of IAKD Operator, or at the latest 5 (five) working days after the General Meeting of Shareholders (GMS) approves the share transfer in the event there are no regulations governing the reporting of changes in controlling Principal Parties.
2) The purchase of IAKD Operator shares by prospective Controlling Principal Parties who are shareholders obtaining an "approved" predicate as referred to in Roman II item 6) letter c) item 2) is reported as an incidental report to the Financial Services Authority in accordance with the reporting regulations of each type of IAKD Operator.
b. Reporting related to Fit and Proper Assessment of Managerial Principal Parties, including:
1) The extension of the term of office of the same Managerial Principal Parties as referred to in Roman II item 1 letter c) is reported as an incidental report to the Financial Services Authority in accordance with the reporting regulations of each type of IAKD Operator, accompanied by the GMS decision that has been approved by the competent authority regarding the extension of the term of office.
2) IAKD Operators must report the appointment of prospective Managerial Principal Parties, as referred to in Roman II item 6 letter d) item 1), to the Financial Services Authority by referring to regulations governing the reporting of changes in Managerial Principal Parties applicable to each type of IAKD, or at the latest 5 (five) working days after the appointment in the event there are no regulations governing the reporting of changes in Managerial Principal Parties.
3) IAKD Operators must report the convening of the GMS to cancel the appointment of Managerial Principal Parties as referred to in Roman II item 6 letter d) item 3) to the Financial Services Authority by referring to regulations governing the reporting of changes in Managerial Principal Parties applicable to each type of IAKD, or at the latest 5 (five) working days after the GMS cancels the appointment of Managerial Principal Parties in the event there are no regulations governing the reporting of changes in Managerial Principal Parties.
c. IAKD Operators must report the transfer of share ownership as referred to in Roman III item 4 letter a) item 6) letter c) to the Financial Services Authority within a timeframe of at the latest 10 (ten) working days calculated from the date the GMS approves the share transfer.
d. IAKD Operators must report the follow-up as referred to in Roman III item 4 letter a) item 13) to the Financial Services Authority within a timeframe of at the latest 10 (ten) working days from the date of the GMS convening for the dismissal of Managerial Principal Parties. e. In addition to the reporting as referred to in letters a) through d), IAKD Operators must submit reports updating the data and information of the domicile of Principal Parties and/or contactable parties at the latest on May 1, 2026, and changes are reported as incidental reports to the Financial Services Authority in accordance with the reporting regulations of each type of IAKD Operator.

f. Reporting as referred to in letters a) through e) is submitted to the Financial Services Authority online via the reporting system managed by the Financial Services Authority. g. In the event that the Financial Services Authority's reporting system as referred to in letter f) is not yet available or experiences technical difficulties, the submission of documents as referred to in letters a) through e) is submitted in the form of electronic documents via email through the address:
1) mailingroomsumitro@ojk.go.id, in the event the Financial Services Authority's reporting system is not yet available;
2) mailingroommrp@ojk.go.id, in the event the Financial Services Authority's reporting system experiences technical difficulties; or
3) other addresses determined by the Financial Services Authority.
h. In the event that the Financial Services Authority's email as referred to in letter g) experiences technical difficulties, the submission of documents is submitted to the Financial Services Authority offline by:
1) direct handover; or
2) sending through a courier service company.
i. Offline report submission as referred to in letter h) is addressed to:
Head of the Department of Supervision of Financial Technology Innovation, Digital Financial Assets and Crypto Assets Soemitro Djojohadikusumo Building Jalan Lapangan Banteng Timur 2-4 Jakarta 10710, Indonesia

j. Documents are deemed received by the Financial Services Authority with the following conditions:
1) submission through the Financial Services Authority's reporting system is proven by a receipt proof from the Financial Services Authority's reporting system;
2) submission via email is proven by a receipt from the Financial Services Authority's email; or
3) offline submission is proven by a receipt from the Financial Services Authority.

This copy is consistent with the original
Head of the Legal Development Directorate
Legal Department signed.
Aat Windradi

V. CLOSING

At the time this Financial Services Authority Circular takes effect, item IV Fit and Proper Assessment and item V Reassessment of Principal Parties, Appendix III, and Appendix IV of Financial Services Authority Circular Number 20/SEOJK/07/2024 concerning the Conduct of Digital Financial Assets including Crypto Assets Trading, are revoked and declared invalid.
This Financial Services Authority Circular takes effect on October 1, 2025.

Established in Jakarta on September 29, 2025
EXECUTIVE HEAD OF SUPERVISOR OF FINANCIAL TECHNOLOGY INNOVATION, DIGITAL FINANCIAL ASSETS AND CRYPTO ASSETS FINANCIAL SERVICES AUTHORITY REPUBLIC OF INDONESIA,

HASAN FAWZI signed.

APPENDIX I
FINANCIAL SERVICES AUTHORITY CIRCULAR
REPUBLIC OF INDONESIA
NUMBER 21/SEOJK.07/2025
CONCERNING
FIT AND PROPER ASSESSMENT AND REASSESSMENT FOR PRINCIPAL PARTIES IN THE FINANCIAL TECHNOLOGY INNOVATION SECTOR, DIGITAL FINANCIAL ASSETS AND CRYPTO ASSETS

PART A
FORMAT OF REQUEST LETTER TO OBTAIN APPROVAL TO BECOME A PRINCIPAL PARTY

REQUEST LETTER TO OBTAIN APPROVAL TO BECOME A PRINCIPAL PARTY Number : (date/month/year) Attachment : A.
Subject : Request to Obtain Approval to Become Principal Party PSP/ President Director/Director/Principal Commissioner/Commissioner/Independent Commissioner *)

To:
Executive Head of Supervisor of Financial Technology Innovation, Digital Financial Assets and Crypto Assets u.p. Head of the Department of Regulation and Licensing of Financial Technology Innovation Financial Services Authority Digital Financial Assets and Crypto Assets

Hereby we submit a request to obtain approval to become a Principal Party for:

Name : ........................................................
Position : As PSP/President Director/Director/Principal Commissioner/Commissioner/Independent Commissioner *)
Name : ........................................................
Position : As PSP/President Director/Director/Principal Commissioner/Commissioner/Independent Commissioner *)
... etc :

To complete the aforementioned request, we attach digital copies (softcopy) of the following administrative requirement documents:

questionnaire;
curriculum vitae;
copy of identity document in the form of an identity card (KTP) or valid passport;
taxpayer identification number (NPWP) for Indonesian citizens/Indonesian legal entities or equivalent documents valid for foreign citizens/foreign legal entities;
annual tax return (SPT) for the last 2 (two) years );
Police Clearing Certificate (SKCK)/Police Clearing or equivalent document for Foreigners;
copy of establishment documents in the form of articles of association of the legal entity, including the last amendment to the articles of association approved by the competent authority or equivalent documents for foreign business entities in accordance with regulations in the country of origin*);
copy of taxpayer identification number (NPWP) for Indonesian legal entities or equivalent documents valid for foreign legal entities*);
statement letter meeting aspects of integrity, financial reputation or financial feasibility, and not currently undergoing fit and proper assessment at another IAKD Operator or Financial Services Authority*);
PSP ownership structure up to the ultimate owner/controller (ultimate shareholders *);
stamped statement letter from ultimate shareholders, containing detailed explanation regarding the nature of the relationship between ultimate shareholders and prospective controlling shareholders *);
stamped statement letter from ultimate shareholders that has been filled out completely, containing a statement of not practicing nominee arrangements, loan of name shares, or acting in concert, which has the potential to cause negative impacts on the IAKD Operator*);
other documents related to indirect shareholders up to ultimate shareholders (in the event required by the Financial Services Authority*);
copy of the highest educational diploma *);
certification documents relevant to the position at the IAKD Operator *)
documents of training and seminars attended in the form of photocopies of graduation certificates or attendance certificates for training attended (if any)*);
letter of work experience*);
letter of recommendation and/or letter of statement to resign from previous workplace ) that is old);
awards relevant to the financial industry achieved (if any)*);
skills mastered in the management of the IAKD Operator and/or mastery of foreign languages*);
the latest annual financial report audited by a public accountant or financial report audited internally by the Party in charge of the finance or audit function at the IAKD Operator);
information regarding the source of funds used as capital contribution to the IAKD Operator in the form of capital deposit proof and/or copy of bank statements for 3 (three) months containing capital receipt or transfer transactions );
documents regarding plans to be carried out after being appointed to the targeted position*); and
statement letter of non-affiliation with the IAKD Operator for prospective independent commissioners *).

Hereby we also submit the list of fulfillment of administrative requirements as referred to in the Attachment of this Financial Services Authority Circular.

It is submitted that for the purposes of this reporting, you may contact Mr./Ms. ...) via email address ... or telephone number ...

Thus this request is submitted, we thank you for your attention, Sir/Madam *)

Owner/Founder/Board of Directors/Board of Commissioners/Other Party appointed by GMS *) IAKD Operator ………………………………

*) strike out what is not necessary
) this requirement is submitted for prospective PSP applications *) this requirement is submitted for prospective PSP applications in the form of a legal entity ) this requirement is submitted for prospective PSP applications as an individual *) this requirement is submitted for prospective applications for members of the Board of Directors and members of the Board of Commissioners

PART B
FORMAT OF LIST OF FULFILLMENT OF ADMINISTRATIVE REQUIREMENT DOCUMENTS

LIST OF FULFILLMENT OF ADMINISTRATIVE REQUIREMENT DOCUMENTS
FOR REQUESTS TO OBTAIN APPROVAL TO BECOME A CONTROLLING PRINCIPAL PARTY (INDIVIDUAL)

List of Fulfillment of Administrative Requirement Documents Request to Obtain Approval to Become Controlling Principal Party (Individual)

Company Name :
Company Type :
Request Letter Number :
Request Letter Date :

The Company submits the following individual name to be proposed as a prospective PSP:
No Name of Prospective PSP Domicile Ownership Percentage Brief Description of Background Request for :
Approval to become
Principal Party
Contact Person (Name, Phone Number, e-mail) :

No
Description of Document
Substance
Yes No
Information
1.
Company
Request Letter
Does the request letter signed by the prospective owner/founder/Board of Directors/Board of Commissioners/other party appointed by GMS?
Has the appropriate format as per Part A of Appendix I of this SEOJK been used?
2. Curriculum
Vitae
Has the questionnaire conformed to the format of Part D of Appendix I of this SEOJK?
Has it been attached with a copy of a valid KTP/Passport?
Has it been attached with a copy of NPWP for
Indonesian citizens or equivalent documents valid for foreign citizens?
Has it been attached with a recent color passport photo?
Has it been attached with the latest year's tax SPT?
Has it been attached with information regarding the source of funds used as capital contribution to the IAKD Operator in the form of capital deposit proof and/or copy of bank statements for 3 (three) months containing capital receipt or transfer transactions?
3. Curriculum
Vitae
Has the curriculum vitae conformed to the format of Part F of Appendix I of this SEOJK?
4.
Statement
Letter from Individual
PSP
Has the statement letter from the individual PSP conformed to the format of Part E in Appendix I of this SEOJK?

Signature above stamp

We declare that the entries above are consistent with the actual documents and if there are differences, corrections will be made.

Owner/Founder/Official of
IAKD Operator *) who is competent
................
(signature)
(full name)
………………………………
(position)
*) strike out what is not necessary

LIST OF COMPLIANCE WITH ADMINISTRATIVE REQUIREMENT DOCUMENTS
APPLICATION FOR OBTAINING APPROVAL TO BE A CONTROLLING PRINCIPAL PARTY IN THE FORM OF A LEGAL ENTITY

List of Compliance with Administrative Requirement Documents Application for Obtaining Approval to Become a Controlling Principal Party in the Form of a Legal Entity

Company Name :
Company Type :
Letter Number : Fill in according to the number of the application cover letter Date of Letter : Fill in according to the date of the application cover letter

The Company submits the following legal entity to be proposed as a candidate Legal Entity PSP:

No Company Name Representative of the Company Position of the Principal Party Represented Domicile Ownership Percentage Brief description of the background of the application to obtain approval to become a Principal Party

Contact Person (Name, Phone Number, e-mail) :

No Description Document Details Substance Yes No

Company application letter
Has the application letter been signed by the prospective owner/founder/Directors/Board of Commissioners/other parties appointed by the GMS*)?
Has the appropriate format been used according to the format in Part A of Appendix I of this SEOJK?
Representative of the company
Is the legal entity/business group of the candidate PSP, which is a shareholder*), represented by the Board of Directors/officials at the Director level?
Has the company questionnaire been used according to the format in Part D of Appendix I of this SEOJK?
Has it been attached with a copy of the establishment document in the form of a deed of establishment of a legal entity or an equivalent document for foreign business entities according to the regulations in the country of origin? Has it been attached with a copy of the Taxpayer Identification Number (NPWP) for Indonesian legal entities or an equivalent document applicable to foreign legal entities?
Curriculum Vitae
Has the curriculum vitae of the Board of Directors members and Board of Commissioners members been in accordance with the format in Part F of Appendix I of this SEOJK?
Has it been attached with a valid ID card/Passport?
Has it been attached with an NPWP for Indonesian citizens or an equivalent document applicable to foreign citizens?
Annual Financial Report
Has it been attached with the latest annual financial report audited by a public accountant?
Ownership Structure
Has it been attached with the company ownership structure up to the ultimate shareholders?
Declaration Letter
Has it been attached with a declaration letter from the Board of Directors or equivalent officials representing the legal entity/PSP which is a shareholder*) in accordance with the format in Part E of Appendix I of this SEOJK?

Signed above the stamp
Has it been attached with a declaration letter from ultimate shareholders that has been drafted and sufficiently stamped, containing detailed explanatory statements regarding the nature of the relationship between ultimate shareholders and prospective controlling shareholders?

Signed above the stamp
Has it been attached with a declaration letter from ultimate shareholders that has been drafted and sufficiently stamped, containing a statement of not practicing nominee arrangements, loan of names for shares, or acting in concert, which has the potential to cause negative impacts on the Digital Financial Asset Service Provider (PSP)?

Signed above the stamp
7. Other Documents
Has it been attached with other documents related to indirect shareholders up to the ultimate shareholder?

If required by the Financial Services Authority

We declare that the above entries are in accordance with the actual documents and if there are differences, corrections will be made.

Owner/Founder/Official of the Digital Financial Asset Service Provider (PSP)*) who is authorized *)
................
(signature)
(full name)
………………………………
(position)
*) strike out what is not necessary

LIST OF COMPLIANCE WITH ADMINISTRATIVE REQUIREMENT DOCUMENTS
FOR BOARD OF DIRECTORS MEMBERS/BOARD OF COMMISSIONERS MEMBERS

List of Compliance with Administrative Requirements Application for Obtaining Approval to Become a Principal Party for Board of Directors Members/Board of Commissioners Members

Company Name :
Company Type :
Application Letter Number :
Application Letter Date :

The Company submits the following individual names to be proposed as the company's Principal Party:

No Name Position Brief description of the background of the application for change of Board of Directors/Board of Commissioners *) Reason for candidacy :
Name of the official being replaced
Reason for replacement of the previous position :
Term of office
Contact Person (Name, Phone Number, e-mail) :

No Description Document Details Substance Yes No

Company application letter
Has the application letter been signed by the prospective owner/founder/Directors/Board of Commissioners/other parties appointed by the GMS*?
Has the appropriate format been used according to the format in Part A of Appendix I of this SEOJK?
Curriculum Vitae
Has the curriculum vitae been in accordance with the format in Part F of Appendix I of this SEOJK?
Has it been attached with a copy of a valid ID card/Passport?
Has it been attached with a copy of an NPWP for Indonesian citizens or an equivalent document applicable to foreign citizens?
Has it been attached with formal education history documents in the form of copies of the last diploma and expertise certificates (if any)?
Has it been attached with documents of training and seminars attended (if any)?
Has it been attached with a letter of work experience?
Has it been attached with recommendation letters and/or letters of intent to resign from the old Digital Financial Asset Service Provider (PSP)?
Has it been attached with awards relevant to the financial industry achieved (if any)?
Declaration Letter
Has the declaration letter from the party nominated as a Board of Directors member/Board of Commissioners member *) been in accordance with the format in Appendix I of this SEOJK?

Signed above the stamp.
Has it been attached with a writing regarding the plans to be carried out after being appointed to the targeted position?
Has it been attached with a declaration letter of non-affiliation with the Digital Financial Asset Service Provider (PSP)*), for prospective independent commissioners?

Signed above the stamp.
4. Documents
Has it been completed with documents regarding the plans to be carried out after being appointed to the targeted position?
Attached work plan document drafted by the prospective principal party and at least containing:
(1) vision and mission
(2) programs to be carried out during the term; (3) targets to be achieved during the term; and (4) declaration letter of non-affiliation with the Digital Financial Asset Service Provider (PSP), for prospective independent commissioners.

We declare that the above entries are in accordance with the actual documents and if there are differences, corrections will be made.

Owner/Founder/Official of the Digital Financial Asset Service Provider (PSP)*) who is authorized *)
................

………………………………
*) strike out what is not necessary

PART C
SELF-ASSESSMENT FORMAT FOR BOARD OF DIRECTORS MEMBERS/BOARD OF COMMISSIONERS MEMBERS

A. SELF-ASSESSMENT INTEGRITY REQUIREMENTS

I INTEGRITY REQUIREMENTS YES NO DESCRIPTION
A. Capable of performing legal acts
B. Possessing good character and morals

Maintaining the confidentiality and security of consumer data and information
Never sentenced for proven criminal acts in the financial services sector whose sentence has been completed within the last 20 (twenty) years before nomination.
Never sentenced for proven criminal acts stipulated in the Indonesian Criminal Code (KUHP) and/or similar KUHP abroad with a prison sentence threat of 1 (one) year or more whose sentence has been completed within the last 10 (ten) years before nomination.
Never sentenced for proven other criminal acts with a prison sentence threat of 1 (one) year or more, whose sentence has been completed within the last 20 (twenty) years before nomination.

C. Possessing a commitment to comply with legislation and support the Financial Services Authority's policies

Never violated and willing to implement prudent principles in the financial services sector.
Never violated and willing to implement principles of legislation in the financial services sector.

D. Possessing a commitment to the healthy development of the Digital Financial Asset Service Provider (PSP)

Submission of the prospective Principal Party's plans for the operational development of the Digital Financial Asset Service Provider (PSP)
Never violated commitments agreed upon with the supervising and overseeing agency of the Digital Financial Asset Service Provider (PSP), namely failing to fulfill commitments to implement part or all of the agreed commitments
Possessing a commitment not to commit and/or repeat acts and/or actions that cause the person to be listed in the list of parties prohibited from being Principal Parties, for candidates who have previously been listed in the list of parties prohibited from being Principal Parties.
Never committed acts that provide unjust benefits to shareholders, Principal Parties, employees, and/or other parties that can harm or reduce consumer rights.
Never committed acts that are not in accordance with their authority or beyond their authority.
Never declared incapable of exercising their authority.
Possessing a commitment in handling and resolving consumer complaints specifically for Principal Parties overseeing the consumer protection function;

E. Not included as a party prohibited from becoming a Principal Party

B. SELF-ASSESSMENT FINANCIAL REPUTATION REQUIREMENTS

II FINANCIAL REPUTATION REQUIREMENTS YES NO DESCRIPTION

Does not have non-performing loans and/or financing.
Never declared bankrupt and/or never been a shareholder, who is not a shareholder, Board of Directors member, or Board of Commissioners member declared guilty of causing a company to be declared bankrupt within the last 5 (five) years before nomination.

C. SELF-ASSESSMENT COMPETENCY REQUIREMENTS

COMPETENCY REQUIREMENTS
ASSESSMENT SCALE
Description
Less
Once Less
Fair
Good
Very Good

A. Knowledge and/or experience in fields relevant to the target position at the Digital Financial Asset Service Provider (PSP)

Experience at Financial License Holders (LJK) and/or Digital Financial Asset Service Provider (PSP) that is relevant;
Filled in according to work experience history in the curriculum vitae.
Company Name : ...
Position : ...
Tenure : ...
Experience in positions relevant to the plans for the person to be appointed or employed
Expertise in the Digital Financial Asset Service Provider (PSP) field and/or other relevant industries.
Filled in with the last formal education and certifications relevant to the position at the Digital Financial Asset Service Provider (PSP)

B. Ability to manage and develop the Digital Financial Asset Service Provider (PSP) strategically

Adequate and relevant knowledge regarding their position
a. Knowledge regarding organizational structure, management, job descriptions, and responsibilities according to position.
Filled in with statements that become the basis for the assessment scale regarding the prospective Principal Party's knowledge of organizational structure, management, job descriptions, and responsibilities according to position. Statement 1a should be different from other statements because it explains a different aspect of competence.

b. Potential ability to conduct business process analysis, lead the organization, and manage human resources, including understanding risk management to achieve organizational goals.
Filled in with statements that become the basis for the assessment scale regarding the prospective Principal Party's potential ability to conduct business process analysis.
Statement 1b should be different from other statements because it explains a different aspect of competence.

c. Basic knowledge of supervision including internal control, specifically for Board of Commissioners members.
Filled in with statements that become the basis for the assessment scale regarding the prospective Principal Party's ability to manage human resources to achieve organizational goals.

Statement 1c should be different from other statements because it explains a different aspect of competence.

d. Basic knowledge related to leadership and conflict management, specifically for Board of Commissioners members and Board of Directors members.
Filled in with statements that become the basis for the assessment scale regarding the prospective Principal Party's basic knowledge of supervision including internal control and conflict management.

Statement 1d should be different from other statements because it explains a different aspect of competence.

e. Ability to evaluate company obligations
Filled in with statements that become the basis for the assessment scale regarding the prospective Principal Party's ability to evaluate company obligations or other technical aspects.

Statement 1e should be different from other statements because it explains a different aspect of competence.

Understanding of legislation
a. Understanding of legislation in the financial services sector, prioritizing legislation in the industry where the prospective Principal Party will serve.
Filled in with statements that become the basis for the assessment scale regarding the prospective Principal Party's understanding of legislation in the financial services sector, prioritizing legislation in the relevant industry.

Statement 2a should be different from other statements because it explains a different aspect of competence.

b. Basic understanding of other relevant legislation, including understanding of legislation regarding limited liability companies, the Financial Services Authority, bankruptcy, and money laundering criminal offenses and their implementing regulations. Filled in with statements that become the basis for the assessment scale regarding the prospective Principal Party's basic understanding of other relevant legislation, including understanding of legislation regarding limited liability companies, the Financial Services Authority, bankruptcy, labor fields, consumer protection, and money laundering criminal offenses, along with their implementing regulations.

Statement 2b should be different from other statements because it explains a different aspect of competence.

3. Ability to conduct strategic management in order to develop healthy business
1. For prospective Board of Directors members:
a. Ability to formulate the vision and mission of the company to be led, specifically for Board of Directors members.
Filled in with statements that become the basis for the assessment scale regarding the prospective Principal Party's ability to formulate the vision and mission of the company to be led.

Statement 1a should be different from other statements because it explains a different aspect of competence.

b. Ability to conduct analysis of the Digital Financial Asset Service Provider (PSP) situation.
Filled in with statements that become the basis for the assessment scale regarding the prospective Principal Party's ability to conduct company situation analysis.

Statement 1b should be different from other statements because it explains a different aspect of competence.

c. Conduct analysis of the internal condition development of the Digital Financial Asset Service Provider (PSP).
Filled in with statements that become the basis for the assessment scale regarding the prospective Principal Party's ability to conduct analysis of the company's internal condition development.

Statement 1c should be different from other statements because it explains a different aspect of competence.

d. Ability to set targets to be achieved related to the position held.
Filled in with statements that become the basis for the assessment scale regarding the prospective Principal Party's ability to set targets to be achieved related to the position held.

Statement 1d should be different from other statements because it explains a different aspect of competence.

e. Ability to design short-term, medium-term, and long-term strategies to achieve Digital Financial Asset Service Provider (PSP) targets, including the ability to anticipate future developments, such as the ability to prepare annual business plans and medium-term and long-term corporate plans using realistic and measurable assumptions; Filled in with statements that become the basis for the assessment scale regarding the prospective Principal Party's ability to design short-term, medium-term, and long-term strategies to achieve company targets.

Statement 1e should be different from other statements because it explains a different aspect of competence.

For prospective Board of Commissioners members:
a. Conduct basic analysis of the Digital Financial Asset Service Provider (PSP) situation Filled in with statements that become the basis for the assessment scale regarding the prospective Principal Party's ability to conduct basic analysis.

Statement 2a should be different from other statements because it explains a different aspect of competence.

b. Conduct analysis of the internal condition development of the Digital Financial Asset Service Provider (PSP), including the financial health condition of the Digital Financial Asset Service Provider (PSP), human resources, and information technology Filled in with statements that become the basis for the assessment scale regarding the prospective Principal Party's ability to conduct analysis of internal situation development.

Statement 2b should be different from other statements because it explains a different aspect of competence.

c. Ability to conduct analysis of Board of Directors policies, specifically for Board of Commissioners members.
Filled in with statements that become the basis for the assessment scale regarding the prospective Principal Party's ability to conduct policy analysis.

Statement 2c should be different from other statements because it explains a different aspect of competence.

Thus, this self-assessment is made truthfully, by parties having compliance, internal audit/remuneration and nomination functions*) at the Digital Financial Asset Service Provider (PSP) ….
(place), (date)
(signature)
(full name)
(position)
*) strike out what is not necessary

PART D
EXAMPLE FORMAT OF QUESTIONNAIRE

1. INDIVIDUAL PSP QUESTIONNAIRE
(Use a separate answer sheet if the available pages are insufficient)

1. Full name (including alias)
2. Other names (if any)
3. Place, date of birth
4. Address according to identity proof
5. Domicile/correspondence address (if different from address according to item 4)
6. Your professional qualifications and their periods (state fully)
7. Explain your profession/business activities and professional membership in the last two years. Explain including company name, business field, position, professional association followed, and other relevant information
8. NPWP (for Indonesian citizens) or equivalent (for foreign citizens)
9. Explain the source of funds you will use to buy shares of the Digital Financial Asset Service Provider (PSP)*), whether from:

Personal wealth?
Domestic loans?
Foreign loans?
Others?
(State the source)
10. Explain the companies you own (directly and indirectly/nominee)
11. Explain your obligations and responsibilities at that company
12. Are you currently a PSP at another Digital Financial Asset Service Provider (PSP)*)? Explain
13. Are you currently acting as a PSP at a non-Digital Financial Asset Service Provider (PSP) company?
14. Do you intend to buy the shares for long-term investment (strategic partner) purposes? If not, explain

15. Do you currently hold shares in the Digital Financial Asset Service Provider (PSP) whose shares you will buy (directly or indirectly)? Explain details with composition
16. How many shares will you buy? What is the purchase value? What is its proportion of the total shares of the Digital Financial Asset Service Provider (PSP)?
If you have previously held shares of the Digital Financial Asset Service Provider (PSP), what is the proportion if added to the number of shares you will buy now?
17. How will you exercise your voting rights at the Digital Financial Asset Service Provider (PSP), individually (you as an individual) or together with your business group/affiliates?
18. Do other Digital Financial Asset Service Provider (PSP) companies and/or non-Digital Financial Asset Service Provider (PSP) companies have business relationships with the Digital Financial Asset Service Provider (PSP) whose shares you will buy? Explain the type of business relationship in detail
19. Have you ever been asked to stop working, subjected to disciplinary actions/sanctions by a company, or subjected to prohibition sanctions to practice your profession?
20. Have you ever been declared bankrupt by authorities in Indonesia or other countries? Explain specifically
21. When you managed or owned a company, was that company ever declared bankrupt by authorities in Indonesia or other countries?
22. Have you, your company, or your business group ever been published and/or become the object of investigation by law enforcement authorities regarding criminal issues and/or disgraceful acts in the financial field?

23. Do you have a company whose license was ever frozen by authorities in Indonesia or other countries?
Explain
24. Do you or your company have licenses to conduct business in Indonesia or other countries? If true, explain the type of business field, how long, where?
If there are licenses that were frozen/cancelled, explain specifically
25. Have you, your company, or your business group ever had a licensing application in the banking/financial sector rejected by authorities in Indonesia or other countries? Explain in detail
26. Do you and/or your business group have plans to conduct other business in Indonesia or other countries that will affect the Digital Financial Asset Service Provider (PSP) whose shares you will buy?
Explain
27. Have you, your company, or your business group ever failed to meet obligations to other parties under the law in Indonesia or other countries (e.g., tax payments, credits, etc.)? Explain
28. Is your business activity or your company's/business group's business activity currently or will be guaranteed by other parties? Explain
29. Explain if there is other information that can provide data as consideration for the Financial Services Authority in processing your application

The undersigned hereby declares that:
1. I have understood the provisions related to my rights and obligations as a PSP who is a shareholder*) as regulated in the applicable provisions.
2. The information provided above is true, complete, and accurate.
3. I will inform the Financial Services Authority within 30 (thirty) days if there are significant changes in information.

4. If the above statements/information are proven to be untrue, then within 30 (thirty) days I am willing to resign from the PSP who is a shareholder*) of the Digital Financial Asset Service Provider (PSP).
*) strike out what is not necessary
(City), ...........…
(Signature above sufficient stamp)
(Name/Position)

2. LIST OF APPLICATION FORMS FOR LEGAL ENTITY PSP
(Use a separate answer sheet if the available pages are insufficient)

1. Full company name and complete address:
2. Place and date of company establishment:
3. Full name (representative of the company):
Position in the company:
4. Explain your obligations and responsibilities as the representative of the company:
5. Supervisory body/Regulator of your company:

Name of Institution :
Address :
Website :
Is your company's supervisory authority willing to accept the concept of consolidated supervision by the Financial Services Authority?
6. Main business of the company currently and in accordance with the company's articles of association:
7. Is your company currently a PSP at another Digital Financial Assets and Crypto Assets (IAKD) Provider?
Explain.
8. Is your company currently acting as a PSP at a non-IAKD Provider company?
Explain.
9. Does the company in question no. 8 have a business relationship with the IAKD Provider to be acquired or with the IAKD Provider in question no. 7?
Explain.
10. Does your company intend to become a controller/act as a PSP for long-term investment purposes (strategic partner)?
If Yes, explain your program.

11. Does your company currently hold shares of the IAKD Provider to be acquired?
If Yes, explain the composition in detail under whose name, and explain the reasons.
12. Detail the nominal amount/percentage of ownership to be acquired by your company and your business group.
13. Explain the use of your company's voting rights at the IAKD Provider to be acquired: Is it used individually (your company independently) or together with your business group as a single unit?
14. List the names and positions of the "key persons" in your company. Explain detailed information including nationality, academic and professional qualifications, and employment history for the last five years.
15. Provide detailed information on the entire list of shareholders in your company and explain their PSP status.
16. Does your company currently control, directly or indirectly, the IAKD Provider to be acquired?
If Yes, explain.
17. Has your company been published or been the object of investigation by competent authorities in Indonesia or other countries in criminal cases or other misconduct in the financial sector?
If Yes, explain, including the final outcome of the resolution.
18. Is your company a controller of another company whose business license has ever been revoked or recommended for revocation by authorities in Indonesia or other countries:
If Yes, explain.

19. Does your company or your business group have a license to conduct business in Indonesia or other countries that was then frozen/suspended/revoked?
If Yes, explain.
20. Has your company or your business group ever had its licensing application in the banking/financial sector rejected by authorities in Indonesia or other countries?
If Yes, explain.
21. Do you and/or your business group have plans to conduct other business in Indonesia or other countries that will affect the IAKD Provider to be acquired?
If Yes, explain.
22. Has your company or your business group ever failed to meet obligations (tax payments, credits, etc.) to other parties under the laws of Indonesia or other countries?
If Yes, explain.
23. Are the activities of your company/other companies in your business group currently or will be guaranteed by other parties?
If Yes, explain by whom and how that guarantee will be implemented.
24. Explain the source of funds that your company will use to acquire the IAKD Provider (answer must be accompanied by supporting documents).
25. Explain the reasons/other information that can strengthen the Financial Services Authority's consideration in processing the application for the acquisition of the IAKD Provider by your company (accompanied by supporting evidence).

The undersigned hereby declares that:

I have understood the provisions related to my rights and obligations as a PSP who is a shareholder*) as regulated in the applicable provisions.
The information provided above is true, complete, and accurate.
I will inform the Financial Services Authority within 30 (thirty) days if there are significant changes in information.
If the above statement/information is proven to be untrue, I am willing to resign from the PSP who is a shareholder*) of the IAKD Provider within 30 (thirty) days.
(City), ..........................
(Signature above stamp duty is sufficient)
Name & Position: _________________________________________________ Name of Company Represented: _________________________________ Legal basis for representation: ___________________________________ *) strike out what is not necessary

PART E
EXAMPLE FORMAT OF DECLARATION LETTER

1. DECLARATION LETTER FOR PSP
DECLARATION LETTER
(to be filled by prospective PSP *)
I, the undersigned:
Name: .....................................................................................
Address: .....................................................................................
Position: PSP *) hereby declare that I:
1. meet the integrity aspect, including:
a. have the legal capacity to perform legal acts as regulated in statutory regulations; b. have never been sentenced for proven criminal offenses in the financial services sector, namely criminal offenses at Financial License Institutions (LJK) where the sentence has been fully served within the last 20 (twenty) years prior to nomination;
c. have never been sentenced for proven criminal offenses, namely criminal offenses listed in the Criminal Code (KUHP) and/or similar foreign criminal codes with a prison sentence threat of 1 (one) year or more where the sentence has been fully served within the last 10 (ten) years prior to nomination;
d. have never been sentenced for proven other criminal acts with a prison sentence threat of 1 (one) year or more, including but not limited to corruption; money laundering; narcotics/psychotropics; smuggling; customs; excise; human trafficking; illegal arms trade; terrorism; counterfeiting money; in the tax field; in the forestry field; in the environmental field; in the marine and fisheries field where the sentence has been fully served within the last 20 (twenty) years prior to nomination; e. maintain the confidentiality and security of consumer data and information; f. have never violated and are willing to implement prudent principles in the financial services sector; g. have never violated and are willing to comply with statutory regulations in the financial services sector; h. have submitted the prospective PSP's plan for the operational development of the IAKD Provider;
i. have never violated commitments agreed upon with the supervising and supervisory agencies of the IAKD Provider;
j. have a commitment not to commit and/or repeat acts and/or actions that cause the person to be listed in the list of prohibited parties as Principal Parties, for candidates who have previously been listed in the list of prohibited parties as Principal Parties; k. have never committed acts that provide unjust benefits to shareholders, Principal Parties, employees, and/or other parties that can harm or reduce consumer rights;
l. have never committed acts that are not in accordance with their authority or beyond their authority;
m. have never been declared unable to exercise their authority; and n. are not included as parties prohibited from becoming Principal Parties.

2. meet the financial feasibility aspect, including:
a. have a good financial reputation; b. have financial capabilities that can support business development;
c. have a commitment to undertake necessary efforts if the company faces capital or liquidity difficulties.
3. are not currently undergoing a fit and proper assessment process at another LJK or IAKD Provider.
4. are not currently undergoing a Reassessment of Principal Parties process at another LJK or IAKD Provider.
5. are willing to accept the decision resulting from the fit and proper assessment.
6. will not file claims or lawsuits in any form against the fit and proper assessment results determined by the Financial Services Authority.
This declaration letter is made truthfully, and if it is later found that my statement is untrue, I am willing to be sued in court in accordance with applicable laws.

(date/month/year)
(signature)
(full name)
*) strike out what is not necessary
Stamp Duty

2. DECLARATION LETTER FOR BOARD OF DIRECTORS/BOARD OF COMMISSIONERS MEMBERS
DECLARATION LETTER
(to be filled by prospective Board of Directors and Board of Commissioners members) I, the undersigned:
Name: .................................................................................
Address: .................................................................................
Position: As President Director/Director/ Independent Commissioner Chief/Commissioner *) hereby declare that I:
1. meet the integrity aspect, including:
a. have the legal capacity to perform legal acts as regulated in statutory regulations; b. have never been sentenced for proven criminal offenses in the financial services sector, namely criminal offenses at LJK where the sentence has been fully served within the last 20 (twenty) years prior to nomination;
c. have never been sentenced for proven criminal offenses, namely criminal offenses listed in the Criminal Code (KUHP) and/or similar foreign criminal codes with a prison sentence threat of 1 (one) year or more where the sentence has been fully served within the last 10 (ten) years prior to nomination;
d. have never been sentenced for proven other criminal acts with a prison sentence threat of 1 (one) year or more, including but not limited to corruption; money laundering; narcotics/psychotropics; smuggling; customs; excise; human trafficking; illegal arms trade; terrorism; counterfeiting money; in the tax field; in the forestry field; in the environmental field; in the marine and fisheries field where the sentence has been fully served within the last 20 (twenty) years prior to nomination; e. maintain the confidentiality and security of consumer data and information; f. have never violated and are willing to implement prudent principles in the financial services sector; g. have never violated and are willing to comply with statutory regulations in the financial services sector; h. have submitted the prospective PSP's plan for the operational development of the IAKD Provider;
i. have never violated commitments agreed upon with the supervising and supervisory agencies of the IAKD Provider;
j. have a commitment not to commit and/or repeat acts and/or actions that cause the person to be listed in the list of prohibited parties as Principal Parties, for candidates who have previously been listed in the list of prohibited parties as Principal Parties; k. have never committed acts that provide unjust benefits to shareholders, Principal Parties, employees, and/or other parties that can harm or reduce consumer rights;
l. have never committed acts that are not in accordance with their authority or beyond their authority;
m. have never been declared unable to exercise their authority;

n. have a commitment in handling and resolving consumer complaints specifically for Principal Parties who oversee the consumer protection function*); and o. are not included as parties prohibited from becoming Principal Parties.
2. meet the financial reputation aspect, including:
a. do not have non-performing credits and/or financing; and b. have never been declared bankrupt and have never been a shareholder, who is not a shareholder, member of the board of directors, or member of the board of commissioners, who was declared guilty of causing a company to be declared bankrupt within the last 5 (five) years prior to nomination.
3. are not currently undergoing a Fit and Proper Assessment process at another LJK or IAKD Provider.
4. are not currently undergoing a Reassessment of Principal Parties process at another LJK or IAKD Provider.
5. are willing to accept the decision resulting from the fit and proper assessment.
6. will not file claims or lawsuits in any form against the fit and proper assessment results determined by the Financial Services Authority.
This declaration letter is made truthfully, and if it is later found that my statement is untrue, I am willing to be sued in court in accordance with applicable laws.

(date/month/year)
(signature)
(full name)
*) strike out what is not necessary
Stamp Duty

3. DECLARATION LETTER FOR INDEPENDENT COMMISSIONER
DECLARATION LETTER
(to be filled by prospective independent commissioner) I, the undersigned:
Name: ..........................................................
Place, Date of Birth: ...........................................................
Address: ..........................................................
Position: Prospective Independent Commissioner .........................................
(name of company to be filled) hereby declare that, I:
1. Do not have an affiliation relationship with members of the Board of Directors, members of the Board of Commissioners, or shareholders of the same IAKD Provider*) and;
2. Have never been a member of the Board of Directors, member of the Board of Commissioners, or held a position 1 (one) level below the Board of Directors at the same IAKD Provider*) or another company that has an affiliation relationship with the IAKD Provider*) within the period in accordance with applicable statutory regulations.
This declaration letter is made truthfully, and if it is later found that my statement is untrue, I am willing to resign as Independent Commissioner ....... *) *) fill in the company name

(date/month/year)
(signature)
...............................
(full name)
Stamp Duty

PART F
CURRICULUM VITAE LIST
4x6 cm
Personal Data
Name: ....................................................
Place/Date of Birth: ....................................................
Gender: ....................................................
Religion: ....................................................
Nationality: ....................................................
National Identity Number (NIK): ....................................................
Address: ....................................................
City .....
Province .....
Postal Code .....
Telephone Number: ....................................................
Mobile Phone Number
Applicant: ....................................................
Educational History

Formal
Education Level
Major/Specialization
Name/Place
Year of Graduation
Non-Formal (Certified)
Course/Seminar
Organizer
Year
Professional Education (Profession)
Certification
Organizer
Year of Graduation

This copy is in accordance with the original
Head of Legal Development Directorate
Legal Department signed.
Aat Windradi

Work History
Company Name
Position
Description of
Main Duties
Date of
Start Working
Date of
Resignation
Reason for Leaving
.....,............ 20.....
Applicant,
...........................................
.....
(Clear name and signature)

Established in Jakarta on 29 September 2025
EXECUTIVE HEAD OF SUPERVISOR FOR FINANCIAL TECHNOLOGY INNOVATION SECTOR, DIGITAL FINANCIAL ASSETS AND CRYPTO ASSETS FINANCIAL SERVICES AUTHORITY REPUBLIC OF INDONESIA,

HASAN FAWZI
Stamp Duty signed.

APPENDIX II
LETTER OF THE FINANCIAL SERVICES AUTHORITY
REPUBLIC OF INDONESIA
NUMBER 21/SEOJK.07/2025
CONCERNING
FIT AND PROPER ASSESSMENT AND REASSESSMENT FOR PRINCIPAL PARTIES IN THE FINANCIAL TECHNOLOGY INNOVATION SECTOR, DIGITAL FINANCIAL ASSETS AND CRYPTO ASSETS

TABLE OF PRINCIPAL PARTY CRITERIA REQUIRING CLARIFICATION PROCESS AT IAKD PROVIDERS

Target Position Experience
Commissioner
Chief Commissioner
Independent Commissioner
Director
President Director
Commissioner N
N
Y
Chief Commissioner
N
N
1
Y
Independent Commissioner
N
N
1
N
1
Y
Y
Director
N
N
Y
N
3
N
4
President Director
N
N
Y
N
N
3
Official at the level of
Director or level 2 in ministries/institutions with functions related to the financial sector N N Y No experience Y

Explanation:
Commissioner/Chief Commissioner
= Commissioner/Chief Commissioner is a company organ tasked with general and/or specific supervision in accordance with the articles of association and providing advice to the Board of Directors for IAKD Providers. Director/President Director = Director/President Director is a company organ authorized and fully responsible for managing the company for the benefit of the company, in accordance with the company's purpose and objectives, and representing the company, both inside and outside of court in accordance with the articles of association for IAKD Providers. Y = Clarification must be conducted for the prospective Principal Party. N = Clarification is not required for the prospective Principal Party. N1 = Clarification is not required for the prospective Principal Party, except for commissioners or chief commissioners who will serve as commissioners or chief commissioners at an IAKD Provider with larger size and complexity. N2 = Clarification is not required for the prospective Principal Party, except for commissioners who will serve as chief commissioners at a different company than previously.

This copy is in accordance with the original
Head of Legal Development Directorate
Legal Department signed.
Aat Windradi

N3 = Clarification is not required for the prospective Principal Party, except for directors or president directors who will serve as directors or president directors at an IAKD Provider with larger size and complexity. N4 = Clarification is not required for the prospective Principal Party, except for directors who will serve as president directors at a different IAKD Provider than previously.

HASAN FAWZI signed.

Lineage: No known changes

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